Object

Representation ID: 43819

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

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4. Policy CSP1 - Development Strategy
Housing requirement
4.1 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 EP1. The report draws the following
key conclusions in relation to housing need, and the consequences of failing to meet that need:
Housing need
The Draft BCP acknowledges an overall need for 76,076 homes throughout the Black
Country over the plan period (2020-39). This equates to an average of 4,004 dwellings
per annum, aligning closely but not exactly with the minimum need for 4,011 dwellings
per annum currently suggested by the standard method.
This would actually only require the existing housing stock to grow at an average rate of
0.7% per annum which is less than is needed either regionally or nationally, according to
the standard method (0.8/1.1%) and indeed aligns exactly with the average housing
growth seen across the West Midlands as a whole since 2006.
The outcome of the standard method for the Black Country therefore should not be
viewed as excessively high, but instead a reasonable benchmark of the minimum need
for housing in this area. It would boost the historic rate of delivery, in line with the



cities to contribute towards meeting a nationwide need for housing.
There may well be an even greater need for housing given that the standard method
makes no attempt to predict the impact of changing economic circumstances, for
existing evidence base does not properly consider whether
there will be sufficient labour to meet the economic growth ambitions of the sub-region.
It equally provides no assurance at present that the prevailing need for houses,
estimated to account for two thirds of the overall housing need in the Black Country,
can and will be met through the proposed supply.
Consequences of failing to meet need
The Draft BCP identifies sufficient land to provide only 47,878 homes over the plan period,
equivalent to 2,518 dwellings per annum which is less than two thirds of the reported
need for 4,004 homes per year.
It represents a level of provision that has been exceeded in each of the last six years,
delivery in this period having been boosted by roughly a third (34%) compared to the six
years prior. While a similar boost would very nearly meet the minimum need for housing
in the Black Country, the Draft BCP instead threatens to bring a 12% reduction compared
to the recent trend of delivery over the last six years.










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This would put at risk the benefits generated through the recent boosting of housing
supply. The Black Country has historically experienced a net outflow of people to other
parts of the UK, for instance, but this has more than halved over the past six years to
suggest that people are being more effectively attracted and retained, helping to
restore a trend of growth in the working age population. Demographic modelling
commissioned to inform this report suggests that this trend is unlikely to continue where
housing delivery is allowed to fall, with the proposal to provide only 2,518 dwellings per
annum effectively forcing around 5,525 residents to move elsewhere every year over
three times more than in recent years.
This would be expected to dramatically slow the rate of population growth and reduce
the size of the working age population. This, combined with potential changes in
behaviour, could result in a labour force that is capable of supporting only 615 new jobs
per year. An economic forecast produced by Experian suggests, for comparison, that
the Black Country actually has the potential to create over three times as many jobs
(c.2,100 per annum) while the Black Country LEP has previously expressed a target that
seemingly equates to more than 6,000 jobs per year, over ten times more than could be
supported through the housing supply identified in the Draft BCP. The proposed housing
requirement will therefore hamper, rather than support, economic growth and recovery,



4.2 The review of housing need and supply in the Black Country at Appendix EP1 follows on from
Taking stock of unmet needs across the Greater Birmingham and Black
EP2). That report identifies
a housing shortfall across the Greater Birmingham and Black Country Housing Market Area
(GBBCHMA) of between circa 18,700 and 42,000 dwellings up to 2031, and between 68,700 and
78,000 homes up to 2040. It is of serious concern that instead of seeking to meet the unmet needs
of Birmingham, the BCP is not even planning to come close to meeting its own needs.
Affordable housing
4.3 The Black Country Housing Market Assessment (BCHMA) identifies a net need for 867 affordable
homes per annum, including 154 per annum in Walsall. There are 5,159 households on each
2; these are real households that need an affordable home
now. The levels of need are very significant.

4.4 Neither the plan nor the evidence base grapples with how this need will be met. The majority of
the housing supply comprises previously developed land in the urban area. However, Policy
HOU3 only requires the following proportions of affordable housing:




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10% on all sites in lower value zones and brownfield sites in medium value zones;
20% on greenfield sites in medium value zones; and,
30% on all sites in higher value zones.
4.5 Continued reliance upon existing sources of supply from the urban area will not deliver enough
affordable housing to meet the identified needs. The evidence base should seek to identify how
much affordable housing will be delivered from the planned housing supply, so that the full extent
of the shortfall is understood.

