Object

Representation ID: 14490

Received: 14/12/2020

Respondent: Rosconn Strategic Land

Agent: DS Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Barton Willmore, on behalf of various developers, have carried out a Housing Need Report in response to the DSP, focusing on the calculation of housing need in the DSP 2020-2036 and whether the approach taken in the DSP aligns with the NPPF. The report concluded:

- The minimum need for Solihull (807 dpa) will need to be increased to account for expected job growth from the UK Central Hub, to 1,036 and 1,248 dpa.
- The deficit in unmet housing need from Birmingham City being delivered by HMA Local Plans amounts to a minimum of between 11,294 and 13,101 dwellings up to 2031, a significant increase from the 2,597 dwellings concluded by the 2020 Position Statement. This increases when the unmet need from the Black Country is considered and additional unmet need will be created post 2031.

The DSP indicates a contribution of 2,015 dwellings towards Birmingham’s identified shortfall of 37,900 to 2031. However, the recent Greater Birmingham Black Country Housing Market Area (“GBBC HMA”) study claims the total Birmingham shortfall has diminished to 2,597 dwellings. This appears somewhat a surprising figure considering the SGS minimum shortfall was identified as 28,000 dwellings in 2018 and is considered to be a highly optimistic prediction.
In its conclusions the GBBC HMA study does not state that the scale of the post 2031 shortfall is not yet known and the shortfall for the whole of the combined authorities HMA post 2031 cannot yet be calculated. 2.5 It follows that, for the reasons summarised here the DSP is clearly unsound by reference to all of the tests set out in paragraph 35 of the NPPF.