Comment

Representation ID: 43936

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Housing delivery
Policy HOU1 (delivering sustainable housing growth)
3.40 Firstly, similarly to our response to policy CSP1 above, the policy should be clear that
47,837 new homes is the proposed supply only and that the full need for the Black
Country is 76,076 new homes. To ensure it is not ambiguous the policy should also
clearly state the exact scale of the remaining unmet need so it is clear for any authority
working with the Black Country on assisting with its unmet needs.
3.41 In terms of the overall need of 76,076 homes (4,004 dwellings per annum), the plan
must be clear that this is a minimum. This represents a relatively small number of new
homes compared to the size of the Black Country’s existing housing stock (501,464
homes as of 20202) and would only require growth at a rate which almost half of the
thirty West Midlands region’s authorities have achieved since 2006 (0.7% per annum3).
3.42 Indeed the proposed housing need, which is based on the area’s standard method
need only, represents a benchmark of the minimum need for housing only. For
instance, it does not account for changing economic circumstances, such as the
Councils’ assurances that there will be sufficient labour to meet the economic growth
ambitions of the area (draft policy EMP1). This could be justification for increasing the
Black Country’s housing needs.
3.43 This demonstrates that there is no evidence for lowering the Black Country’s total
housing needs, if there is to be any change it should be to increase it to ensure
sufficient labour is provided to meet the sub-region’s economic growth ambitions.


2 MHCLG (2020) Table 125: dwelling stock estimates by local authority district
3 Based on the outcome of the standard method as of August 2021, estimated for every local authority by Turley
and aggregated to the West Midlands (21,829dpa) and England (297,619dpa)




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Table 3 (Black Country housing land supply and indicative phasing 2020-39)
3.44 The proposed supply of 47,878 new homes between 2020 and 2039 is the equivalent
of 2,518 dwellings per annum. This is less than what the authorities have delivered per
annum for the last six years (2,863 dwellings per annum). Whilst the supply within the
urban area may be more exhausted going forward than in those previous six years, this
level of delivery demonstrates the scale of demand in the Black Country and that the
market is capable of absorbing it.
3.45 The increased supply of homes has directly contributed to the area more effectively
attracting and retaining people than it has historically. One benefit of this is that the
Black Country’s working age population has grown4. The proposed supply in the draft
BCP therefore risks this recent trend and ultimately will result in reducing the size of
the working age population.
3.46 Notwithstanding the above, we have some concerns regarding the robustness of the
Councils’ proposed supply, which we summarise below:
• There are a number of sources of the supply which are proposed on existing
vacant or occupied employment land (6% of the total proposed supply). Similarly
to the response to draft policy DEL2 above, this approach significantly risks the
NPPF’s requirement for the plan to provide a sufficient supply of employment
sites, as well as for housing supplies to only include land with a realistic prospect
that it is available and could be viably developed. It also contradicts the plan’s
objective to support economic growth.
• The above is not a new approach. The BCCS also allocated a total of 16,182
homes on occupied employment land. Based on the Urban Capacity Review
Update (May 2021) only 679 (4.2%) of those homes have been delivered to date
(with less than five years of the plan period remaining).
• The BCCS assumed a 10% non-implementation rate for sites under construction.
The BCP plans to reduce this to 5%, based only on evidence from
Wolverhampton City for the period 2001-20045. There is insufficient evidence at
this stage to justify such a change in approach.
• 4,973 new homes are proposed on existing allocations (circa 10% of the total
supply). The largest contributions to this are from Dudley (2,506 homes) and
Wolverhampton (2,248 homes). These sites are largely located in Strategic
Centres and allocated in Area Action Plans which followed the BCCS. There is no
new evidence to demonstrate their deliverability to support their continued
allocation in the draft BCP, there is however evidence where the Councils
concede a number of these sites are constrained given issues such as land


4 ONS (2021) Mid-year population estimates, 2001 to 2020
5 Paragraph 2.1.14 of the Black Country Urban Capacity Review Update (May 2021)




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ownership, viability, the need to relocate existing uses, or ground
contamination6.
• No compelling evidence (as required by NPPF paragraph 71) has been provided
to justify including 812 new homes (circa 2% of the supply) in Wolverhampton
City Centre on upper floor conversions. There is no evidence in the SHLAA or any
data on historic windfall delivery rates of this nature in the Black Country.
3.47 The above reinforces the importance of, as a minimum, protecting those sites that are
in sustainable locations, can deliver real benefits for the community, and are
demonstrably deliverable in the proposed supply, such as IM Land’s site at Queslett
Road, Walsall. Indeed paragraph 6.7 of the draft BCP recognises that the Councils’ own
evidence on market delivery constraints has already been taken into account in
determining the capacity at the site.