Object

Representation ID: 44768

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing need
• 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. As set out at pages 5 and 33 of the report, 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 20201) 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 annum2).

• 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.
This demonstrates that there is no evidence for lowering the Black Country’s total housing needs, indeed it should be increased if it is to ensure sufficient labour is provided to meet the sub-region’s economic growth ambitions.