Comment

Representation ID: 9551

Received: 15/03/2019

Respondent: Richard Cobb Planning

The methodology imposed at national level and using the 2014 based figures probably produces a higher figure than the latest projections (2016) indicate are necessary. The Council are yet to reach agreement with adjoining Councils in terms its contribution to the HMA shortfall, and unless the Council make additional provision in their Local Plan it is likely that the Council will not be able to fulfil its duty to cooperate. More housing land may need to be allocated in the green belt. The proposed rate of delivery is far above the highest that has been achieved in Borough and unlikely this can be sustained. The 2016 based projection from GL Hearn is more realistic. It is likely that some of the sites will not be capable of delivery because of ownership and infrastructure issues. The Council hasn't allocated smaller sites and is relying on a handful of larger sites which are unlikely to deliver the housing numbers. Failed to consider wider components of growth, omitting areas of employment such as in Balsall Common, Knowle and Dickens Heath. No provision is made to encourage employment sustainability.