Object

Representation ID: 44777

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing supply and shortfall

6. The Draft BCP intends to make provision for only 47,837 homes over the plan period, equivalent to 2,517 dwellings per annum, leaving a shortfall of circa 28,239 homes to 2039 with an assumption – but no guarantee – that this will be met in neighbouring areas. The proposed level of annual provision has been exceeded in each of the last six years, when roughly a third more homes have been delivered. The Black Country has seen tangible benefits as a result, more effectively attracting and retaining people than has been the case historically and once again growing its working age population.

7. Rather than planning positively for a similar “boosting” that would very nearly meet the minimum need for housing suggested by the standard method, the Draft BCP instead threatens to reduce the recent rate of delivery by 12%. Demographic modelling suggests that this would dramatically slow the recent rate of population growth and effectively force around 5,500 residents to move elsewhere every year, over three times more than in recent years.

8. The associated reduction in the size of the working age population, combined with potential behavioural changes, would be expected to leave a labour force capable of supporting only 615 new jobs every year, whereas at least one economic forecast suggests that the Black Country has the potential to create over three times as many jobs (c.2,100 per annum) and indeed the LEP has previously expressed a target that appears to be over ten times greater, at in excess of 6,000 jobs per annum.

9. This demographic modelling could even be reasonably described as optimistic as it assumes that the proposed requirement can be met through the supply identified in the Draft BCP, which may not be the case based on the analysis in this report. The National Planning Policy Framework (NPPF) 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 NPPF glossary. This report assesses the Councils’ claimed supply against the NPPF guidance and concludes that 9,571 homes are unlikely to be deliverable/developable during the plan period. This has a significant impact because it would result in the shortfall increasing to 37,810 homes, circa 50% of the minimum need for housing.

10. Given the large gap between supply and need, compounded by previously over optimistic assumptions on what can be delivered, the Councils’ sources must be scrutinised further as the BCP advances, and the implications of the possible additional housing supply shortfalls considered closely.

11. This report follows on from Turley’s ‘Falling Short – Taking stock of unmet needs across the Greater Birmingham and Black Country Housing Market Area’ published in August 2021. 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. This includes the Black Country shortfall as currently reported in the Draft BCP. Any reduction to the Councils’ proposed supply would only exacerbate and worsen the wider GBBCHMA shortfall up to 2031 and 2040.