A number of representors, particularly from the development sector, consider that the DtC has not been met in respect of the Birmingham Development Plan [BDP], because explicit provision for the unmet housing need from the City has not been made in the CS. My colleague who examined the North Warwickshire Core Strategy said that an early review of that plan would ‘…be a sensible and pragmatic approach’. Whilst the Inspector’s Interim Findings on the BDP were issued in the week that the matter was discussed at the Hearing, it remains true to say that Birmingham cannot confirm the scale of its OAN that it is unable to meet within its own administrative boundary.
The submitted Memorandum of Understanding between the Council and Birmingham City Council records agreement across all relevant areas, including the level and distribution of housing. The City Council has welcomed the commitment to a review of the CS should the housing shortfall that has been identified in the Birmingham HMA lead to an increase in housing provision within Stratford District. In my view the review mechanism represents an effective policy on this strategic cross boundary matter, again as required by the Guidance.
In any event, prior to closing the Hearing sessions, the Council put forward a reserve sites policy in order to address the reservations that were expressed at the Hearing that a review would not be capable of meeting the need at the point at which it was identified. Although various parties from the development sector argue that the unmet need arises now I cannot accept this claim when the respective Councils have yet to determine or agree the quantum of the shortfall to be met within Stratford. Nevertheless at the point where the scale of the need crystallizes the reserve sites policy would enable the Council to meet that need much earlier than a review. It would also be less resource intensive. Noting that the BDP is at a similar stage of preparation it would appear to be counterproductive to proceed to adopt this CS only to have to move straight on to a review once the BDP has been adopted. A reserve sites policy would better reflect paragraph 14 of the Framework, which says a plan should meet OAN with sufficient flexibility to adapt to rapid change.
Although the Council has said that the review process can be delivered by 2019 a reserve sites policy would be even more flexible. Whilst there can be no certainty as to what scale of reserve might be required I intend to consider this matter in my final report once the OAN has been agreed. However I note that the main modification proposes 10 % and that the Council’s reservation in going further seems to be that, above this scale, a review would be appropriate. I accept that there is a level above which a review would be sensible. For all of the reasons set out above, and taking all other matters into account, I am satisfied that the DtC has been met.
But just try a reserve sites policy for London overspill – where increased need would top 30% for some authorities if you had no Green Belt review according to NLP figures.