Comment

Representation ID: 46181

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Table 4 which follows the policy text of HOU1 sets out the minimum housing target over the period 2020-39 for each of the four Black Country authorities and for each of the Black Country Plan phases (2020-29, 2029-34 and 2034-39). Total net homes to be delivered in Sandwell is stated as 9,158 or 482 dwellings per annum. There is a significant discrepancy between the standard methodology assessed requirement for Sandwell of 1,488 houses per annum and the expected net delivery of 482 dwellings per annum. The draft Black Country Plans needs to be explicit over the land supply reasons for this (i.e. is it site availability only, and/or other reasons), the justification for a redistribution of housing requirements and the potential for some of the discrepancy to be recovered through higher density development; particularly within the defined Core Regeneration Areas.

47,837 net new homes are considered are deliverable across the four administrative areas during the plan period. This leaves a shortfall of 28,238, based upon an assessed housing requirement of 76,076 units, without any complete picture on how this shortfall might be addressed. It is acknowledged that under the ‘Duty to Cooperate’, the BCA are working with neighbouring authorities to determine what level of additional housing could be delivered outside of the Black Country Plan area to help address the shortfall. An estimate of up to 9,500 houses still leaves a shortfall of over nearly 19,000 homes.

It is possible that continued discussions with neighbouring authorities will result in agreement over increased housing provision outside of the Black Country Plan area; the current 9,500 units upper threshold might also not be realised. It is possible that a future review of the standard methodology will reduce the burden of responsibility on the BCA. However, it seems unlikely that there will be any shift in either requirement or provision of any materiality such that the shortfall of 19,000 homes is eliminated.

This indicates very strongly that the BCA will have to look to other solutions within the plan area. It is highly likely that a component of any solution will be higher density residential development.