4.6 Paragraph 2a-024 of the PPG states:

The total need for affordable housing will need to be converted into annual
flows by calculating the total net need (subtract total available stock from total
gross need) and converting total net need into an annual flow based on the
plan period.
The total affordable housing need can then be considered in the context of its
likely delivery as a proportion of mixed market and affordable housing
developments, taking into account the probable percentage of affordable
housing to be delivered by eligible market housing led developments. An
increase in the total housing figures included in the plan may need to be
considered where it could help deliver the required number of affordable
homes.
4.7 Paragraph 67-001 also states:

egic policy-making authorities will need to consider the extent to which
the identified needs of specific groups can be addressed in the area, taking
into account:
the overall level of need identified using the standard method (and
whether the evidence suggests that a higher level of need ought to be
considered);
the extent to which the overall housing need can be translated into a
housing requirement figure for the plan period; and
the anticipated deliverability of different forms of provision, having
rega
4.8 Therefore, the PPG states that an increase in the housing requirement above local housing need
can be considered if it is necessary to help address the identified level of affordable housing
need. However, the Black Country is not even proposing to meet local housing need. The
approach is inconsistent with national planning policy and guidance, and would only worsen the










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already significant issue of affordable housing need in the Black Country and Walsall. A step
change in affordable housing delivery is needed, going to the heart of the spatial strategy. This
means allocating additional sites which can viably deliver affordable housing in the plan period.
Justification for not meeting local housing need in full
4.9 Paragraph 3.20 of the BCP states:

will provide for the great majority of housing and employment land
needs arising in the Black Country to be met within the Black Country. However,
the capacity of the Black Country is finite; it is not possible to provide for all the
ng and employment land needs within its administrative
boundaries, given the circumstances around land deliverability, justifiable



4.10 Firstly, a housing requirement of only 47,837 dwellings over the plan period would meet less than
two thirds (63%) of the reported housing need
the plan.

4.11 Secondly, the proposition that it is not possible to provide for all the Black
employment land needs within its administrative boundaries is not credible, for the following
reasons.
Reliance upon the Sustainability Appraisal (SA)
4.12 As set out in the BCP Options document, the BCA is effectively relying upon the Sustainability
Appraisal (SA) to justify its decision. However, the SA is a numerical scoring exercise which fulfils
a legal requirement to assess reasonable alternatives. It cannot replicate the planning balance
exercise discussed in paragraph 11 of the Framework, which involves the weighing of numerous
quantitative and qualitative planning considerations, and it should not be used as the main
justification for the selection of the housing requirement in the emerging plan. Assessing impacts
on the landscape and natural resources requires a far more considered appraisal than a simple
scoring-based system. If there is a genuine level of environmental capacity that cannot be
breached, then that needs to be properly and fully evidenced. It is not sufficient to simply say
that one option scored better than another in the SA.

4.13 Notwithstanding, it can be noted that the SA assessment of the growth options is flawed. The
options assessed are provided at Table 3.1 of the SA:

[See attachment: ‘tables 3.1 and 3.4’]








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4.14 The assessment of the housing options is set at Table 3.4:












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4.15 Option 5 was the chosen option.

4.16

concludes th
3, 4 and 5. This is illogical given that:

Option 5 would not meet the needs within the Black Country, which would have adverse
impacts upon the Black Country housing market irrespective of whether those needs are
met elsewhere.

There is no agreement for the needs to be met elsewhere and it is therefore unlikely that
they will be met in full.

Whilst the SA is factoring in the positive impact of delivering housing in neighbouring
authorities, it makes no such attempt to factor in the potential negative impacts of
delivering that housing elsewhere, including on landscape and the Green Belt. This is
acknowledged at paragraph 3.3.12 of the Sustainability Appraisal.

4.17 It is therefore impossible to draw the conclusion that housing growth can be more sustainably
delivered in a neighhbouring authority, having regard to Green Belt and other constraints. If those
needs are met by neighbouring authorities, the impacts may be greater than meeting them in
the Black Country.

