Draft Black Country Plan

Comment

Representation ID: 22519

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Harris Lamb

Housing Requirement

Policy CSP1 – Development Strategy, of the draft Plan provides the overarching policy guidance on housing delivery during the course of the Plan Period. Part 1.(a) of the policy 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.

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.

In the first instance, 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).

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 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, 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 meet the jobs which will be created during the course of the Plan Period. 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 would be via Section 106 agreements.

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 areas. On all sites in higher value areas 30% affordable housing will be sought. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing.

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, 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 by 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 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.

Housing Delivery

We also have a number of concerns with the deliverability of various sources of the housing demand supply identified by the Plan. 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. There is insufficient information available to determine whether or not the discount rate suggested is robust. Furthermore, it is not clear whether there are sites with a resolution to grant planning permission, but the S.106 has not been signed, where the resolutions are several years old. 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 – These sites are expected to provide 4,973 dwellings. This is excluding those sites within the Strategic Centres that already have the benefit of planning permission, a resolution to grant planning permission, or are completed. The Walsall Site Allocations Document was adopted in 2019. The Dudley Borough Development Strategy was adopted in February 2017 and other various Dudley MBC AAPs were adopted between 2011 and 2017. The Sandwell Site Allocations and Delivery DPD was adopted in December 2012. The Wolverhampton Area Action Plans were adopted between
2014 and 2016. There has, therefore, been a significant period of time for the sites allocated for development in the Strategic Centre to to come forward for development. The fact that these sites have not delivered despite the benefit of a positive planning framework suggests that there may be problems with their delivery. That being the case, the 10% discount rate suggested for these sites is entirely unrealistic.

• Occupied Employment Land - Occupied employment land is expected to deliver 3,091 dwellings towards the total housing requirement. This should not be included as a source of supply. There is no guarantee if or when such sites will come forward for development. Landowner’s intentions may change during the course of the Plan Period. In addition, we have frequently found that industrial values outweigh residential values in large parts of the Black
Country. As a consequence, it simply may not be economic to bring a site forward for residential development.

Furthermore, there is a significant shortfall of employment land within the Black Country, and the conurbation as a whole. Whilst new employment allocations are proposed by the Plan these will be new build estates where rents will be significantly greater than second hand stock. It is unlikely that businesses that are located on the poorer quality employment sites will be able to afford to rent or buy a new premises. Secondary, and lower cost stock, plays a vital role in the West Midlands economy. Losing land of this type to residential use may result in businesses closing. We are, therefore, extremely concerned that this source of supply is by and large undeliverable but could also have a detrimental effect on the supply of employment land through the plan area. We therefore recommend that this source of supply be deleted from the overall supply. If allocated employment sites come forward for development during the course of the Plan Period they should simply be treated as part of the proposed windfall allowance.

• Other Allocations - The “Other” allocations within the plan have a 10% discount rate applied.
It is not clear how this discount rate has been calculated. However, given the significant proportion of the allocations in the draft Plan that are brownfield sites they are likely to have delivery constraints. A 10% discount rate is inadequate.

• Additional Site Capacity in Strategic Centres - The sites in this category are due to be identified and allocated through subsequent Local Plans produced later into the plan period. We are concerned that the housing figures identified for these areas are not robust, and ultimately the plan making process will find that there is not the capacity to deliver this level of development within future Local Plans. A substantial discount rates should, therefore, be applied to sites in this category.


Furthermore, as detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. The emerging plan seeks to adopt a space standard policy which will increase 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 density, such as mineshafts or due to their relationship to surrounding uses.

It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will be reduced accordingly.

In conclusion, we are concerned that the identified sources of supply will be incapable of meeting that part of the housing requirement identified by the Plan to be developed in the Black Country. 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, failing the Housing Delivery Test and providing much needed market and affordable housing within the Black Country for those that need it.

