Issue and Options 2023

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Form ID: 74289
Respondent: Dudley MBC

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We welcome the acknowledgement that Stratford-on-Avon falls within the Greater Birmingham and Black Country Market Area (GBBCHMA) and the recognition that homes built within the district can contribute to the GBBCHMAs unmet housing needs. We welcome the positive approach taken to date in respect of seeking to address the housing shortfall arising from the GBBCHMA. Under the Duty to Cooperate, we continue to support ongoing joint working with the South Warwickshire authorities to address the GBBCHMA housing shortfall going beyond 2031 and up to the end of the South Warwickshire Local Plan (SWLP) period of 2050. The approach of identifying reserve sites within Stratford-on-Avon that contributes towards the housing shortfall of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) up to 2031 is welcomed. It is understood that these sites, if adopted via the Site Allocations Plan for Stratford-on-Avon, will carry forward into the South Warwickshire Local Plan. The consultation SWLP refers to the recent Birmingham Local Plan Issues and Options consultation (2022) which identifies a significant potential shortfall of 78,415 homes. It states that there may be additional housing shortfalls arising from the Black Country authorities. Whilst the Black Country authorities have recently agreed to cease work on the joint Black Country Local Plan (October 2022) it should be recognised that the most recent consultation on the plan (Regulation 18, Draft Plan in Summer 2021) did identify a significant housing shortfall of 28,239 homes for the period 2020-2039. The scale of the potential shortfall should therefore be recognised. Whilst the approach taken to date in respect of reserve sites identified in Stratford-on-Avon for unmet housing needs up to 2031 is supported, we consider that the approach taken in the SWLP going forward (up to 2050) should reflect the potentially significant scale of the GBBCHMA shortfall (noting that this is subject to further evidence base work as part of the Local Plan process for the GBBCHMA partner authorities.) We note that the SWLP refers to the accompanying Sustainability Appraisal testing options of an additional 5,000 and 10,000 homes for unmet housing needs. At page 109 of the SWLP, it states that given the size of South Warwickshire it is considered that any additional needs can be accommodated outside of any protected areas (e.g., Cotswolds National Landscape/AONB) with one exception possibly being areas designated as Green Belt.

It is noted that the ‘refined’ spatial options for growth include those focused on sustainable transport corridors (rail and bus) and areas for economic growth. Within these options there is the potential for the delivery of new settlements. In respect of helping to address the GBBCHMA housing shortfall, we consider that development in the most sustainable locations which provides sustainable commuting links to the wider conurbation would be appropriate. We consider that new settlements would also be appropriate, as they would generate a significant scale of housing with associated employment uses, justifying significant infrastructure and transport improvements including new and improved commuting links. We consider that development in and around those locations that are or could be major sources of employment in South Warwickshire would also be appropriate as it could provide a balance of homes and jobs and reduce the need to travel.

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