Draft Black Country Plan

Comment

Representation ID: 23288

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Part 1.(a) of policy CSP1 states that during the course of the Plan Period “at least” 47,837 net new homes will be provided in the Black Country. However, the housing target of 47,837 dwellings will not deliver the total number of houses that are required. Table 2 – Black Country Development Strategy 2020- 2039, of the draft Plan identifies a need for the development of 76,076 dwellings. The residual requirement of 28,239 dwellings will be directed to other local authority areas through the Duty to Cooperate. This approach has been adopted due to a lack of suitable additional sites to allocate for development within the Black Country.

We have a number of concerns with the overall housing requirement identified in the Plan and the sources of housing land supply that have been identified to meet the target. This has consequential implications for the quantum of development that will be needed to be exported to other local authority areas.

Comment

Representation ID: 23289

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

The housing requirement

Table 2 of the draft Plan suggests that a total of 76,076 dwellings are 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 of the BCHMA 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 that a total of 76,361 dwellings is required during the course of the plan period (4,019 dpa x 19 years).

The National Planning Policy Framework (“the Framework”) advises at paragraph 61 that to determine the “minimum” number of homes needed strategic policies should be informed by a local housing needs assessment conducted using the Standard Method, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market signals. The draft Plan suggests a minimum housing figure below that identified by the BCHMA, and consequently fails to meet the requirement of the Framework. That being the case, as a very minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents.

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 figures set out above will apply”. That being the case, the BCHMA does not test whether the minimum Standard Method housing requirement figure should be increased, in accordance with the requirements of the PPG.

Paragraph ID:2a – 010 – 20201216, of the PPG advises that there will be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate 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.

We are not aware of any assessment to establish whether the minimum Standard Method housing requirement should be exceeded. It could be the case that the minimum Standard Method housing requirement is not sufficient to meet the housing needs of the Black Country.

In this regard we note that Table 5.1 of the BCHMA identifies that the percentage of people of working age in the Black Country will be less in 2039 than it is in 2020. In order to meet the emerging Plan’s economic growth aspirations it is necessary to ensure that a sufficient number of houses are provided to house the Black Country’s workforce. An assessment should be undertaken to establish if the housing requirement needs to be uplifted to support economic growth.

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing will be via Section 106 agreements.

Comment

Representation ID: 23290

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing will be via Section 106 agreements.

Comment

Representation ID: 23291

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility and Self Build/Custom Build Housing, advises that 10% affordable housing will be sought on sites in lower value areas and brownfield sites in medium value zones. 20% affordable housing will be sought on greenfield sites and in medium value area. On all sites in higher value areas 30% affordable housing will be sought. This approach has been adopted for viability reasons. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing. It is appreciated that affordable housing will be provided on sites allocated for development outside of the Plan area allocated for development to support the growth of the Black Country. However, as these sites are not known there is no certainty as to how much affordable housing they will deliver. This is not, therefore, a consideration at this time.

The draft Plan does not identify what proportion of the housing requirement is expected to take place in each of these zones. However, paragraph 6.4 of the Plan advises that 81% of the housing requirement is expected to be provided on brownfield land and 19% on greenfield land. That being the case the majority of the sites will provide either 10% or 20% affordable housing (if this is viable). This strongly suggests that the affordable housing policy within the Plan will be incapable of delivering a sufficient quantum of affordable housing to meet their identified need.







We are not aware of any assessment that seeks to establish the relationship between the quantum of affordable housing required by the BCHMA, and the likely level of affordable housing that it is expected Policy HOU3 of the Plan will deliver. This is a key piece of evidence that is missing from the emerging Plan. An increase to the minimum housing requirement may be required to ensure that a sufficiently supply of affordable housing is provided.

Drawing these matters together, it is our view that the housing requirement within the draft Plan is not justified given that it is below the minimum Standard Method requirement, and there appears to have been no supporting work undertaken to establish if there is a requirement for an uplift to the minimum Standard Method housing target on economic or affordability grounds.

