Comment

Representation ID: 44784

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

3. Consequences of failing to meet need

Planning to reduce the recent rate of housing delivery

3.1 The Draft BCP acknowledges a need for 76,076 homes, equivalent to 4,004 dwellings per annum throughout the plan period, but only identifies sufficient land to provide 47,837 homes or 2,518 dwellings per annum17. It openly admits that this would meet less than two thirds (63%) of the reported housing need, with a presumption – but no guarantee – that neighbouring authorities will accommodate the shortfall18.

3.2 Such an approach, whilst evidently threatening to leave a substantial amount of need unmet, would reverse the progress that has recently been made in boosting housing delivery in the Black Country. Figure 3.1 shows that the proposed requirement for 2,518 dwellings per annum is less than what has been delivered in each of the last six years, the average rate of provision in this period having been boosted by around one third (34%) compared to the six years prior but now apparently at risk of falling by some 12% under the approach proposed by the Draft BCP. This would represent a missed opportunity, as positively planning for a further boosting – of the scale achieved recently (+34%) – would very nearly meet the minimum need suggested by the standard method19.

See attachments for Figure 3.1:Proposed housing requirement relative to recent delivery
Risking the benefits associated with recently increased provision

3.3 The recent boosting of housing supply has brought demonstrable benefits to the Black Country which will be put at risk if delivery is allowed to fall.

3.4 One such benefit relates to the attraction and retention of people within the Black Country. This area has historically tended to lose residents to other parts of the UK without attracting the same number from elsewhere, but Figure 3.2 shows that the average size of this net annual outflow over the past six years (2014-20) has been less than half that recorded previously, over the years for which consistent data is available20 (2001-14).

See attachment for Figure 3.2: Recent change in the average net outflow from the Black Country

3.5 This smaller net outflow of people has helped to restore a trend of growth amongst the working age population (16-64) which had been faltering in the years before21. Having declined throughout the 1990s, this cohort grew in size for ten straight years to 2011 before effectively remaining static for three years, with average annual growth of close to zero (0.04%). The boosting of supply from 2014 onwards, however, has helped to once again grow this key cohort of the population as shown at Figure 3.3 overleaf.
See attachment for Figure 3.3:Annual change in the working age population of the Black Country

3.6 The positive trends outlined above appear extremely unlikely to continue if the rate of housing delivery slows to the rate proposed by the Draft BCP, according to demographic modelling by Edge Analytics which has been commissioned to inform this report. This is intended to illustrate how the provision of 2,518 dwellings per annum from 2020 onwards could, in combination with other demographic factors, affect the size and profile of the Black Country population. Further detail on the methodology is provided at Appendix 1.

3.7 The model suggests that the proposed level of housing provision would be unable to accommodate a net inflow of people from outside of the Black Country, effectively forcing circa 5,525 residents every year to move to other parts of the UK. This is more than three times greater than the net outflow of recent years, shown at the earlier Figure 3.2, and indeed is without recent precedent where it is larger than recorded in any year since at least 2001. This does technically allow for a net inflow of international migrants, albeit one that is smaller than recorded in recent years, but even if this does not materialise and their homes accommodate those otherwise assumed within the model to move elsewhere, the overall net outflow – shown as a dotted grey line at Figure 3.4 below – would remain larger than seen historically.
See attachment for Figure 3.4: Modelled impact of reduced housing provision on net migration

3.8 Population growth would be expected to dramatically slow in this scenario, falling to only 0.1% per annum over the 19-year plan period compared to 0.6% per annum over the equally long historic period (2001-20).

See attachment for Figure 3.5: Modelled impact of reduced housing provision on total population

3.9 The working age population would also be expected to shrink by circa 2% in total – as shown at Figure 3.6 overleaf – while the elderly population, aged 65 and over, could grow by as much as a quarter. This would increasingly and markedly shift the demographic profile of the Black Country towards older age groups.

See attachment for Figure 3.6: Modelled impact of reduced housing provision on selected age groups

Implications for the Black Country economy

3.10 Such limited population growth, combined with a changing age profile, would in turn affect the size of the resident labour force, and its ability to support the creation of new jobs in the Black Country. Edge Analytics’ modelling suggests, based on the assumptions detailed at Appendix 1, that the labour force could support the creation of only 615 jobs per annum over the plan period if housing delivery aligns with the proposed requirement.

3.11 At least one economic forecast, produced by Experian, suggests that the Black Country has the potential to create over three times as many jobs over the same period (2,116pa). The Local Enterprise Partnership (LEP), meanwhile, has previously expressed a target that – although not officially annualised – appears to equate to more than 6,000 jobs per annum if reasonably assumed to cover a period of twenty years22. This is over ten times more jobs than could be supported by the Draft BCP, as shown by Figure
3.7 overleaf.

See attachment for Figure 3.7: Benchmarking job growth annually supported through the proposed approach


3.12 The proposed housing requirement will therefore hamper, rather than support, the recovery and growth of the Black Country economy. This is contrary to one of the overarching aims of the Draft BCP, which explicitly seeks to ‘attract new businesses and jobs’ to the area and:

“…increase employment opportunities to support the delivery of the Black Country and West Midlands Combined Authority Strategic Economic Plans (SEP), the Local Industrial Strategy and Covid-19 recovery plans”23

3.13 It later describes the LEP’s ‘overall aim of transforming the sub-regional economy by creating the conditions for enterprise to flourish, resulting in greater economic prosperity across the Black Country’24. It states that its own ‘challenge’ is to maintain the ‘momentum’ that has recently led to economic growth, particularly in light of the pandemic, suggesting that ‘the Black Country Plan is part of that process’25 in terms of providing employment sites without acknowledging the parallel importance of attracting and retaining labour through making sufficient provision for housing.

3.14 The proposed approach to housing supply does not rise to this ‘challenge’, threatening instead to stall any ‘momentum’ that has developed in recent years. It must therefore be reconsidered, with the aim of further boosting housing supply and retaining the benefits that have recently been generated through increased delivery.