Comment

Representation ID: 23460

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

Housing Needs in the Black Country – Policy CSP1.
The Black Country area (including Dudley, Sandwell, Walsall and Wolverhampton forms an
integral part of Greater Birmingham & Black Country Housing Market Area (GB&BCHMA).
Both Birmingham City Council and the Black Country Authorities have long had unmet
housing needs but the situation is somewhat fluid as circumstances change over time.
In January 2017 the adopted Birmingham Development Plan identified a housing shortfall of
37,900 dwellings which was expected to be met from contributions by surrounding
authorities (including possibly the Black Country). The Birmingham Local Plan Inspector
imposed a 3 year deadline within which Local Plans were meant to come forward to address
the shortfall otherwise Birmingham would be thrown into a further Local Plan review.
Since then, Birmingham City Council has re-assessed it shortfall and recalculated the housing
output from for example, completions, plots under construction, windfalls, additional sites
within the City Centre and assumptions on new development on the Commonwealth Games
site at Perry Barr. A Joint Local Authority Position Statement on the GBBCHMA – dated July
2020 claims that the housing shortfall at that time had reduced to only 2,597 dwellings based on the GL Hearn Strategic Growth Study (February 2018) baseline figure of 207,979
dwellings needed to 2031. This is clearly a sharp reduction on the shortfall expressed in the
GL Hearn Strategic Growth Study (2018) of 28,000 dwellings and has not yet been tested.
In addition, the Strategic Growth Study (2018) looked forward to 2036 and identified a
minimum baseline figure of almost 61,000 dwellings and hence this will add to both the
Birmingham and the Black County requirement – which looks further forward to 2039.
Currently (as I write) the Solihull Local Plan Inquiry is considering these figures (alongside
other assessments of housing shortfall from the private sector) as part of the parallel debate
about Solihull’s true housing requirements and hence – in the absence of any agreed figures
(or a strategic planning input) decisions about the overall shortfall will be made by the
Solihull Inspectors which could have a wider bearing on the Black Country Local Plan.
The situation in the Black Country creates a further shortfall. The Draft BCP states that the
capacity of the Black Country is finite and not all of the Black Country’s housing needs will be
met within its own administrative boundaries (see para 3.20). The Draft BCP sets a housing
target for the Black Country of 47,837 dwellings over the plan period 2020 – 2039 or 2,518
dwellings per annum against a minimum Local Housing Need of 76,076 dwellings (see para
3.21 & Policy CSP1).
Measuring the housing requirement against the Local Housing Need (LHN) from the
government’s Standard Methodology the combined figures produce a minimum LHN of
76,361 dwellings (or 4019 per year) between 2020-2039, which according to paragraph 60 of
the NPPF are intended to be regarded as a minimum. This comprises:
12,084 new homes in Dudley (636 per year)28,272 new homes in Sandwell (1,488 per year)
16,758 new homes in Walsall (882 per year)
19,247 new homes in Wolverhampton (1,103 per year) – including a 35% uplift.
76,361 new homes for Black Country area.
The Turley report comments that despite the challenge of meeting potentially 76,361 new
homes in the Black Country, the resultant figures from the Standard Method are not
especially high in terms of growth in relation to existing stock. Indeed, despite the City of
Wolverhampton receiving a 35% uplift, as one of the country’s 20 largest cities, its ultimate
target is relatively modest and it is only the tight administrative boundaries which make it
difficult to meet its expected contribution towards a nationwide need for housing. The
adjacent authority of South Staffordshire – and especially Codsall which borders
Wolverhampton, provides a valuable opportunity to provide new housing very close by.