Draft Black Country Plan

Object

Representation ID: 44768

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing need
• 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 pages 5 and 33 of the report, 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 20201) 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 annum2).

• 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.

Object

Representation ID: 44769

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Supply
• 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 11 of the enclosed report, 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 proposed supply therefore threatens to reduce the recent rate of delivery across the Black Country by 12%. Demographic modelling suggests that this would dramatically slow the recent rate of population growth and effectively force around 5,500 residents to move elsewhere every year, over three times more than in recent years.

• The recent 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 grown3. The proposed supply in the draft Black Country Plan therefore risks this recent trend and ultimately will result in reducing the size of the working age population

Object

Representation ID: 44770

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

In terms of the proposed supply, there are a number of sources which are proposed on existing vacant or occupied employment land (6% of the total proposed supply). 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 Black Country Core Strategy (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).

Object

Representation ID: 44771

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

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 2001-20044. There is insufficient evidence at this stage to justify such a change in approach.

Object

Representation ID: 44772

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

• 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 contamination5

Object

Representation ID: 44773

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

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 contamination5

Object

Representation ID: 44774

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

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.

Object

Representation ID: 44775

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

5. There may well be an even greater need for housing given that the standard method makes no attempt to predict the impact of changing economic circumstances, for example, and the Councils’ existing evidence base does not properly consider whether there will be sufficient labour to meet the economic growth ambitions of the sub- region. It equally provides no assurance at present that the prevailing need for houses, estimated to account for two thirds of the overall housing need in the Black Country, can and will be met through the proposed supply.

Object

Representation ID: 44776

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing supply and shortfall

6. The Draft BCP intends to make provision for only 47,837 homes over the plan period, equivalent to 2,517 dwellings per annum, leaving a shortfall of circa 28,239 homes to 2039 with an assumption – but no guarantee – that this will be met in neighbouring areas. The proposed level of annual provision has been exceeded in each of the last six years, when roughly a third more homes have been delivered. The Black Country has seen tangible benefits as a result, more effectively attracting and retaining people than has been the case historically and once again growing its working age population.

7. Rather than planning positively for a similar “boosting” that would very nearly meet the minimum need for housing suggested by the standard method, the Draft BCP instead threatens to reduce the recent rate of delivery by 12%. Demographic modelling suggests that this would dramatically slow the recent rate of population growth and effectively force around 5,500 residents to move elsewhere every year, over three times more than in recent years.

8. The associated reduction in the size of the working age population, combined with potential behavioural changes, would be expected to leave a labour force capable of supporting only 615 new jobs every year, whereas at least one economic forecast suggests that the Black Country has the potential to create over three times as many jobs (c.2,100 per annum) and indeed the LEP has previously expressed a target that appears to be over ten times greater, at in excess of 6,000 jobs per annum.

9. This demographic modelling could even be reasonably described as optimistic as it assumes that the proposed requirement can be met through the supply identified in the Draft BCP, which may not be the case based on the analysis in this report. The National Planning Policy Framework (NPPF) requires Local Plans to be aspirational but deliverable, identifying a sufficient supply of sites taking into account their availability, suitability and likely economic viability. Those sites should meet the tests of deliverable and developable contained in the NPPF glossary. This report assesses the Councils’ claimed supply against the NPPF guidance and concludes that 9,571 homes are unlikely to be deliverable/developable during the plan period. This has a significant impact because it would result in the shortfall increasing to 37,810 homes, circa 50% of the minimum need for housing.

10. Given the large gap between supply and need, compounded by previously over optimistic assumptions on what can be delivered, the Councils’ sources must be scrutinised further as the BCP advances, and the implications of the possible additional housing supply shortfalls considered closely.

11. This report follows on from Turley’s ‘Falling Short – Taking stock of unmet needs across the Greater Birmingham and Black Country Housing Market Area’ published in August 2021. That report identifies a housing shortfall across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) of between circa 18,700 and 42,000 dwellings up to 2031, and between 68,700 and 78,000 homes up to 2040. This includes the Black Country shortfall as currently reported in the Draft BCP. Any reduction to the Councils’ proposed supply would only exacerbate and worsen the wider GBBCHMA shortfall up to 2031 and 2040.

Object

Representation ID: 44777

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Housing supply and shortfall

6. The Draft BCP intends to make provision for only 47,837 homes over the plan period, equivalent to 2,517 dwellings per annum, leaving a shortfall of circa 28,239 homes to 2039 with an assumption – but no guarantee – that this will be met in neighbouring areas. The proposed level of annual provision has been exceeded in each of the last six years, when roughly a third more homes have been delivered. The Black Country has seen tangible benefits as a result, more effectively attracting and retaining people than has been the case historically and once again growing its working age population.

7. Rather than planning positively for a similar “boosting” that would very nearly meet the minimum need for housing suggested by the standard method, the Draft BCP instead threatens to reduce the recent rate of delivery by 12%. Demographic modelling suggests that this would dramatically slow the recent rate of population growth and effectively force around 5,500 residents to move elsewhere every year, over three times more than in recent years.

8. The associated reduction in the size of the working age population, combined with potential behavioural changes, would be expected to leave a labour force capable of supporting only 615 new jobs every year, whereas at least one economic forecast suggests that the Black Country has the potential to create over three times as many jobs (c.2,100 per annum) and indeed the LEP has previously expressed a target that appears to be over ten times greater, at in excess of 6,000 jobs per annum.

9. This demographic modelling could even be reasonably described as optimistic as it assumes that the proposed requirement can be met through the supply identified in the Draft BCP, which may not be the case based on the analysis in this report. The National Planning Policy Framework (NPPF) requires Local Plans to be aspirational but deliverable, identifying a sufficient supply of sites taking into account their availability, suitability and likely economic viability. Those sites should meet the tests of deliverable and developable contained in the NPPF glossary. This report assesses the Councils’ claimed supply against the NPPF guidance and concludes that 9,571 homes are unlikely to be deliverable/developable during the plan period. This has a significant impact because it would result in the shortfall increasing to 37,810 homes, circa 50% of the minimum need for housing.

10. Given the large gap between supply and need, compounded by previously over optimistic assumptions on what can be delivered, the Councils’ sources must be scrutinised further as the BCP advances, and the implications of the possible additional housing supply shortfalls considered closely.

11. This report follows on from Turley’s ‘Falling Short – Taking stock of unmet needs across the Greater Birmingham and Black Country Housing Market Area’ published in August 2021. That report identifies a housing shortfall across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) of between circa 18,700 and 42,000 dwellings up to 2031, and between 68,700 and 78,000 homes up to 2040. This includes the Black Country shortfall as currently reported in the Draft BCP. Any reduction to the Councils’ proposed supply would only exacerbate and worsen the wider GBBCHMA shortfall up to 2031 and 2040.