Object

Representation ID: 21201

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy CSP1 – Development Strategy
Following the publication of the revised Standard Methodology for calculating housing need in December, which included an urban uplift of 35% applicable to the 20 largest cities and urban areas, the BCAs have calculated that their combined local housing need for the Plan period is 76,076 homes.
Policy CSP1 goes on to set out how the BCAs will go about meeting this need. It says that it expects the Plan’s housing allocations to deliver some 47,837 dwellings, based on the following components (see Table 1 overleaf):

Table 1: Black Country Development Strategy 2020-2039
Location Housing (net new homes)
Strategic Centre 9,561
Core Regeneration Areas 11,208
Neighbourhood Growth Areas 6,792
Towns and Neighbourhoods Areas 12,625
Small windfall housing sites (outside Strategic Centres) 7,651
Total Black Country 47,837
To be exported through Duty to Co-operate 28,239
Grand Total 76,076

Evidently, even if the Council’s planned supply delivers in the way anticipated in the Draft Plan, the BCAs will under-deliver against their local housing need within their administrative boundaries by 28,239 dwellings.

However, in reality, the shortfall is probably even greater. We say this because the Plan, as drafted, does not propose to accommodate any additional homes to help address the unmet need arising from Birmingham and elsewhere in the wider housing market area.

As outlined in Table 1, the Plan proposes to export over 28,000 dwellings to neighbouring authorities through the Duty to Co-operate. The Duty to Co-operate Statement, published by the BCAs as part of the Draft Plan evidence base, concludes that neighbouring authorities can potentially accommodate up to 14,750 homes, as follows:
• Cannock Chase – Between 500 and 2,500 homes;
• Lichfield – Between 2,000 to meet Black Country needs out of a contribution of 2,665 to the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) as a whole;
• South Staffordshire – Up to 4,000 homes;
• Shropshire – 1,500 homes.
• Stafford – Up to 2,000 homes
• Solihull – A proportion of the 2,105 dwelling contribution identified in the submitted Local Plan to the GBBCHMA
• Telford and Wrekin – 3,700 homes.

Whilst the above contributions are to be tested as the Local Plans for some neighbouring authorities are progressed (namely Cannock Chase, Lichfield, South Staffordshire, Shropshire and Solihull), there is certainly no guarantee that these additional dwellings will come forward to address the shortfall currently faced by the BCAs. This is evident in the case of Solihull who were expected to allocate a proportion of their 2,105 dwelling contribution identified in its submitted Local Plan to the Black Country. However, Solihull MBC’s view expressed at the Examination of its new Local Plan is that it will now no longer plan to take any unmet need from the Black Country up to and post 2031 and will, instead, look to exclusively assist in meeting the unmet needs of Birmingham.

Moreover, the Duty to Co-operate Statement suggests that the level of housing that Stafford Borough and Telford and Wrekin are able to accommodate should be viewed as ‘minimums’, however, there is no evidence to suggest that this is the case, as the Draft Plan is not supported by any Statements of Common Ground, or other similar document, which commits these authorities to taking a proportion of the Black Country’s unmet housing needs.

In any event, if the BCA’s assumptions around how their unmet housing need will be distributed amongst the neighbouring local authorities are correct, this would still leave a shortfall of some 13,489 dwellings that will need to be allocated. This being the case, the BCAs are failing to plan to meet their identified need, contrary to the provisions of the NPPF. In order to address this, the BCAs must, in our view, look at allocating additional sites in the Plan to help meets the Black Country’s housing requirements over the Plan period.