Comment

Representation ID: 47039

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Firstly, similarly to our response to policy CSP1 above, the policy should be clear that 47,837 new homes is the proposed supply only and that the full need for the Black Country is 76,076 new homes. To ensure it is not ambiguous the policy should also clearly state the exact scale of the remaining unmet need so it is clear for any authority working with the Black Country on assisting with its unmet needs.

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 page 31 of Appendix 7, 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 20203) 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 annum4).

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.

Table 3 (Black Country housing land supply and indicative phasing 2020-39)

The proposed supply of 47,837 new homes between 2020 and 2039 is the equivalent of 2,518 dwellings per annum. As demonstrated at page 9 of Appendix 7, this is less than what the authorities have delivered per annum for the last six years (2,863 dwellings per annum). Whilst the supply within the urban area may be more exhausted going forward than in those previous six years, this level of delivery demonstrates the scale of demand in the Black Country and that the market is capable of absorbing it.

The increased supply of homes has directly contributed to the area more effectively attracting and retaining people than it has historically. One benefit of this is that the Black Country’s working age population has grown5. The proposed supply in the draft BCP therefore risks this recent trend and ultimately will result in reducing the size of the working age population.

Notwithstanding the above, based on the findings of Turley’s Technical Review of Housing Need and Supply in the Black Country, we have significant concerns regarding the robustness of the Councils’ proposed supply, which we summarise below:

• There are a number of sources of the supply which are proposed on existing vacant or occupied employment land (6% of the total proposed supply). Similarly to the response to draft policy DEL2 above, this approach significantly risks the NPPF’s requirement for the plan to provide a sufficient supply of employment sites, as well as for housing supplies to only include land with a realistic prospect that it is available and could be viably developed. It also contradicts the plan’s objective to support economic growth.

• The above is not a new approach. The BCCS also allocated a total of 16,182 homes on occupied employment land. Based on the Urban Capacity Review Update (May 2021) only 679 (4.2%) of those homes have been delivered to date (with less than five years of the plan period remaining).

• The BCCS assumed a 10% non-implementation rate for sites under construction. The BCP plans to reduce this to 5%, based only on evidence from Wolverhampton City for the period 2001-20046. There is insufficient evidence at this stage to justify such a change in approach.

• 4,973 new homes are proposed on existing allocations (circa 10% of the total supply). The largest contributions to this are from Dudley (2,506 homes) and Wolverhampton (2,248 homes). These sites are largely located in Strategic Centres and allocated in Area Action Plans which followed the BCCS. There is no new evidence to demonstrate their deliverability to support their continued allocation in the draft BCP, there is however evidence where the Councils concede a number of these sites are constrained given issues such as land ownership, viability, the need to relocate existing uses, or ground contamination7.

• No compelling evidence (as required by NPPF paragraph 71) has been provided to justify including 812 new homes (circa 2% of the supply) in Wolverhampton City Centre on upper floor conversions. There is no evidence in the SHLAA or any data on historic windfall delivery rates of this nature in the Black Country.

Making the appropriate reductions in supply based on the above reduces the Black Country’s housing supply by almost 10,000 homes, leaving a potential supply of only 38,266 homes (2,014 dwellings per annum).

There is currently no evidence to demonstrate how the Black Country’s shortfall of circa 28,000 homes will be met, let alone the more likely scale of the shortfall – circa 38,000 homes. The plan refers to Lichfield, South Staffordshire and Shropshire contributing to the shortfall – this totals a maximum of 7,500 new homes8. So a 30,500home shortfall remains based on Turley’s analysis of the supply.

To provide some context to the scale of the shortfall, even if Wolverhampton City’s 35% standard method cities uplift was removed, the shortfall including contributions from other authorities would still stand at circa 16,000 based on the Black Country’s claimed supply, or circa 24,000 homes based on Turley’s analysis of the supply. There is reference to Telford potentially also assisting (and at the Solihull Local Plan examination reference was made to Stafford potentially contributing), but this is unlikely to be a significant contribution or anything close to ensure the unmet need is fully resolved.

This is further exacerbated by the Black Country’s shortfall only being a component of a greater shortfall within the wider Greater Birmingham and Housing Market Area, as demonstrated by the Turley’s Falling Short: Taking Stock of Unmet Needs across the Greater Birmingham and Black Country Housing Market Area report (August 2021) (Appendix 8). That report shows that up to 2040 the potential shortfall within the Housing Market Area could be between 53,000 and 64,000 homes.

The Black Country should therefore be examining its potential supply of greenfield sites to ensure its supply is robust and to further reduce the shortfall to be exported to neighbouring authorities. As set out at Section 4 below land at Birmingham Road, Great Barr has been unfairly scored in the Councils’ SA and Site Assessment scoring exercise. When reasonably and appropriately considered it is capable of delivering new homes which can assist in reducing the scale of the Black Country’s shortfall, whilst providing real benefits for existing and new residents.