Comment

Representation ID: 23461

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

Housing Shortfall in the Black Country.
As a result of the foregoing analysis, Table 2 of the Black Country Development Strategy
2020 – 2039 expects a housing shortfall of 28,239 dwellings to be exported to other
authorities through the operation of the Duty to Co-operate. This ignores any shortfall from
the wider Greater Birmingham area. As I indicate above, currently there are no firm
commitments from other authorities to accommodate this shortfall despite all authorities
within the GBBCHMA having been asked to contribute (as indicated within the Duty to Cooperate
section. Furthermore, as we indicate above, there is an outstanding shortfall from the Birmingham
Housing Needs Assessment which could lie somewhere between 2,597 dwellings (the
number declared in the joint position statement and 28,0000 highlighted in the GL Hearn
report to 2031 – or indeed higher). This would be in addition to the shortfall of 28,239
dwellings now evident in the Black Country which creates an overall shortfall of up to
50,000-60,000 dwellings in the GBBCHMA.
However, Turley’s previous report ‘Falling Short – Taking stock of unmet needs across the
Greater Birmingham and Black Country Housing Market Area’ published in August 2021
identified a housing shortfall across the Greater Birmingham and Black Country Housing
Market Area (GBBCHMA) of between 68,700 and 78,000 homes up to 2040. This tends to
suggest that the acknowledged shortfall of 28,239 represents a serious under-estimate.
As I have described above, there are only two local authorities – Telford & Wrekin BC and
South Staffordshire DC – within the wider Housing Market Area who have expressed any
willingness or indeed have the capacity to absorb any major overspill – with the possibly
addition of Shropshire Council who are now well advanced in their own plan and have
rejected proposals for development at Junction 3 (M54) within the green belt. However,
this does not necessarily represent the full shortfall. Private sector interests co-ordinated by
planning consultants Turley, have undertaken further research which looks at the pressures
for development in and around the Birmingham and Black Country HMA.
Housing Land Supply.
The achievement of the net provision of 47,837 dwellings over the plan period 2020 – 2039
or 2,518 dwellings per annum, relies entirely on achieving and delivering sufficient readily
available land to build enough homes – and that those homes will be viable to build and will
appeal to the market (or tenants) and hence will be delivered and occupied. Any significant
shortfall will result in further overspill to adjacent areas -added to the 28,239 dwellings
which are estimated to be required elsewhere to satisfy the Black Country’s housing needs.
A separate exercise by consultants, Turley, submitted on behalf of a number of housebuilders,
highlights the very high reliance on brownfield land (85%) and estimates that some
10,000 plots which are included in the Councils’ Black Country Local Plan may not be
achieved for a variety of reasons. This likely shortfall is also picked up in the HBF’s response
where they identify many sites within the Strategic Centres as being unviable, based on the
Councils’ own ‘Black Country Viability and Delivery Study’. The Turley report comments that
many existing housing allocations especially those on established employment land have not
been delivered and the decision to simply roll these forward presents a high-risk approach in
terms of achieving delivery. They calculate the need for firstly, reductions to commitments (-
695 homes), secondly, existing allocations (-4,973 homes), thirdly, occupied employment
land (-3,091 homes) and finally upper floor conversions in Wolverhampton (-812 homes),
equating to 9,571 dwellings in all.
There is also concern within the HBF response that high levels of affordable housing
(including what could be onerous requirements for First Homes, rented housing and
Accessibility housing) and also high densities and pressures from Biodiversity requirements –
important though they are – may frustrate the ability of developers to deliver the scale of
housing within the Black Country. They also note that the figures provided provide little
flexibility in numbers so that all virtually all the housing land provision identified will need to
be built to achieve the Councils’ targets with little or no room for flexibility.