No representation is made regarding the calculation and categorisation of housing numbers which will be assessed by others although it is considered that insufficient flexibility has been included to provide for unmet need across the Region.
However, 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.
Of greater concern is that sites are being "allocated" by way of these modifications and seemingly based on the Sustainability Appraisal Report which has not been the subject of transparent debate. As a result, it is believed that there are clear flaws in the assessment process.