Object

Representation ID: 23599

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

6.2
Policy HOUI — Delivering Sustainable Housing Growth
Housing requirement
We address our objections to the proposed housing requirement in our response to Policy CSPI.
We consider that local housing need should be met in full.
Housing land supply
HIMOR has jointly commissioned Turley to undertake a review of housing need and supply in the
Black Country. A copy Of the report is provided at Appendix EPI The report draws the following
key conclusions in relation to housing land supply:
• The Framework requires Local Plans to be aspirational but deliverable, identifying a
sufficient supply of sites taking into account their availability, suitability and likely
economic viability. Those sites should meet the tests of deliverable and developable
contained in the Framework's glossary. It is vital to realistically assess the amount of
deliverable supply in plan period, as to overestimate the amount of housing coming
forward in the plan period, as appears to be the case here, causes a significant planning
harm connected to the unnecessary creation Of an acute shortfall Of housing when
individuals require them.
The Black Country authorities have evidently made a set of assumptions in relation to the
housing capacity and deliverability Of certain sources Of supply. relied upon in the Draft
BCP. This report has assessed the proposed sources of supply and identified significant
concerns with the assumptions being relied on, with a clear absence of any up-to-date
and robust evidence. In some areas the Councils' assumptions are not rigorous enough.
the evidence base is inadequate to draw out the conclusions being relied on, and in
our opinion the justification provided falls short given the context and scale of the
implications Of misjudging the true amount Of housing supply.
• Setting realistic delivery assumptions, as required by the Framework, is essential as
planning harm crises when delivery does not come to fruition. This is evident in the Black
Country, where there has been clear issues in delivering sites previously identified in the
Black Country Core Strategy (BCCS). Despite this, the Councils seek to simply roll forward
the approach taken in that previous plan, with little scrutiny or regard to the
effectiveness (Or not) of that strategy. The report highlights that:
In relation to non-implementation of commitments, the Councils seek to lower
the opposed discount rate based on entirely inadequate evidence, and a
reduction of 695 homes to this source in the plan period is proposed;
The Councils rely on existing allocations from previous Plan documents, which
are not subject to review through the BCP but have evidently struggled to come
forward in the preceding decade. A reduction of 4,973 homes to this source in
the plan period is proposed; 6.3
The Councils rely on a significant amount of supply from currently occupied
employment land, on which there is patently no reasonable prospect that
development will come forward at the point envisaged considering the local
delivery track record on employment sites, and the wider economic context. The
Councils' strategy on these sites may contradict the wider context in the
Framework which also seeks to ensure a sufficient supply Of employment sites. A
reduction of 3,091 homes to this source in the plan period is proposed; and
The Councils rely on a significant number of dwellings in Wolverhampton Ci
Centre. where upper floor conversions of retail units are expected to Come
forward at a given rate. There is no compelling evidence to include this windfall
allowance in the BCP supply, and the removal of the entirety of this source (812
homes) in the plan period is proposed.
• Based on the above, the Draft BC? exaggerates the housing supply that is likely to come
forward from its identified sources, by almost 10 000 homes. Unless additional sites are
identified, this could lead to the provision of only 38,266 homes over the plan period. or
2,014 dwellings per annum, which is barely half of the identified minimum need for
housing in the Black Country. With this report showing that even delivering in line with the
proposed requirement would have negative consequences for the area. it follows that
these consequences would be even more pronounced if delivery were to be lower still.
In progressing the BCP, the Black Country authorities are encouraged to fundamental
reconsider the proposed approach to housing provision. adding to and scrutinising the
identified supply with the aim of further boosting delivery and meeting housing needs in
Therefore, there is a significant shortfall in housing land supply even against the SCP's artificially
constrained housing requirement, bt alone a higher requirement in line with bcal housing need
as we propose in Our response to Policy CSPI The strategy needs to be fundamentally changed
to address these significant issues of soundness. This means significantly boosting the supply of
housing land to meet local housing need in full.