We have a number of concerns that need to be addressed:

* The emerging SHMA should have tested whether the HMA boundary remains valid for the purposes of its assessment, rather than just seeking to build upon the work undertaken to establish the Greater Birmingham HMA as part of the preparation of the Birmingham Development Plan. It is commonly accepted that HMAs overlap and the HMA for Birmingham will not be exactly the same as that for the Black Country.
* It is not clear from the SHMA how the backlog against the adopted BCCS has been dealt with. The only reference to a 'backlog' relates to a notional figure for the shortfall for the period 2011-2014 against the SHNS suggested annual need figure. No reference is made to the period between 2006 and 2011.
* The SHMA does not fully address affordable housing requirements, which is contrary to the guidance in the Planning Practice Guidance ("PPG"), which requires the SHMA to "address the need for all types of housing, including affordable housing and the need for different groups in the community". Affordable housing need is not a direct component of the demographic part of the objectively assessed needs assessment and so a 'policy on' calculation is required in this regard. The SHMA advises that it is for the client Authorities to consider whether more new homes over and above the housing needs figure identified in the SHMA should be provided to address affordable housing need through policy adjustments. From our perspective, it does not matter who undertakes this exercise, it just needs to be undertaken to ensure the housing need figure complies with the guidance in the PPG.