We agree with the Inspector that considerably greater provision for new housing must be made - in part to meet unmet need in the SHA; in part to assist with meeting unmet need across the Region; and, fundamentally to provide a substantial and deliverable degree of flexibility should site allocations not come forward as expected. Past performance has not met promised targets by a large degree as Councils have sought to restrict land allocations to the minimum degree necessary.
This may be understandable but is nevertheless unjustified. In order to meet the over-arching objectives of the NPPF, a basic minimum requirement is that clear and deliverable flexibility must be built in to not just meet but also exceed stated targets and deliver essential development through the presumption in favour of sustainable development.
By way of example, the Birmingham Development Plan identifies the need for 37,900 houses to be supplied in Authorities outside its own area. The means by which these are to be supplied is not specified but it is suggested that additional focus is required both in the SHMA AND in neighbouring Authorities. It will NOT be acceptable just to say that discussions are ongoing as a means of complying with the Duty to Cooperate and actually supplying the needed homes.
It is not considered that
● there is a sufficient degree of flexibility in the modified Plan to ensure that housing requirements are met, and
● the sites which the Council have identified to meet their estimated need are neither the most appropriate nor the most sustainable.
● As a result, it is suggested that the Plan is still not "sound" in terms of being positively prepared, justified, effective or consistent with national policy.