Object

Representation ID: 23215

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Housing Supply

We also have a number of concerns with the deliverability of various sources of the housing demand supply identified by the Plan. Table 3 – Black Country Housing Land Supply Indicative Phasing 2020-2039, identifies the various sources of housing land supply. We have concerns with the sources of supply, including:

• Sites with Other Commitment – The sites in this category are expected to deliver
3,802 dwellings during the plan period. It is understood from the BCAs SHLAAs that an “other commitment” is a site with a resolution to grant planning permission but the Section 106 has not been signed. This source of supply is discounted by 10% in order to allow for non-delivery. It is not clear from the draft Plan how the 10% discount rate has been calculated. However, it is noted that the SHLAAs (e.g. Walsall SHLAA 2019 paragraph 17) advise that Other Commitments are discounted by 10% as the adopted Black Country Core Strategy (“BCCS”) applied a discount rate of 10% to commitments. It is advised that a discount rate that is based on past trends may not be an appropriate way of establishing future delivery rates.

Whilst this may be the case, we would also suggest that it is equally unreliable to take a discount rate from the adopted BCCS, which was published in 2011. The BCCS is in excess of ten years old, and its supporting evidence documents even older. At the very least, a past trend-based analysis should be undertaken in order to see if the discount rate is robust for the Other Commitments category. There is insufficient information available to determine whether the discount rate suggested is robust.




Furthermore, the age of these resolutions is not clear. It is our view that is the resolution to grant planning permission is more than 6 months old the site should not be included as a source of supply.

• Existing Housing Allocations in Strategic Centres – These sites are expected to provide 4,973 dwellings. This excludes those sites within the Strategic Centres that already have the benefit of planning permission, a resolution to grant planning permission, or are completed. The Walsall Site Allocations Document was adopted in
2019. The Dudley Borough Development Strategy was adopted in February 2017 and other various Dudley MBC AAPs were adopted between 2011 and 2017. The Sandwell Site Allocations and Delivery DPD was adopted in December 2012. The Wolverhampton Area Action Plans were adopted between 2014 and 2016. In most cases there has been a significant period for the sites allocated for development in the Strategic Centre to come forward for development, particularly at a time when multiple housebuilders have been actively searching for any potentially deliverable site searching due to a severe lack of supply. In this context, the fact that these sites have not delivered suggests that there may be problems with their delivery. That being the case, the 10% discount rate suggested for these sites is entirely unrealistic.

• Occupied Employment Land - Occupied employment land is expected to deliver
3,091 dwellings towards the total housing requirement. This should not be included as a source of supply. There is no guarantee if or when such sites will come forward for development. Landowner’s intentions may change during the Plan Period. In addition, we have frequently reviewed such sites that have been allocated in the aforementionedDevelopment Plan Documents with the site owners and/or housebuilders look for sites. In doing so, we have found that industrial values outweigh residential values in large parts of the Black Country. Furthermore, even if land values are similar or slightly exceed the employment values, owner occupiers have no incentive to move because there are no alternative units to move to or the cost of a new unit outweighs the land receipt, whilst landlords will lose their income. Consequently, it simply may not be economic to bring a site forward for residential development and/or an attractive proposition for the owner.

This has already been proven through the adopted development plan, where most of the allocated sites have remained in employment use.


It is also pertinent to note that there is a significant shortfall of employment land within the Black Country, and across the conurbation. Whilst new employment allocations are proposed by the Plan these will be new build estates where rents will be significantly greater than second-hand stock. It is unlikely that businesses that are located on the poorer quality employment sites will be able to afford to rent or buy a new premises. Secondary, and lower cost stock plays a vital role in the West Midlands economy. Losing land of this type to residential use may result in businesses closing. We are, therefore, extremely concerned that this source of supply could also have a detrimental effect on the supply of employment land through the plan area.

On the rare occasion currently occupied employment sites come forward for development during the Plan Period they will be part of the proposed windfall allowance.
• Green Belt sites - No discount is applied to Green Belt land release sites. In it simply unrealistic to assume every single predicted house will come forward on these sites in the plan period. It is possible that not all sites come forward or the lead in time is longer than expected (Langley SUE in the Birmingham Development Plan is a prime example of this where delivery was originally predicted to have commenced by now, and this has already been pushed back by several years, with the prospect of this timeframe slipping further); that when a planning application is submitted the aspirational target figures are not met for the site when the long list of policy requirements within the BCP have been properly accounted for; and/or not all of the site is delivered in the plan period.

• Other Allocations - The “Other” allocations within the plan have a 10% discount rate applied. It is not clear how this discount rate has been calculated. However, given the significant proportion of the allocations in the draft Plan that are not Green Belt are brownfield sites they are likely to have delivery constraints. A 10% discount rate is inadequate.

• Additional Site Capacity in Strategic Centres - The sites in this category are due to be identified and allocated through subsequent Local Plans produced later into the plan period. We are concerned that the housing figures identified for these areas are not robust, and ultimately the plan making process will find that there is not the capacity to deliver this level of development within future Local Plans. A substantial discount rates should, therefore, be applied to sites in this category.

Conclusion

In conclusion, we are concerned that the identified sources of supply will be incapable of meeting the housing requirement identified by the Plan. In addition, given the housing requirement should be a minimum there is clearly a distinct advantage in erring on the side of caution, and applying robust and realistic lapse rates to the various sources of supply as if additional housing does come forward this will be of no detriment to the Plan. However, a housing delivery shortfall has the potential to be extremely problematic, causing five-year housing land supply issues, failing the Housing Delivery Test and failing to provide much needed market and affordable housing within the Black Country for those that need it.