Comment

Representation ID: 22521

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Harris Lamb

Employment Land Issues

The Representor considers that the Black Country economy is an important element of the overall West Midlands’ economy and, as such, needs to be strongly supported in terms of the Plan’s policy objectives and the allocation of land to meet the future economic needs of the Plan. In this context, the Representor strongly supports the desire to allocate further land to meet the Black Country’s needs and provide support for the principle of Policy EMP1. The draft Plan acknowledges that the employment needs of the Black Country are such that not all of this need can be accommodated within the Plan area. Paragraph 7.10 explains that the allocations in the Plan will meet only 63% of forecast needs arising within the Black Country. It is explained in paragraph 7.12 that a further 37% of employment land will, therefore, not be met within the Black Country and that this will need to be accommodated in adjoining authorities which have a strong existing economic relationship with the Black Country.

The Representor welcomes the acknowledgement that not all of the Plan’s needs can be met in the Black Country authorities administrative areas and that land will have to be released elsewhere to meet the overall economic needs of the Plan area. The Representor also welcomes the identification of South Staffordshire as having a strong economic link with the Black Country.

However, the Representor is concerned that the extent of the overspill requirement has been underestimated. Policy EMP1 explains that of the total of 355 hectares of employment land which is to be delivered in the Plan period, some 74 hectares (a minimum figure) will be brought forward on other sites throughout the Black Country, mainly through the redevelopment, intensification and enhancement of existing employment areas and premises. It is clear, therefore, that a significant proportion of the land to be brought forward is in fact redevelopment of the existing stock and does not represent net additions which will meet the increased needs identified for the Plan area. Therefore, the Representor objects to Policy EMP1 and considers that the actual figure identified in sub-para 1 of 355 hectares should be reduced to 281 hectares. This would mean that the extent of the overspill identified at paragraph 2.10 should be increased by 74 hectares to 284 hectares (it is also noted that the figures identified in 7.10 do not appear to tally with those in Policy EMP1, sub-para 1 and this error should be rectified).

The Representor has submitted details of land at Wall Heath, which is well placed to accommodate the overspill needs for employment land for the Black Country.

The Representor is also extremely concerned that the supply figure identified to meet the Black Country’s needs should place no reliance upon the strategic logistic site at Four Ashes. That site serves a regional/national need and is not suitable for many of the businesses seeking premises within the Black Country or on sites immediately adjoining it.

Comment

Representation ID: 22522

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Harris Lamb

Omission Site: Land at Holbeache Lane, Kingswinford

The Objector has noted elsewhere that there is a considerable overspill figure to be accommodated and which will have to be found in the Green Belt surrounding the Black Country. The Objector has also raised concerns that some of the findings regarding the use of existing industrial land for residential development in the Plan period are unsound and that the extent of the overspill has, in fact, been underestimated. The Objector submits that it is imperative that the Black Country authorities utilises as much land as possible within their administrative area to ensure that every opportunity has been undertaken to accommodate the Black Country’s needs within its own boundaries.
In this context, the Objector submits that land under its control north of Holbeache Lane and adjoining the Policy DSA1 allocation – Land South of Holbeache Lane should be identified for residential development.

The allocation of the site is justified on the following grounds:

1) There is a substantial shortfall in the amount of land needed to meet the Black Country’s needs and that which is allocated in the Plan; thus the allocation of the site would help to reduce the extent of the shortfall. The overall land available is some 7.279 hectares which, at a density of 40 units on a net developable area of 5 hectares, could provide some 200 units.

2) The site is situated in an area where further development is already contemplated by the Black Country and we refer to the Policy DSA1 allocation. It is clear, having regard to this allocation and also the surrounding land uses to the south, that residential development is inappropriate land use in the area.

3) Sustainable Location
Kingswinford is a sustainable part of the Black Country with good access to a range of facilities including employment and local centres.

4) Visual Impact
The site is well contained by existing land uses to the south-east and east, a substantial planting belt to the north, providing visual containment and prevent further outward spread of development. To the south, the site adjoins the DSA1 allocation.

