Object

Representation ID: 18566

Received: 11/10/2021

Respondent: Dudley Labour Group

Agent: Councillor Qadar Zada

[Housing numbers]

We consider there are three fundamental aspects of the process which the BCP has failed to address adequality, which, as a consequence, discredit the proposals and places them at risk of potential legal action. These include the determination of the housing need, timing, duration and nature of the consultation process (including scrutiny) and equality considerations.

Determination of housing need

The government has indicated that the Black Country has a requirement for 76,000 additional new homes and the proposals produce just 46,000 of which Dudley is proposing sites for 13,000 homes, a number that appears to be a contribution that is a disproportionately high level compared to other Boroughs. No information has been forthcoming about how government has calculated these figures or why Dudley is providing more than one quarter of the total proposed and despite
asking at every opportunity, the Authority has refused to explore this further


We consider that Dudley Council has not provided sufficient challenge regarding;


Projected Population Figures


The figures come from the Office for National Statistics (ONS). The ONS have assumed growth will continue at the same average rate that it has for the last 20 years. The ONS states specifically that it has not taken account of the impact of Brexit in it’s projections and assumes the same rate of growth will continue into the future. The figures also do not
appear to account for the number of excess deaths, some of which are related to covid. It also does not appear to take account of the falling birth rate. Instead the figures presented by the ONS seem to be very
much a worst case scenario and should not be used for planning purposes.


The ONS produced a second dataset based on the previous ten years growth that takes greater account of the changes to net migration since the Brexit vote in 2016. Using this dataset, which is likely to be more realistic, the Black Country will require 10,000 fewer homes during the Plan period. Given that the plan projects that 7,000 homes will have to be built on Greenbelt land; the use of this dataset would mean that no homes will have to be built on the greenbelt or green spaces at all.


It seems inconceivable that green belt and green spaces could be lost because “someone” has decided to use an unrealistic worse case growth scenario. We believe that once greenbelt and green spaces are allocated for housing these sites will be amongst the first of the sites within the Plan to be developed, not the last as has been suggested.


If the decision to go with a particular set of forecasts has been made at Ministerial level, which we suspect, then if the new ministerial team is minded to review them, there is little point in proceeding.


Finally, on this issue, planning does not exist in isolation. It is there to help meet future needs. If those future needs are assessed wrongly the plan will be wrong. We are convinced the best strategy is to challenge the future growth projections as these are inaccurate and undermine the whole plan. The Plan should not be approved by the Council until the projections have been re-examined and adjusted to be more realistic rather than presenting the worst case scenario.