Comment

Representation ID: 23289

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

The housing requirement

Table 2 of the draft Plan suggests that a total of 76,076 dwellings are 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 of the BCHMA 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 that a total of 76,361 dwellings is required during the course of the plan period (4,019 dpa x 19 years).

The National Planning Policy Framework (“the Framework”) advises at paragraph 61 that to determine the “minimum” number of homes needed strategic policies should be informed by a local housing needs assessment conducted using the Standard Method, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market signals. The draft Plan suggests a minimum housing figure below that identified by the BCHMA, and consequently fails to meet the requirement of the Framework. That being the case, as a very minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents.

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 figures set out above will apply”. That being the case, the BCHMA does not test whether the minimum Standard Method housing requirement figure should be increased, in accordance with the requirements of the PPG.

Paragraph ID:2a – 010 – 20201216, of the PPG advises that there will be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate 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.

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 house the Black Country’s workforce. An assessment should be undertaken to establish if the housing requirement needs to be uplifted to support economic growth.

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing will be via Section 106 agreements.