5) Although the site is within the Green Belt, it is clear that Green Belt will have to be released in order to meet the Black Country’s needs. As noted above this particular site is well contained by existing landscaping to the north and the existing urban area and proposed allocations to the east and south and west.

In this context, there will be no uncontrolled urban sprawl. Although there will be a loss of Green Belt in principle, none of the other purposes of the Green Belt would be materially affected.

6) There is direct access to the A449 along Holbeache Lane. Whilst this would need to be upgraded in part, this could be done in conjunction with adjoining development.

7) The site is flat and otherwise relatively featureless.


8) The site is in single ownership and there is no impediment to it being brought forward within the Plan period.

For the reasons stated above, the Objector respectfully requests that land to the north of Holbeache
Lane be added to the allocation of residential sites within the Black Country Plan.
Holbeache Lane

Object

Representation ID: 23120

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Savills

Black Country Draft Plan Regulation 18 Consultation Representations on behalf of CWC Group - Clowes Developments Land at Lawnswood Road, South Staffordshire

Savills (UK) Limited, on behalf of CWC Group - Clowes Developments sets out the below representations in respect of their land at Lawnswood Road, South Staffordshire.

The site is listed as site 108 in the current Black Country SHLAA, as shown in the below Plan.

See Attachment

The site is located within South Staffordshire District and has been submitted to a Call for sites consultation in December 2019, accompanying representations to the previous round of consultation of the emerging South Staffordshire Local Plan.

There is a discrepancy between the site boundary put forward in the Black Country SH LAA and that set depicted in a submission made to the South Staffordshire call for sites. The Black Country SHLAA includes land at Ridgehill Woods, whereas the South Staffordshire Plan does not. We request that the site boundary being considered by the Black Country is amended to reflect the submission made to South Staffordshire, and remove Ridgehill Woods as land for development, as this was never the intention. A copy of this plan is submitted with these representations.

Due to the site's location within South Staffordshire, our comments below focuses on the Black County's Duty to Cooperate (DtC) with neighbouring authorities, including South Staffordshire regarding their unmet housing need. According to the consultation draft of the emerging Local Plan this totals 28,239 dwellings (37 .12% of BC's total requirement). This shortfall has occurred as the Black Country conclude that they have identified and made effective and extensive use of brownfield and urban sites and have also undertaken density uplifts in relation to both existing and new allocations.

The Shortfall Position

The Black Country regulation 18 draft plan sets out how the Black Country intend to meet its housing requirement of 76,076 dwellings in the period 2020 - 2039. This is planned to be delivered as follows:

• Total new homes proposed: 47,837 (62.88% of total requirement)
• To be exported through DtC: 28,239 (37.12% of total requirement)

This means that over a third of the Black Country's housing requirement will need to be met outside of its boundaries. At present there is no definitive conclusion of how the 28,239 dwellings are to be accommodated, notwithstanding the potential need for a buffer in addition to this total. Below we discuss the current position in relation to the current status of "offers" made by neighbouring LPAs to deal with the DtC requirement.

LPA "Offers"

We have composed the below table taking account of the "offers" set out in the Black Country DtC statement which was released for consultation along with the draft plan. We have set out below how contributions from each LPA compares in terms of being proportionate to the overall shortfall of 28,239.

See Attachment for Table 1: Agreed Contributions to Black Country Shortfall

In calculating the overall contribution from HMA LPAs, we have only considered contributions that have been confirmed by LPAs to be made specifically in respect of the Black Country's need. This is because agreement on how contributions towards general GBBCHMA shortfall has not been reached, which makes the approach being taken in the Black Country Plan unjustified and ineffective.

