Comment

Representation ID: 23279

Received: 05/10/2021

Respondent: IM Land

Agent: RPS

Comments on the ‘offers’ from neighbours


In any event, RPS is of the view that the current contributions ‘offered’ by neighbouring authorities are insufficient to remedy the scale of the shortfall facing the Black Country (even after the potential supply from within the ABCA boundaries has been assessed). RPS notes that certain authorities, namely South Staffordshire, are relying for their 4,000 dwelling contribution on information taken from the Greater Birmingham HMA Strategic Growth Study (SGS) (February 2018)2, based on an urban extension of at least
1,500 dwellings, an urban extension to an existing strategic employment site for at least 1,500 dwellings, and two dispersal areas each of 500 dwellings.

However, the SGS is now over three years old and has been superseded by more recent events that bring into question the robustness of the evidence that underpins it. Notably, the basis for housing shortfall calculation used in the SGS are now likely to be out of date, for the following reasons.

Firstly, the SGS applied the previous methodology for calculating objectively assessed need using the national guidance applicable in 2018, and not the standard method approach now in operation. The new standard method now includes a 35% uplift applicable to the 20 largest cities, including Birmingham and, notably, Wolverhampton. The result is that the measure of housing need for the Black Country is now different compared to previous estimates that underpinned the SGS. The SGS identifies the housing need for the Black Country (using the old PPG methodology) of 3,554 dpa based on evidence prepared in 20163. This figure has been quoted as recently as July 2020 in the latest HMA-wide Position Statement on housing need and supply4. However, the evidence underpinning the dBCP now indicates a much higher need, showing a need for 4,004 dpa. Whilst not directly comparable, this indicates an additional 450 dpa are required to meet the minimum need going forward. Over the 19-year plan period, this equates to an additional 8,550 dwellings compared to previous estimates of need.

Secondly, evidence on housing land supply demonstrates that the SGS over-estimated the likely housing capacity in the Black Country. This is helpfully summarised in HMA Position Statement July 20205. Across the four Black Country Authorities, the estimated capacity in the SGS was 62,543 dwellings. By 2019, this had fallen to 58,737 dwellings, a decrease of 3,806 overall. It should be noted that the change in capacity
highlighted in SGS only relates to the period up to 2031, and so the SGS has not considered the capacity issues post-2031. Given the increase in the shortfall outlined above, the capacity issues facing the Black

Country will most likely have worsened in the post-2031 period.


And thirdly, the SGS did not assume any shortfall existed in the Black Country up to 20316 at the time the analysis was undertaken. This, as explained above, is now clearly not the case.

Based on this analysis, it is evident that the housing position of the Black Country has worsened since the findings of the SGS were published. RPS would therefore questions the reliance on the SGS as a basis for the 4,000 dwelling contribution towards the Black Country’s housing shortfall proposed by South Staffordshire. RPS would argue that the contribution should not be based on the strategic locations proposed in the SGS but, instead, should be derived from the scale of need and the housing shortfall stemming from it.