Comment

Representation ID: 44893

Received: 11/10/2021

Respondent: Gladman Developments Ltd.

Policy CSP1 and the associated supporting text describes the proposed development strategy for the Black Country over the period 2020 to 2039. Policy HOU1 – Delivering Sustainable Housing Growth also sets the context for the delivery of new homes over the plan period.
It is noted that the councils have updated their evidence base during 2021 to provide The Black Country Housing Market Assessment, March 2021 and the Black Country Urban Capacity Review Update, May 2021. This provides baseline evidence on the overall housing need and the extent to which these needs can be met within the urban area. Gladman welcomes the intention of the councils to periodically update the Urban Capacity Review (the next being in 2022) and see this as an essential element in making a realistic assessment of the capacity of the area to accommodate the level of housing and employment that is needed over the period to 2039.
The Plan intends to deliver at least 47,837 net new homes over the plan period and 355ha of employment land. The housing requirement equates to 2,517 dwellings per annum. The supporting text recognises that the capacity of the Black Country to accommodate development is finite and acknowledges that it will not be possible to meet development needs in full within the administrative boundaries. There is estimated to be a shortfall of 28,239 homes and 210ha of employment land against the needs identified through the evidence base of 76,076 homes and 565ha of employment land.
The Standard Method for calculating housing need in national policy produces only a “minimum” need for housing3. The PPG accepts that there will be circumstances where it is appropriate to plan for a higher housing need figure. This includes the consideration of growth strategies or strategic infrastructure investments that could drive an increase in the number of homes needed. The HMA evidently displays these characteristics and has strong economic growth ambitions, including those associated with the Midlands Engine and the country’s most significant infrastructure investment in the form of High Speed 2, alongside a range of other investments recognised within the Midlands Connect Strategy. Careful consideration will need to be given to these factors as plan making progresses across the area.
The Turley Falling Short Report (see Appendix 1), considers the wider evidence of housing need across the GBBCHMA and recommends that given the scale of the housing shortfall, a more radical approach to strategic and spatial plan-making is required to tackle the challenge of long term growth. The Report also highlights the need to revisit the ‘Position Statements’ and ‘Statements of Common Ground’ associated with development needs between neighbouring authorities as plan making across the area progresses. This will be central to the soundness of the proposed development strategy for the Black Country Plan for the period 2020 to 2039, which includes the proposed release of land from the Green Belt and to export a proportion of the development needs to authorities in the wider HMA. Where development needs are exported, it will be for the importing Local Planning Authority to determine how any such requirement can be sustainably accommodated within the context of its own spatial strategy. It is welcomed that the Black Country Authorities are committed to continued and constructive engagement, through the Duty to Co-operate, with their neighbours to secure the most appropriate and sustainable locations for housing and employment growth to meet Black Country needs over the plan period. Gladman look forward to reviewing any associated documentation as the plan making process advances.