Issue and Options 2023

There seems little difference in the figures provided for the different options especially in the long-term. Given the many assumptions that must be involved in making these estimates, how significant are these small differences?

There seems little difference in the figures provided for the different options especially in the long-term. Given the many assumptions that must be involved in making these estimates, how significant are these small differences?

Neutral

Neutral

Neutral

Neutral

Neutral

We would like to make the following additional points as there was not an option to expand on answers in the relevant sections: (S1) Without the Local Nature Recovery Strategy there is no guarantee that any green or blue corridors identified by SWLP will have a beneficial impact on nature. For this reason we suggest that neither options S1a or S1b are appropriate. It would be better to identify corridors after a strategy has been produced. (S2) Certain types of intensification in town centres should be supported for example the conversion of unused retail property, including upper floors, to provide housing. (S6) The statistical underpinning of this section is flawed. The 54% figure cited in favour of Green Belt development is, at best, misleading. This is not a representative figure because the respondents to the first consultation were not a representative sample. Analysis of respondents on this issue shows that 35% were developers and 10% were landowners or businesses, suggesting that only a small proportion of other respondents were in favour (see Consultation Statement January 2022, p275). This skew towards groups with a vested interest means that this statistic should not be used as justification for pursuing this strategy. We are concerned that improper analysis and misleading conclusions may be taken forward and used to provide evidence of exceptional circumstances for developing the Green Belt. Green Belt boundary review does not need to happen (from a policy perspective) and should not happen (from an environmental safeguarding and wellbeing perspective). If it were to happen, it should be part of a strategic West Midlands Review rather than a piecemeal exercise (West Midlands Land Commission, 2017). In view of all of this we argue that the process should be halted and the parameters of the Local Plan shifted so that Green Belt development is not assumed. The non-Green Belt growth options that were explored in Part 1 of the spatial growth workshops should be prioritised and communicated and the wishes of local residents should be listened to.

No

The HEDNA should be revised using more recent data to better reflect future economic and demographic projections both post-Pandemic and post-Brexit. Data from 2022 is too close to the emergence from the pandemic to provide a reliable trend. Revised data should then be used to inform the choice of spatial growth strategy. This logical ordering does not appear to have been followed in the plan process to date: the HEDNA was published in November 2022 and yet it seems the key direction for the spatial growth strategies were arrived at in September 2022 following the June/July workshops. This clearly places the cart before the horse and calls into question both the reasoning and motivation for publishing options reliant on Green Belt development as a focus for the new local plan proposals.

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Yes

Policies supporting small-scale employment opportunities are particularly important. They would help the development of opportunities in rural areas which in turn would support the diversification of the rural economy, and reduce the need for people to travel for work.

No

The population growth analysis has been conducted too close to the emergence from the Covid-19 pandemic to generate reliable projections. It should be revisited to provide a better understanding of emerging trends. Following that it should be used in the correct order of process, to inform decision-making rather than being published afterwards to retrospectively justify decisions. Crucially, housing need should just be a “starting point” and local councils should work with their communities to determine an appropriate level. As the Secretary of State for Levelling Up said in his written statement (6.12.22): “It will be up to local authorities, working with their communities, to determine how many homes can actually be built, taking into account what should be protected in each area - be that our precious Green Belt or national parks, the character or an area, or heritage assets. It will also be up to them to increase the proportion of affordable housing if they wish.”