Comment

Representation ID: 23292

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Sources of Housing Land Supply

Table 3 – Black Country Housing Land Supply Indicative Phasing 2020-2039, identifies the various sources of housing land supply. We have a number of concerns with the sources of supply, including:

• Sites with Other Commitment – The sites in this category are expected to deliver 3,802 dwellings during the course of the Plan period. It is understood from the Black Country authorities SHLAAs that an “other commitment” is a site with a resolution to grant planning permission but the Section 106 has not been signed. This source of supply is discounted by 10% in order to allow for non-delivery.

It is not clear from the draft Plan how the 10% discount rate has been calculated. However, it is noted that the SHLAAs (eg. Walsall SHLAA 2019 paragraph 17) advise that Other Commitments are discounted by 10% as the adopted Black Country Core Strategy (“BCCS”) applied a discount rate of 10% to commitments. It is advised that a discount rate that is based on past trends may not be an appropriate way of establishing future delivery rates. Housing delivery in the Black Country has been affected by the 2008 recession and a number of government initiatives for improving future delivery, such as help to buy and ISA for first time buyers.

Whilst this may be the case, we would also suggest that it is equally unreliable to take a discount rate from the adopted BCCS, which was published in 2011. The BCCS is in excess of ten years old, and its supporting evidence documents even older. At the very least, a past trends based analysis should be undertaken in order to see if the discount rate is robust for the Other Commitments category. Furthermore, it is not clear whether sites with a resolution to grant planning permission, but the S.106 has not been signed, where the resolutions are several years old have been included. If the resolution to grant planning permission is more than 6 months old the site should not be included as a source of supply.

• Existing Housing Allocations in Strategic Centres
• Occupied Employment Land
• Green Belt sites
• Other Allocations
• Additional Site Capacity in Strategic Centres

Comment

Representation ID: 23293

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Furthermore, as detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. This is on the basis that:

• The emerging plan seeks to adopt a NDSS policy which will increase minimum dwelling sizes impacting upon density.

• It is not unusual, in our experience, for brownfield sites within the Black Country to have constraints that adversely affect their capacity and density, such as mineshafts or due to their relationship to surrounding uses.
• Achieving biodiversity net gain could reduce net developable areas.
• On site POS provision could reduce net developable areas.

It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. Site densities should be based on agreed masterplans for the strategic sites as the process is refined, rather than a blanket approach. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will need to be reduced accordingly.

Comment

Representation ID: 23294

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

In conclusion, we are concerned that the identified sources of housing land supply will be incapable of meeting the housing requirement identified by the Plan. In addition, given the housing requirement should be a minimum there is clearly a distinct advantage in erring on the side of caution, and applying robust and realistic lapse rates to the various sources of supply as if additional housing does come forward this will be of no detriment to the Plan. However, a housing delivery shortfall has the potential to be extremely problematic, causing five year housing land supply issues, the LPA’s failing the Housing Delivery Test and preventing the provision of much needed market and affordable housing within the Black Country.

Comment

Representation ID: 23301

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

It is fully appreciated that the BDP cannot include policies for the allocation of land outside of the Black Country area. However, given that a significant proportion of the housing and employment requirement will be met in other Local Authority areas, it is our view it would be helpful for the Spatial Strategy to include guidance on where the Black Country authorities will support the allocation of sites in emerging Plans.

This will help neighbouring authorities within the site selection process and the development industry in bringing sites for development. It is out view that the BDP should advise that the Black Country Authorities will support the allocation of sites in neighbouring authorities that:

• Are located close to the edge of the Black Country, so that development is provided close to the area where the need arises from.

• Are able to come forward for development promptly once allocated.

• Have good access to services and facilities.

• Are able to deliver all necessary onsite infrastructure

• Can provide onsite services and facilities that are to the benefit residents and the wider community

• Are able to deliver greater biodiversity net gain

• Area able to take advantage of existing landscape features.

Support

Representation ID: 23305

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 and HOU1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

Support

Representation ID: 23307

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We support the recognition in Policy CSP3 that exceptional circumstances exist to release land from the Green Belt and allocated it for development. It is clear that the housing requirement cannot be met without significant Green Belt release. However, even with Green Belt land release is is apparent that the full housing requirement cannot be met.