From our analysis, only 3,500 of the dwelling offers being made can be directly attributed to meeting the needs of the Black Country shortfall. This is significantly lower than the 8,000 dwelling total claimed by the BCAs in paragraph 7 .6 of the DtC Statement. Paragraph 7 .6 of the DtC states that "some of this contribution would need to be attributed to meeting the needs of Birmingham...." Therefore it remains unclear what "offers" are solely for the Black Country shortfall.

A key points that we draw from this analysis only 12% of the Black Country's housing shortfall appears to have been identified to date from neighbouring authorities which we consider to be a weak position for progressing the Black Country Plan.

From the Duty to Cooperate Statement it appears that there is a lack of clarity in respect of some "offers" and whether the housing being offered is for the Birmingham HMA shortfall or the Black Country shortfall or both.

Table 2 below sets out a review of the Birmingham and Black Country Housing Market Area and provides an overview of the proposed offer by each LPA towards the general housing shortfall in the wider Birmingham and Black Country HMA. It sets out what the current "offers" are in relation to the overall current proposed contributions that have been put forward and what that "offer" is in terms of the % of the overall wider HMA shortfall.

See Attachment for Table 2: Agreed and Potential Contributions to GBBCHMA Shortfall

We note in paragraph 7.9 that the Council make reference to potential contributions totaling a higher figure. The same issue applies here, in that this is mostly comprised of contributions referencing the whole HMA, rather than the Black Country specifically. Even in a very best case scenario in which all of the "offers" are attributed to the Black Country, this only accounts for 61 % of the unmet need and leaves 10,834 dwellings still to be found.

In summary, only 3,500 dwellings have been secured towards the unmet need, accounting for only 12% of the unmet need and leaving a further 24,739 dwellings to be found. The BCAs therefore have a lot more work to do in order to secure a suitable level of contributions towards the unmet need from their neighbours and meet their shortfall.

We consider that in order to fully address the shortfall, LPAs with the greatest geographical and functional relationship with BCAs should be making the greatest contribution towards this unmet need. Our analysis below shows that South Staffordshire is the LPA with the greatest geographical connection to the Black Country. The map bellow shows geographical connections to the Black Country, with South Staffordshire sharing 44% of the Black Country boundary.

See Attachment for Figure 2

Functionally, the LPAs are connected by proximity and key connections such as the M54 and M5 motorways and the Shrewsbury to Birmingham railway line.

We also be consider a functional relationships to exist in the form of the Dudley Travel to Work Area (TTWA). Clowes Development's site at Lawnswood Road, South Staffordshire is located within the Dudley Travel to Work area, along with areas of the Black Country including Stourbridge, Kingswinford and Brierley Hill. TTWAs have been developed by ONS to provide an approximate self-contained labour market areas. These are areas where most people both live and work. They are based on statistical analysis rather than administrative boundaries. We consider that such measures should be used when determining the weight given to functional relationships with other Local Authorities.

The table below sets out the length of shared boundary between the Black Country and neighbouring LPAs. We consider this sort of geographical relationship should be considered when determining where contributions towards meeting the Black Country's shortfall should come from.

See Attachment for Table

This table demonstrates that only Lichfield of the LPAs bordering the BCAs has agreed to make a contribution to explicitly meet the Black Country's shortfall of housing land. This represents only 7.08% of the total shortfall of 28,239. In this context the Black Country should be seeking to secure a much larger amount from South Staffordshire as by far the largest LPA bordering the Black Country, particularly considering Birmingham's inability to contribute to remedy The Black Country's shortfall due to having a shortfall themselves.

Statements of Common Ground

We note at section 1.10 of the draft local plan there is reference to an intention to draft and agree statements of common Ground with relevant authorities and publish them at the publication stage of the Local Plan. The DtC statement also references that a SoCG will be produced taking on board engagement through the regulation 18 consultation with neighbouring LPAs. It is proposed that the SoCG contains actions and the SoCG will be submitted with the draft plan for examination.

We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (PPG Paragraph: 020 Reference ID: 61-020-20190315). Furthermore the BCAs proposal for the SoCG to contain actions and then be submitted at such is at odds with the requirement for Duty to Cooperate to be dealt with before submission of a Local Plan (PPG Paragraph: 031 Reference ID: 61•
031-20190315).

Meetings with Neighbouring LPAs

We note that another way the Black Country intends to evidence constructive engagement is through the publication of evidence such as that seen at appendix 3 of the DtC Statement, entitled: "Duty to Cooperate Meetings held from 2017 onwards". This lists out a number of meetings with different partners. The minutes, actions and outcome of these actions should be made public (albeit redacted where necessary). This would then suitably evidence cooperation. Otherwise it is not clear whether meetings have been useful I ensuring effective cooperation.

Another issue we have identified with the meetings that have taken place is that they are recorded as taking place at the earliest from September 2019 in the case of South Staffordshire, with meetings engaging other LPAs beginning in 2020. Consultation of the emerging Black Country Plan first took place in 2017. These meetings should have therefore been taking place and engagement being recorded at this point. We ask the BCAs to publish detailed minutes, lists of attendees etc. for the meetings referenced in appendix 3 and furthermore provide a clear indication of the level of engagement that has been taking place with HMA LPAs previous to February 2019 in order to satisfy the requirement for ongoing and meaningful engagement.

Level of unmet need from GBBCHMA

As set out above we have serious concerns regarding the level of housing that neighbouring LPAs to the Black Country can deliver in order to satisfy the unmet need. A key issue not discussed within the Black Country's consultation submission is the likelihood of the HMA shortfall being larger than the
2,597 dwelling figure identified in the HMA position statement 3.

Significantly, a consortium of housebuilders and promoters have recently commissioned a review of the Housing Market Area shortfall. They have concluded that up to 2031, the shortfall is around 19,000 dwellings and up to 2036 this could range between 50,000 and 60,000 homes.

Several issues exist with the HMA shortfall calculations, which are based on position statement 3, including:

- It covers the period 2011 to 2031, whereas the Local Plan runs until 2039.

- It does not reflect the standard method, particularly including the 35% uplifts required of Birmingham and Wolverhampton.

- Raw data has not been made readily accessible alongside the latest position statement, making it difficult to scrutinise the statement properly.

There is therefore compelling evidence for the existence of a higher level of unmet need from across the HMA LPAs, including the Black Country Authorities.

The level of unmet need across the GBBCHMA impacts the Black Country as it has the potential to reduce the amount of additional housing need that can be met and attributed to the Black Country.

There are a limited number of suitable sites currently identified and this will need to increase in order to accommodate the wider GBBCHMA need and the Black Country's individual need.

Key points for the Black Country Authorities to Consider

Only around 7% of the Black Country's shortfall has been agreed to be dealt with by neighbouring LPAs. Even in a very best case scenario this rises to 61 %, albeit a more realistic figure is perhaps around half as other contributions are made in relation to the wider GBBCHMA.

We consider that in order to fully address the obvious and identified shortfall, LPAs with the greatest geographical and functional relationship with BCAs should be making the greatest contribution towards this unmet need.

Our analysis below shows that South Staffordshire is the LPA with the greatest geographical connection to the Black Country (44% of the Black Country Boundary) and is partly within the Dudley TTWA, demonstrating a clear functional relationship for the part of the district within the TTWA.

The BCA should review their approach to maintaining records of and publishing SoCG and meetings, in order to suitably evidence compliance with DtC at examination of the Local Plan.

The BCAs should also consider a recent review of the Birmingham HMA shortfall which suggested the level of unmet need was much higher up to 2031 than has been set out by the LPAs. The BCAs should consider that the positon of the GBHMA unmet need from 2031 upto the end of the plan period in 2039 is unknown. The level of unmet need across the GBBCHMA impacts the Black Country as it has the potential to reduce the amount of additional housing need that can be met and attributed to the Black Country.