Draft Black Country Plan

Object

Representation ID: 43917

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.40 Firstly, similarly to our response to policy CSP1 above, the policy should be clear that
47,837 new homes is the proposed supply only and that the full need for the Black Country is 76,076 new homes. To ensure it is not ambiguous the policy should also clearly state the exact scale of the remaining unmet need so it is clear for any authority working with the Black Country on assisting with its unmet needs.
3.41 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 page 31 of Appendix 7, 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).
3.42 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
1 MHCLG (2020) Table 125: dwelling stock estimates by local authority district
2 Based on the outcome of the standard method as of August 2021, estimated for every local authority by Turley and aggregated to the West Midlands (21,829dpa) and England (297,619dpa)

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.
3.43 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.
Table 3 (Black Country housing land supply and indicative phasing 2020-39)
3.44 The proposed supply of 47,837 new homes between 2020 and 2039 is the equivalent of 2,518 dwellings per annum. At demonstrated at page 9 of Appendix 7, 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.
3.45 The 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 BDP therefore risks this recent trend and ultimately will result in reducing the size of the working age population.
3.46 Notwithstanding the above, based on the findings of Turley’s Technical Review of Housing Need and Supply in the Black Country, we have significant concerns regarding the robustness of the Councils’ proposed supply, which we summarise below:
· There are a number of sources of the supply which are proposed on existing vacant or occupied employment land (6% of the total proposed supply). Similarly to the response to draft policy DEL2 above, 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 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).
· 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.
· 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
3 ONS (2021) Mid-year population estimates, 2001 to 2020
4 Paragraph 2.1.14 of the Black Country Urban Capacity Review Update (May 2021)

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.
· 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.
3.47 Making the appropriate reductions in supply based on the above reduces the Black Country’s housing supply by almost 10,000 homes, leaving a potential supply of only 38,266 homes (2,014 dwellings per annum).
3.48 This would see the shortfall grow to 37,810 homes, just under 50% of the area’s total housing needs. This is significant, especially given there are other sites which can make a contribution to ensuring the Councils’ housing supply is robust, such as land at Pennwood.
3.49 There is currently no evidence to demonstrate how the Black Country’s shortfall of circa 28,000 homes will be met, let alone the more likely scale of the shortfall – circa 38,000 homes. The plan refers to Lichfield, South Staffordshire and Shropshire contributing to the shortfall – this totals a maximum of 7,500 new homes6. So a 30,500 home shortfall remains based on Turley’s analysis if the supply.
3.50 Even if Wolverhampton City’s 35% standard method cities uplift was removed, the shortfall including contributions from other authorities would still stand at circa 16,000 based on the Black Country’s claimed supply, or circa 24,000 homes based on Turley’s analysis of the supply. There is reference to Telford potentially also assisting (and at the Solihull Local Plan examination reference was made to Stafford potentially contributing), but this is unlikely to be a significant contribution or anything close to ensure the unmet need is fully resolved.
3.51 The Black Country should therefore be examining its potential supply of greenfield sites to ensure its supply is robust and to further reduce the shortfall to be exported to neighbouring authorities. As set out at Section 4 below land at Pennwood has been unfairly scored in the Councils’ SA and Site Assessment scoring exercise. When reasonably and appropriately considered it is capable of delivering new homes which can assist in reducing the scale of the Black Country’s shortfall, whilst providing real benefits for existing and new residents.
5 Referenced at paragraph 7.7 of the Viability and Delivery Study (May 2021), paragraph 6.6 of the draft BCP, specific site commentary in the SHLAAs, and paragraph 3.1.24 of the Black Country Urban Capacity Review Update (May 2021)
6 Based on page 2 of the Black Country Authorities’ hearing statement to Matter 2 of the Solihull Local Plan examination

Support

Representation ID: 43918

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.52 It is agreed that a range of types and sizes of accommodation are needed, this is reflected in the Councils’ Housing Market Assessment (March 2021). Notwithstanding this, any housing mix should be agreed based on the most recently available information at the point an application is determined, this is rightly acknowledged by the policy.

Comment

Representation ID: 43919

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.53 At the current time the majority of the Councils’ proposed supply (though we dispute the scale of it) will be on brownfield land, which based on draft HOU3 will only deliver 10% affordable housing.
3.54 Any development on land which is currently in the Green Belt will be expected to deliver the higher 30% affordable housing requirement. Wolverhampton is only proposing 1,014 new homes on land currently in the Green Belt – 8% of Wolverhampton’s proposed supply and circa 5% of its total need.
3.55 It is absolutely necessary for Wolverhampton to be identifying sites which can make a more significant contribution to its affordable housing shortfall – such as Barratt’s site at land at Pennwood which proposes affordable housing provision.

