Comment

Representation ID: 2809

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. In terms of housing need, the SHMA has made no market signals uplift to the demographic starting point for any of the Black Country areas on the basis that housing across the HMA is generally more affordable than the national average. However, the SHMA has overlooked the recommendations of the Local Plans Expert Group on this issue, notably an assessment of the House Price Ratio as a key indicator of housing affordability, looking at the ratio of lower-quartile house prices to lower-quartile earnings. In a case where the ratio is higher than 5.3 and lower than 7.0, applicable to all four of the Black Country authorities (see fig 5.8, SHMA), the LPEG recommendation is that an uplift of 10% should be applied.

Notwithstanding the above, it is right to keep the OAN figure under review, recognising a review of the SHMA may be necessary prior to Examination in view of the publication of more up to date population and household projections, and proposed implementation of a standardised approach to the calculation of OAN through the revised NPPF.

In terms of unmet housing need, no evidence has been provided regarding the on-going Duty to Cooperate considering the matters relating to Birmingham City. Paragraph 3.18 indicates that the Black Country have committed to test the accommodation of an extra 3,000 homes up to 2031 to help address the shortfall in the wider HMA. There is however no explanation as to how 3,000 of the 37,900 dwellings from Birmingham City needed to be found elsewhere within the HMA by 2031 has been arrived at - there appears to have been no agreement to this level of housing from the other HMA authorities and no robust and thorough apportionment methodology adopted to justify this figure. In view of the strong migration and commuting links with Birmingham, it is queried whether a higher proportion of the unmet need would be more appropriate, or otherwise testing of a range of figures might be sensible.

In terms of housing supply, paragraph 2.5 of the document notes that whilst the majority of current planned growth is focussed within the growth network, the level of delivery has been less than expected to date. It continues by explaining this is because there is not as much surplus employment land suitable for housing as anticipated due to the economy strengthening and local firms being more robust than expected. However, at paragraph 3.16, in noting that a key source of housing supply under the existing spatial strategy is the release of surplus employment land, it is then suggested that a further 10,400 dwellings could be delivered from this source over the period 2026-36. It then states that to exceed past levels of allocations will be extremely challenging due to delivery constraints and need to protect viable employment premises. In our view, it is highly unlikely that greater or even similar levels of capacity can be expected from such a source in view of recent experience - the ability to allocate employment land does not necessarily mean it will be delivered, so to rely on similar level of supply from this source going forward is highly questionable and would fail to satisfy the requirements at paragraph 47 of the Framework.