Draft Local Plan - Supplementary Consultation

Birmingham City Council agree that there are no special circumstances justifying an alternative approach.
In accordance with the NPPF (para 60), any needs that cannot be met within neighbouring areas should also be taken into account in addition to the local housing need figure in establishing the amount of land to be planned for. The provision of 2000 additional dwellings to meet the HMA Shortfall was identified in the Draft Local Plan published in 2016 and remains an important contribution towards the HMA shortfall and the Table on Page 13 of the Consultation document shows that sufficient land supply has already been identified to meet local housing need as well as those 2,000 additional homes.
However, Birmingham City Council (BCC) has some concerns that this Consultation does not specifically address any potential revision to the contribution that Solihull is making towards the HMA shortfall as stated in Paragraph 5 of the Consultation Document.
A large amount of evidence has come forward since the last consultation (Draft Local Plan Stage (2016)) including the addition of more than 70 sites considered in this consultation as well as the publication of the West Midlands Strategic Growth Study (February 2018) carried out by GL Hearn. Scenarios which test the validity of the existing spatial strategy and the possibility of significantly higher housing provision and growth have yet to be fully considered and assessed through a sustainability appraisal process (even if this approach and evidence may go on to show that such higher levels are not justifiably achievable or deliverable).
Since the GL Hearn Study was published in February 2018, local planning authorities such as South Staffs and Lichfield have presented and tested scenarios within their local plan consultation documents for significant levels of growth over and above their local Housing Need in line with the Study. The Solihull Supplementary Consultation states that any potential to revise the contribution towards the HMA shortfall beyond the 2,000 dwellings already identified would be done as part of the Submission Draft Plan stage.
BCC would therefore need assurances that this course of action has been fully considered and implemented prior to Submission Draft Plan stage to demonstrate that Duty to Co-operate obligations have been fully considered and met in line with NPPF requirements. Such options would also need to be considered through the Sustainability Assessment process and the potential effects (positive or negative) any options may have on adjoining areas.

Birmingham City Council has no specific comments on the Site Selection methodology itself. However, it is not clear whether the assessment of the 70+ additional 'call for sites' submissions since the Draft Plan stage has contributed positively to the overall land supply already identified in the Local Housing Need section of the document. If so, this would provide some additional capacity on top of the 2,000 additional homes already identified to meet the HMA shortfall.

As a key stakeholder in the development of the UK Central Hub, Birmingham City Council support the approach being taken particularly in relation to land at Arden Cross and at the NEC and the promotion of the site for high quality, high density mixed use development.
The delivery 2,500 dwellings at the NEC within the plan period will be subject to market conditions.

BCC support the proposal in the Consultation document to remove certain villages/settlements from their current status of washed over green belt to help boost windfall housing provision and help maximise the delivery of sustainable homes.