Object

Representation ID: 43920

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.56 Paragraph 7.34 states “Local Employment Areas are often vulnerable to pressure for redevelopment to other uses such as housing. However, the loss of too much local employment land will compromise the successful delivery of the BCP’s employment strategy”. This is contrary to draft policy DEL2 which allows for housing or employment development on previously developed land that accords with other BCP and local plan policies.
3.57 As mentioned at paragraph 3.27 of this document, the draft Local Plan does not currently include an employment protection policy or ‘test’ for applications for housing development or other types of development on employment sites. This could be incorporated in to draft policies HOU1, EMP1-EMP4, or alternatively a specific policy could be prepared.

Support

Representation ID: 43921

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.59 Barratt is supportive of draft policy ENV3. Land at Pennwood has been designed to maximise the delivery of new habitat and biodiversity. The site therefore can contribute to principles identified by policy ENV3, as set out within paragraph 2.42 of the accompanying vision document which provides an overview of the ecological opportunities at the site.

Support

Representation ID: 43922

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.60 Barratt is supportive of the Council’s ambition to protect historic character and local distinctiveness where it is evidenced.
3.61 Turley’s Preliminary Heritage Assessment demonstrates that the significance of Park Hall Hotel is principally invested in its historic interest as an early 18th century country house, its later conversion into a Roman Catholic School and its associations with notable individuals. Its significance is also attributed to its architectural interest, principally the exterior of the principal house and the historic extensions to a lesser extent. The significance of the building has been diminished by widespread alterations to the interior and substantial extensions, to the extent that the legibility of the building as a former house is diminished and its legibility as a former school is very limited. The immediate setting is altered and appears to yield no evidence of the historic domestic or educational use of the building and site.
3.62 The character of the wider setting of the building has also changed and is now characterised in large part by modern residential development. We have found no evidence that the countryside setting of the building was instrumental to the decision to establish a school at Sedgley Park. It is however acknowledged that the land to the south does make a degree of contribution as a remaining part of the rural and countryside setting of the former country house. This has been considered as part of the masterplan presented in the accompanying Vision Document for land at Pennwood, including the retention of a view corridor to the south.

Support

Representation ID: 43923

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.64 As expressed throughout these representations, there is a need for policy
requirements to be fully evidence and justified. Barratt therefore support using the most up to date local open space, sport and recreation standards and these should be evidenced accordingly by each local authority and inform further development of the plan.
3.65 Barratt support draft policy ENV8 which sets out the aim for expanding community use of open space, sport and play, and moving towards most ‘up to date’ local open space, sport and recreation standards. Open space evidence identifies deficit around land at Pennwood. As such, the masterplan comprises a large amount of open space including a new woodland park and play facilities.
3.66 Wolverhampton’s most up to date evidence is the Open Space Strategy and Action Plan (2018). This report finds that:
· There is a decrease in the quantity standards of open space provided in Wolverhampton from 4.43ha per 1,000 population in 2012 to 4.38ha per 1,000 population. This is due to the reduction in the total amount of open space and increase in population.
· The ‘Central and South’ area (which land at Pennwood is located within) represents the second most significant decrease in open space – 0.76ha per 1,000 population. This includes a 0.18ha per 1,000 population loss of parks. The

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loss has seen the need for children and young person’s provision not being met in the area.
· In terms of accessibility to district parks, a large proportion of Sedgley to the north of land at Pennwood is not within a 20 minute walk of a district park.
· The overall summary for the ‘Central and South’ area is that “there are low levels of open space provision” (page 25) and that “there is little potential to create new open space through development”.
3.67 Land at Pennwood’s significant benefit of public open space representing more than 50% of the proposals, including a woodland park and play areas will make a substantial contribution to the deficits identified in Wolverhampton’s most up to date open space, sport and recreation evidence.

Object

Representation ID: 43924

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.68 Policy ENV9 appears to be a duplication of the criteria contained in draft policy CSP4 and can be most appropriately dealt with by way of the production of a Local Design Guide for the Black Country aligning with the Governments’ recent amendments to the NPPF. As such it is not necessary.