4.18 Therefore, the BCA assessment of the growth options in the SA is flawed, and the reliance upon
the SA to justify its preferred option is misplaced.
Landscape and Green Belt harm
4.19 It is not clear how the SA has arrived at the conclusion that the impacts on landscape and natural

options. It appears to be based upon the crude notion that more development equals more
harm. There is no evidence to suggest that a certain quantum of development tips the balance
to an unacceptable level of harm, such that the adverse impacts significantly and demonstrably
outweigh the very considerable benefits of meeting identified needs.










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4.20 It should be noted that in determining the methodology for calculating local housing need, the
Government is well aware that meeting the housing needs of the country will necessitate
greenfield sites in Green Belt areas. There is nothing demonstrably special about the Black
Country to suggest that it should not meet its development needs in the same way that other
authorities are expected to.

4.21 Although not explicitly set out within the Growth Options report, part of the BCA justification
appears to be the application of its site selection methodology as set out within the Draft Site
Assessment Report. Under stage 3, the methodology filters out sites
cause very high harm to remaining green belt and moderate-high or high harm to landscape
. However, as a whole the evidence base significantly over-states Green Belt and
landscape harm, thus over-stating the overall impacts of meeting housing needs in full. In this
regard, it can be noted that the evidence in relation to Green Belt and landscape relies upon
area-based assessments which do not reflect specific sites and proposals put forward by
developers. We discuss this further in our response to the site selection methodology.

4.22 Therefore, to conclude, the BCA reliance upon the SA to justify the proposed growth option is
misplaced. There is no evidence to justify a specific environmental capacity for the Black Country
which cannot be breached now or in the future. The proposed approach is not justified, effective
or positively prepared. The BCP should seek to meet local housing need in full within the Black
Country.
Agreements with neighbouring authorities
4.23 providing
a strategy which, as a m
informed by agreements with other authorities, so that unmet need from neighbouring areas is
accommodated where it is practical to do so and is consistent with achieving sustainable
development.

4.24 Therefore, the starting point for the Duty to Cooperate is that the Black Country should be seeking

nd instead seeks to export its own needs.
To do so it relies upon unspecified future agreements for neighbouring authorities. Paragraphs
3.23 - 3.25 of the BCP provide:










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land need to be provided for across the Housing Market Area, Functional
Economic Market Area (FEMA) and other areas with which the Black Country
has a physical or functional relationship.
3.24 As a result, the BCA have worked openly and constructively with
neighbouring authorities to help provide as much certainty as possible about
will be delivered. The current position is set out in the Draft Plan Statement of
Consultation and will be elaborated on in more detail in Statements of
Common Ground at Publication stage.
3.25 The BCA recognise that this approach may only address a proportion of
the housing and employment shortfall, as it is inappropriate and beyond the
powers of the BCA to establish the limits of sustainable development in
neighbouring authorities
4.25 The BCA therefore concede that there is no guarantee that the neighbouring authorities will
accommodate the shortfall. Given the absence of firm agreements, it seems inevitable that the
unmet needs will not be met elsewhere. Therefore, the approach is not positively prepared, and
is inconsistent with the Framework.












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Employment land requirement
4.26 The BCP proposes a similar approach to employment land as it does with the housing
requirement, in terms of not meeting the identified needs and relying upon neighbouring
authorities to meet the shortfall, which amounts to 210 hectares of employment land.

4.27 Furthermore, a significant proportion of the identified housing supply comprises existing
employments sites. Aside from the identified strategic and local employment areas (Policies
EMP2 & EMP3), the plan provides no protection to existing employment sites. In fact, Policy EMP4
is permissive of such sites being developed for housing, without any test as to whether there is a
continued need for the site to remain in employment use. This will only exasperate issues of
employment land supply in the Black Country.

4.28 Failing to meet the identified need for employment land will cause significant harm to the local
economy. Businesses will not be able to invest and grow in the Black Country, and jobs growth
will be curtailed to the detriment of residents. There may also be an impact on commuting
pattens.

4.29 ng to meet the identified need for employment need are similar to
its reasons for failing to meet local housing need. The approach is flawed because:

The SA is based upon flawed assumptions.
The BCA reliance upon the SA to justify the proposed growth option is misplaced.
The alleged impacts on landscape and natural resources (including Green Belt) are
overstated.
There is an absence of firm agreement with neighbouring authorities to meet the
needs.
4.30 Overall, the proposed approach is not justified, effective or positively prepared. The BCP should
seek to meet housing and employment needs in full within the Black Country.