Table 2 - Black Country Development Strategy 2020 - 2039

Object

Representation ID: 12211

Received: 11/10/2021

Respondent: Mrs Karen Shaw

You are proposing to build in areas that don't have the infrastructure needed to support the new residents

Object

Representation ID: 20973

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Table 2 of the draft Plan suggests that a total of 76,076 dwellings is required during the Plan Period. This is, however, less than the Standard Method housing requirement identified by the Black Country Housing Market Assessment 2021 (“BCHMA”), produced by the Black Country Authorities. At paragraph 4.13 it is advised that “the final housing need in the Black Country, assessed using the revised Standard Method, is 4,019 per year”. The Plan period runs from 2020 to 2039. As such, the BCHMA concludes with a total of 76,361 dwellings required during the course of the plan period (4,019dpa x 19 years). As a minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents in accordance with Paragraph 61 of the Framework.

Paragraph 4.14 of the BCHMA advises that whilst paragraph 010 of the PPG identifies a series of circumstances where it may be appropriate to pursue a higher housing needs figure than is indicated by the Standard Method “this assessment is carried out on the basis that the Standard Method figure set out in the above will apply”. That being the case, the BCHMA does not test whether the minimum standard of housing requirement figure should be increased, contrary to the requirements of the PPG.
Paragraph ID:2a – 010 – 20201216, of the PPG advises that these circumstances where it may be appropriate to explore a higher housing figure include, but are not limited to, situations where increases in housing need are likely to exceed past trends because of:
• Growth strategies for the area that are likely to be deliverable;
• Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• An authority agreeing to take on unmet need from neighbouring authorities.