Object

Representation ID: 23213

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP1 – Development Strategy

HD a number of concerns with the overall housing requirement identified in the Plan and the sources of housing land supply that have been identified to meet the target. This has consequential implications for the quantum of development that will be needed to be exported to other local authority areas.


Housing Supply

Policy CSP1 identifies a housing requirement across the Black Country Authorities (BCA) of
76,076 dwellings over the period 2020 – 2039. However, only capacity for 47,837 of these has been identified leaving a shortfall of 28,239 dwellings against what is needed and will be
directed toward other authorities through the duty to cooperate.

Table 2 of the draft Plan suggests that a total of 76,076 dwellings is required during the Plan Period. This is, however, less than the Standard Method housing requirement identified by the Black Country Housing Market Assessment 2021 (“BCHMA”), produced by the Black Country Authorities. At paragraph 4.13 it is advised that “the final housing need in the Black Country, assessed using the revised Standard Method, is 4,019 per year”. The Plan period runs from 2020 to 2039. As such, the BCHMA concludes with a total of 76,361 dwellings required during the course of the plan period (4,019dpa x 19 years). As a minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents in accordance with Paragraph 61 of the Framework.

Paragraph 4.14 of the BCHMA advises that whilst paragraph 010 of the PPG identifies a series of circumstances where it may be appropriate to pursue a higher housing needs figure than is indicated by the Standard Method “this assessment is carried out on the basis that the Standard Method figure set out in the above will apply”. That being the case, the BCHMA does not test whether the minimum standard of housing requirement figure should be increased, contrary to the requirements of the PPG.

Paragraph ID:2a – 010 – 20201216, of the PPG advises that these circumstances where it may be appropriate to explore a higher housing figure include, but are not limited to, situations where increases in housing need are likely to exceed past trends because of:

• Growth strategies for the area that are likely to be deliverable;
• Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• An authority agreeing to take on unmet need from neighbouring authorities.


Economic Growth

We are not aware of any assessment to establish whether the minimum Standard Method housing requirement should be exceeded. It could be the case that the minimum Standard Method housing requirement is not sufficient to meet the housing needs of the Black Country. In this regard we note that Table 5.1 of the BCHMA identifies that the percentage of people of working age in the Black Country will be less in 2039 than it is in 2020. In order to meet the emerging Plan’s economic growth aspirations it is necessary to ensure that a sufficient number of houses are provided to meet the jobs which will be created during the course of the Plan Period. An assessment should be undertaken to establish if the housing requirement needs to be uplifted to support economic growth.

Summary

Drawing these matters together, it is our view that the housing requirement within the plan is not justified given that it is below the minimum Standard Method requirement, and there appears to have been no supporting work undertaken to establish if there is a requirement for an uplift to the minimum Standard Method Housing target on economic of affordability grounds.