As a starting point we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to revisit the HMA but builds upon the work undertaken in establishing the Greater Birmingham HMA as part of the preparation of the Birmingham Development Plan. HMAs overlap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whether the HMA boundary remains valid for the purposes of its assessment.

It should also be noted that the SHMA does not fully address affordable housing requirements. It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordable housing need is not a direct component of the demographic part of the objectively assessed needs assessment. The SHMA has not factored in affordable housing needs. It is advised in the SHMA 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 in the plan area to address affordable housing need through policy adjustments.

The Framework confirms at paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things, "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore, provide a complete picture of housing need within the subject Authority areas. The SHMA is not in accordance with national guidance. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore, there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the Plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing BCCS where there has been significant under delivery in the Growth Network. As referred to in our response to Question 1, there is uncertainty regarding for delivery of a significant number of the housing allocation identified on the existing employment land by current Development Plan documents. It is necessary for former Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure to take account of non-delivery of proposed housing allocations. At the present time, the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). An unexpected number if windfall sites have, however, bolstered supply using this as a proxy for delivery it is, our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 20% to establish an overall housing requirement.

In terms of source of supply the current completion rates are significantly below what is required for even the current BCCS housing requirement. Taking the base SHMA housing requirement of 78,190 units over the plan period, results is an annualised requirement for 3,554 units per annum, which is far in excess of what has ever been achieved annually in the BCCS. In this context, we believe that it is going be important to significantly change the balance of the current supply with far greater reliance on greenfield/Green Belt sites.

We note that the overall supply from the urban area depends upon some 42,507 units from existing sites with a further 8,335 units from the urban area, much of which appears to be from employment sites. Given that the problems in delivering housing employment sites through the current strategy we consider that a Local Plan strategy which relies upon some 65% provision on urban brownfield/greenfield sites is wholly unrealistic.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the strategy of the plan with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA.