Draft Black Country Plan

Comment

Representation ID: 23459

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

I am writing to you on behalf of my client Hallam Land Management, a company which has
an established track record in working with local authorities and partners to promote land
for both housing, industrial, commercial and mixed-use development all over the country.
They take a positive approach towards promoting land through the planning process,
including bringing forward land through local plans to ensure that homes and jobs are
delivered for the benefit of local communities and for the wider economy.
Their interests are not specifically within the Black Country area, but on two strategic sites -
one at Sandy Lane in Codsall (South Staffordshire DC) within a few miles of the Black Country
boundary. This site forms a logical extension to the village next to a recently completed
former safeguarded site. The other is on the urban edge of Telford beyond the green belt
(Telford & Wrekin BC) and represents a sustainable urban extension to the town. Both of
these sites offer sensible alternatives to developing ‘green belt’ land in the Black Country.
Black Country Local Plan opportunities & challenges.
Hallam Land Management submitted representations to the Issues and Options stage of the
Black Country Plan in September 2017 and this Regulation 18 Draft Plan has now emerged in
late 2021. We worry that the draft Black Country Local Plan (BCP) has taken 4 years to
deliver and that the plan-led process is proceeding at such a ‘glacial’ pace – both in the Black
Country and in surrounding authorities.
Nevertheless, we welcome the Black Country Local Plan (consultation draft) which
represents an important step in the planning of the wider West Midlands Metropolitan subregion.
It has a critical bearing on the surrounding local authorities including South
Staffordshire and Telford & Wrekin with whom the Black Country authorities are
accustomed to working closely as a means of delivering their wider housing needs.

Duty to Co-operate
We very much welcome the clear strategy within the BCP to work with neighbouring
authorities and to provide certainty and transparency to residents, businesses and
developers for a Local Plan up to 2039. However, the absence of a strategic planning tier
presents some critical challenges in terms of:
1. The difficulty of planning across administrative boundaries and co-ordinating
infrastructure, housing and employment which are better planned on a wider scale,
2. Problems created by neighbouring authorities planning to different time-horizons
and at different times with no natural integration between them,
3. The difficulties of involving the private sector in the ongoing cross boundary
discussions between authorities through the so-called ‘duty to Co-operate’.
According to the guidance on Duty to Co-operate, negotiations between authorities need to
be constructive, active and ongoing. As a replacement for the former strategic planning
process, the Duty to Co-operate process is less than ideal. It is largely opaque and limited in
scope. However, it is an essential element of the plan-led process if Councils are to engage
and negotiate in a meaningful way and overall housing needs in a wider area are to be met
which is necessary to render the emerging Local Plan ‘sound’.
Currently, the situation on the Duty to Co-operate between the Black Country and other
local authorities is by no means clear, as outlined within the supporting evidence. The Black
Country Councils undertake within paragraph 1.10 of the Draft BCP that there will be
Statements of Common Ground in the Deposit version of the Local Plan. But so far, all the
letters from neighbouring authorities contained within the BCP evidence base are around 3
years old – mostly written in mid-2018 and so are somewhat dated. However, they do give a
flavour of the respective Councils’ stances in relation to addressing the Black Country’s
growing housing shortfall.
Telford & Wrekin: By way of example, the letter from Telford and Wrekin BC is dated 26th
July 2018 (over 3 years ago) just after the adoption of the Telford & Wrekin Plan (in January
2018). Telford & Wrekin Council had resisted attempts by the Black Country authorities to
accept the dispersal of some of its housing needs to Telford during the T & W Local Plan
Inquiry, despite its past role as a New Town accepting outflow from the Black Country
authorities. The letter written subsequent to the Local Plan adoption states, inter alia, that:
The matter of Telford & Wrekin accommodating unmet need from Birmingham and the Black
Country was discussed at the Examination in Public for the Telford & Wrekin Local Plan (Local
Plan). The Local Plan Inspector found there to be no evidence to convince him at that point
that Telford & Wrekin should accommodate the unmet housing needs of your authorities.
The Council has, however, committed to monitoring this matter in light of emerging
evidence. Your letter does not provide the Council with any further evidence to support a case
for Telford & Wrekin to contribute to meeting your unmet housing need. The Urban Capacity
Study referenced identifies a raft of evidence work to be undertaken this year.
The letter from T & W goes on to suggest: ‘In reference to your request that the Council
consider its position regarding meeting some of the Black Country’s unmet housing need, in
order to consider this, we’d need more specific proposals and evidence regarding the
quantum and type of development you are seeking Telford & Wrekin to accommodate as
well as your strategy for meeting unmet need. In addition to this we would need a clear indication as to how the necessary supporting infrastructure to facilitate ourselves
accommodating unmet need, were this to be agreed, would be enabled and resourced’.
This might have been the position in 2018, however since then, a more substantial shortfall
in housing land capacity has been identified within the Black Country (evidenced in your
current work). Furthermore, the situation with regard to Telford & Wrekin is somewhat
different. In Issues and Options stage of the emerging Telford & Wrekin Local Plan Review
the authority recognised that there were pressures to accept in-migration from the Black
Country and (had the Draft Telford & Wrekin Local Plan been issued in May 2021 as
expected) we would have expected this to have been acknowledged and quantified.
We would therefore expect the Black Country Councils to have a constructive dialogue with
Telford & Wrekin BC, so that Telford & Wrekin (which has potential development land
outside the green belt, including our site at Wappenshall which is suitable for a large
Sustainable Urban Extension), can assist the Black Country in addressing its housing shortfall.
We have not yet seen evidence of any further dialogue – but expect it to appear in the
evidence base at the Pre-submission (Reg 19) stage.
South Staffordshire: The picture in South Staffordshire is much more optimistic. Their letter
dated 23rd August 2018 (again 3 years ago) explains that their Site Allocations Document
(SAD) published in 2017 did allocate 1,000 dwellings for the needs of the Black Country and
more important their subsequent emerging South Staffs Local Plan Review has earmarked
some 4,000 dwellings for the wider needs of the Black Country.
The 2018 letter also states, very positively, that; ‘South Staffordshire Council is clear on its
obligations to work constructively and positively with our Black Country neighbours on a
range of key issues, not least on meeting housing and employment needs. Likewise the Black
Country Authorities will also play an important role in helping to meet some of our needs too
and we look forward to continuing our ongoing co-operation and delivery with you’.
With that in mind it is important to emphasise that Hallam Land Management has a suitable
and sustainable site on the northern edge of Codsall within easy reach of Wolverhampton
which is surrounded on three sides by development and lies immediately adjacent to former
safeguarded land which has since been developed by Taylor Wimpey, (now fully completed).
Shropshire, on the other hand undertook a Strategic Sites Review in 2017, which, inter alia,
explored a major site at Junction 3 of the M54. They emphasised in their undated 2018
emailed Duty to Co-operate response that they were undertaking a review of opportunities
along the M54 corridor as part of a study by consultants, GVA, and would consider working
with the Black Country despite it falling within a different HMA. In practice however,
Shropshire Council subsequently decided not to support a major new settlement at Junction
3 of the M54 – although they have promoted an employment growth point at RAF Cosford
nearby. There is no prospect therefore that Shropshire will accommodate a major
proportion of the Black Country’s housing overspill but might allocate some land close-by.
Other authorities: According to the 2018 Duty to Co-operate letters, none of the other
authorities in the West Midlands region have expressed a willingness to provide for the
Black Country’s needs. Birmingham City Council has a capacity problem of its own (and now
needs to allocate a further 35% ‘bonus’ on top of its previous allocation, despite the
apparent reduction in its pressure for overspill). Other Council’s in the Birmingham & Black
Country Housing Market area – such as Cannock Chase, Lichfield, Bromsgrove and Solihull have all expressed concerns about problems of their own – many of them in helping to
alleviate Birmingham and the Black Country’s capacity shortfall. Other authorities are
further afield and have no functional relationship and hence have urged the Black Country to
review its own green belt before seeking to share its overspill with them. This is something
that your authority has now done as part of the draft BCP.
In summary therefore, the only two authorities which stand out as having the capacity or
the willingness to contribute to the Black Country’s surplus housing needs are South
Staffordshire DC and Telford & Wrekin BC – with the possibility of some assistance from
Shropshire Council (albeit their Local Plan shows few allocations close to the Black Country
boundary). The Hallam Land Management sites at Codsall and Wappenshall (Telford)
therefore provide a key opportunity to help address the Black Country’s long-term needs.
There has been a long history of engagement between the GB&BCHMA authorities (and
between the public and the private sector stakeholders) prior to the abolition of regional
and strategic planning in 2011. But to date, there has been no conclusive strategic crossboundary
distribution of unmet housing needs from Birmingham and the Black Country
Authorities. This creates huge uncertainty for both the local authorities, the private sector
and for local people and is not a sound basis for decision making.
The complex network of relationships between 10-15 authorities within the surrounding the
West Midlands Metropolitan Area creates a potential network of 100-150 communications
between respective authorities all sent at different times and completely uncoordinated.
This is a grossly inefficient means of engaging in debate and establishing consensus. We feel
negotiation between authorities should be replaced by a Standing Conference of Local
Authorities, open to private sector interests who have much to contribute.
We would therefore firmly support the HBF in arguing that the GB&BC HMA authorities
should prepare a Joint Statement of Common Ground in conjunction with the private sector
interests (through a joint planning conference) which would explore, in a systematic way,
the need for strategic housing provision across Birmingham and the Black Country to ensure
that housing needs across the sub-region are properly planned and adequately met.
Housing Needs in the Black Country – Policy CSP1.
The Black Country area (including Dudley, Sandwell, Walsall and Wolverhampton forms an
integral part of Greater Birmingham & Black Country Housing Market Area (GB&BCHMA).
Both Birmingham City Council and the Black Country Authorities have long had unmet
housing needs but the situation is somewhat fluid as circumstances change over time.
In January 2017 the adopted Birmingham Development Plan identified a housing shortfall of
37,900 dwellings which was expected to be met from contributions by surrounding
authorities (including possibly the Black Country). The Birmingham Local Plan Inspector
imposed a 3 year deadline within which Local Plans were meant to come forward to address
the shortfall otherwise Birmingham would be thrown into a further Local Plan review.
Since then, Birmingham City Council has re-assessed it shortfall and recalculated the housing
output from for example, completions, plots under construction, windfalls, additional sites
within the City Centre and assumptions on new development on the Commonwealth Games
site at Perry Barr. A Joint Local Authority Position Statement on the GBBCHMA – dated July
2020 claims that the housing shortfall at that time had reduced to only 2,597 dwellings based on the GL Hearn Strategic Growth Study (February 2018) baseline figure of 207,979
dwellings needed to 2031. This is clearly a sharp reduction on the shortfall expressed in the
GL Hearn Strategic Growth Study (2018) of 28,000 dwellings and has not yet been tested.
In addition, the Strategic Growth Study (2018) looked forward to 2036 and identified a
minimum baseline figure of almost 61,000 dwellings and hence this will add to both the
Birmingham and the Black County requirement – which looks further forward to 2039.
Currently (as I write) the Solihull Local Plan Inquiry is considering these figures (alongside
other assessments of housing shortfall from the private sector) as part of the parallel debate
about Solihull’s true housing requirements and hence – in the absence of any agreed figures
(or a strategic planning input) decisions about the overall shortfall will be made by the
Solihull Inspectors which could have a wider bearing on the Black Country Local Plan.
The situation in the Black Country creates a further shortfall. The Draft BCP states that the
capacity of the Black Country is finite and not all of the Black Country’s housing needs will be
met within its own administrative boundaries (see para 3.20). The Draft BCP sets a housing
target for the Black Country of 47,837 dwellings over the plan period 2020 – 2039 or 2,518
dwellings per annum against a minimum Local Housing Need of 76,076 dwellings (see para
3.21 & Policy CSP1).
Measuring the housing requirement against the Local Housing Need (LHN) from the
government’s Standard Methodology the combined figures produce a minimum LHN of
76,361 dwellings (or 4019 per year) between 2020-2039, which according to paragraph 60 of
the NPPF are intended to be regarded as a minimum. This comprises:
12,084 new homes in Dudley (636 per year)28,272 new homes in Sandwell (1,488 per year)
16,758 new homes in Walsall (882 per year)
19,247 new homes in Wolverhampton (1,103 per year) – including a 35% uplift.
76,361 new homes for Black Country area.
The Turley report comments that despite the challenge of meeting potentially 76,361 new
homes in the Black Country, the resultant figures from the Standard Method are not
especially high in terms of growth in relation to existing stock. Indeed, despite the City of
Wolverhampton receiving a 35% uplift, as one of the country’s 20 largest cities, its ultimate
target is relatively modest and it is only the tight administrative boundaries which make it
difficult to meet its expected contribution towards a nationwide need for housing. The
adjacent authority of South Staffordshire – and especially Codsall which borders
Wolverhampton, provides a valuable opportunity to provide new housing very close by.
Housing Shortfall in the Black Country.
As a result of the foregoing analysis, Table 2 of the Black Country Development Strategy
2020 – 2039 expects a housing shortfall of 28,239 dwellings to be exported to other
authorities through the operation of the Duty to Co-operate. This ignores any shortfall from
the wider Greater Birmingham area. As I indicate above, currently there are no firm
commitments from other authorities to accommodate this shortfall despite all authorities
within the GBBCHMA having been asked to contribute (as indicated within the Duty to Cooperate
section.

Furthermore, as we indicate above, there is an outstanding shortfall from the Birmingham
Housing Needs Assessment which could lie somewhere between 2,597 dwellings (the
number declared in the joint position statement and 28,0000 highlighted in the GL Hearn
report to 2031 – or indeed higher). This would be in addition to the shortfall of 28,239
dwellings now evident in the Black Country which creates an overall shortfall of up to
50,000-60,000 dwellings in the GBBCHMA.
However, Turley’s previous report ‘Falling Short – Taking stock of unmet needs across the
Greater Birmingham and Black Country Housing Market Area’ published in August 2021
identified a housing shortfall across the Greater Birmingham and Black Country Housing
Market Area (GBBCHMA) of between 68,700 and 78,000 homes up to 2040. This tends to
suggest that the acknowledged shortfall of 28,239 represents a serious under-estimate.
As I have described above, there are only two local authorities – Telford & Wrekin BC and
South Staffordshire DC – within the wider Housing Market Area who have expressed any
willingness or indeed have the capacity to absorb any major overspill – with the possibly
addition of Shropshire Council who are now well advanced in their own plan and have
rejected proposals for development at Junction 3 (M54) within the green belt. However,
this does not necessarily represent the full shortfall. Private sector interests co-ordinated by
planning consultants Turley, have undertaken further research which looks at the pressures
for development in and around the Birmingham and Black Country HMA.
Housing Land Supply.
The achievement of the net provision of 47,837 dwellings over the plan period 2020 – 2039
or 2,518 dwellings per annum, relies entirely on achieving and delivering sufficient readily
available land to build enough homes – and that those homes will be viable to build and will
appeal to the market (or tenants) and hence will be delivered and occupied. Any significant
shortfall will result in further overspill to adjacent areas -added to the 28,239 dwellings
which are estimated to be required elsewhere to satisfy the Black Country’s housing needs.
A separate exercise by consultants, Turley, submitted on behalf of a number of housebuilders,
highlights the very high reliance on brownfield land (85%) and estimates that some
10,000 plots which are included in the Councils’ Black Country Local Plan may not be
achieved for a variety of reasons. This likely shortfall is also picked up in the HBF’s response
where they identify many sites within the Strategic Centres as being unviable, based on the
Councils’ own ‘Black Country Viability and Delivery Study’. The Turley report comments that
many existing housing allocations especially those on established employment land have not
been delivered and the decision to simply roll these forward presents a high-risk approach in
terms of achieving delivery. They calculate the need for firstly, reductions to commitments (-
695 homes), secondly, existing allocations (-4,973 homes), thirdly, occupied employment
land (-3,091 homes) and finally upper floor conversions in Wolverhampton (-812 homes),
equating to 9,571 dwellings in all.
There is also concern within the HBF response that high levels of affordable housing
(including what could be onerous requirements for First Homes, rented housing and
Accessibility housing) and also high densities and pressures from Biodiversity requirements –
important though they are – may frustrate the ability of developers to deliver the scale of
housing within the Black Country. They also note that the figures provided provide little
flexibility in numbers so that all virtually all the housing land provision identified will need to
be built to achieve the Councils’ targets with little or no room for flexibility.

The impact on the Black Country’s Green Belt.
The Black Country Green belt is unusual insofar as it comprises a network of green wedges
which separate induvial settlements within the Black Country communities. Unlike the
London Metropolitan or Birmingham Green Belts it does not simply surround the
conurbation.
The BCP makes the controversial proposal to remove areas of green belt to provide room for
some 7,720 dwellings across the Black Country. This comprises land for:
1,117 homes in Dudley,
171 homes in Sandwell,
5,418 homes in Walsall, and
1,103 homes in Wolverhampton
Understandably, these proposals have proved unpopular with local people and with local
politicians to the point where public statements have been made challenging the loss of
green belt and it is doubtful whether the Black Country Local Plan will ultimately receive
members’ support. The West Midlands Mayor (who doesn’t have strategic planning powers)
but does seem to have a wider influence, has also declared himself resistant to green belt
development within the boundaries of the conurbation.
Under Paragraph 140 of the NPPF Government guidance stresses that ‘green belt boundaries
can only be altered where exceptional circumstances are fully evidenced and justified,
through the preparation or updating of plans. Strategic policies should establish the need for
any changes to green belt boundaries…’
Whilst in circumstances such as these it is likely to be feasible to meet the criteria for some
green belt releases through the Local Plan process, but it is important to recognise that
paragraph 141 stresses that ‘Before concluding that exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to
demonstrate that it has examined fully all other reasonable options for meeting its identified
need for development. This will be assessed through the examination of its strategic policies’.
In this particular case, it is important to note that other opportunities to develop beyond the
green belt in and around Telford do exist without affecting green belt land in the Black
Country. Indeed, in years gone by, Telford New Town served as a formal overspill function
and provided just such a ‘safety valve’ to enable people to move elsewhere in the sub-region
to enjoy new opportunities, whilst not encroaching on the West Midlands green belt.
(Those formal overspill arrangements have long since expired, but the new town of Telford
has still not reached its original target population of 225,000 and yet still enjoys the benefit
of extensive infrastructure provided by the Exchequer to service the overspill population).
Furthermore, arguably, in a post-covid world, the Black Country now badly needs to protect
its landscape, environmental and ecological assets (as well as its recreational green space)
rather than gradually encroaching on its green belt and filling in the network of gaps
between established settlements which makes the Black Country so unique. At the same
time, it is entirely feasible that many people may relish the prospect of moving to a new
sustainable waterside development in Telford – against the background where many people
now appreciate the value of better space standards and greater open space which a new site
at Telford – or indeed at Codsall can offer. These opportunities need to be explored.

Summary and Conclusions.
The Black Country Local Plan (BCP) has been deposited for public consultation under
Regulation 18. It provides for 47,837 dwellings (or 2,518 new homes per year), some 29,239
short of the estimated requirement for 76.361 dwellings (or 4,019 per annum). It is assumed
(but it cannot be guaranteed) that the residual will be deflected to other local authorities.
In addition, there is a considerable housing shortfall in neighbouring Birmingham City
ranging from around 2,600 dwellings (as now anticipated by the West Midlands authorities)
up to 2031 to some 28,000 estimated by Turley (plus a further shortfall to 2039.
The Turley study further estimates that the scale of housing supply may have been overestimated
by up to 10,000 dwellings attributed to a change in the non-implementation
allowance from 10% to 5%, a reliance on existing allocations which have failed to come
forward, an over-dependency on changes of use from employment sites and a possible
double-count from dwellings provided on Wolverhampton upper floors with windfalls. The
Black Country Authorities have already identified land for some 7,720 dwellings from green
belt land which is proving very controversial.
In total, based on the analysis above, there is likely to be an overspill of between 30,000 and
40,000 surplus plots to find elsewhere, with the expectation that an additional 3,000 –
30,000 will need to be found elsewhere in the Birmingham and Black Country housing
market to cater for Birmingham’s longer-term needs.
From the published letters received in response to the Duty to Co-operate exercise in 2018,
few neighbouring authorities have volunteered to assist the Black Country Councils. The
only willing authorities so far are potentially Telford and Wrekin BC and South Staffordshire
DC – with the possibility of some limited overspill to Shropshire Council within the already
proposed allocations bordering the Black Country and possibly along the M54 corridor, but
they too would be in the green belt.
Hallam Land Management has two strategic sites;
Firstly, a greenfield site with a potential capacity of up to 2.500 dwellings at Wappenshall on
the northern edge of Telford (not within the green belt) which would provide a sustainable
mixed use urban extension, linked to a proposed employment site on Homes England land,
Secondly, a smaller green belt site (adjacent to a former safeguarded site now released from
the green belt and developed) on the northern edge of Codsall in South Staffordshire DC,
Either or both of these sites would provide admirable opportunities for future development
to offset development displaced from the Black Country.
Whilst this may not require a specific amendment to the Black Country Plan, it can serve as
valuable evidence to the Black Country authorities in their negotiation with the two
authorities during the Duty to Co-operate process.

Comment

Representation ID: 23460

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

Housing Needs in the Black Country – Policy CSP1.
The Black Country area (including Dudley, Sandwell, Walsall and Wolverhampton forms an
integral part of Greater Birmingham & Black Country Housing Market Area (GB&BCHMA).
Both Birmingham City Council and the Black Country Authorities have long had unmet
housing needs but the situation is somewhat fluid as circumstances change over time.
In January 2017 the adopted Birmingham Development Plan identified a housing shortfall of
37,900 dwellings which was expected to be met from contributions by surrounding
authorities (including possibly the Black Country). The Birmingham Local Plan Inspector
imposed a 3 year deadline within which Local Plans were meant to come forward to address
the shortfall otherwise Birmingham would be thrown into a further Local Plan review.
Since then, Birmingham City Council has re-assessed it shortfall and recalculated the housing
output from for example, completions, plots under construction, windfalls, additional sites
within the City Centre and assumptions on new development on the Commonwealth Games
site at Perry Barr. A Joint Local Authority Position Statement on the GBBCHMA – dated July
2020 claims that the housing shortfall at that time had reduced to only 2,597 dwellings based on the GL Hearn Strategic Growth Study (February 2018) baseline figure of 207,979
dwellings needed to 2031. This is clearly a sharp reduction on the shortfall expressed in the
GL Hearn Strategic Growth Study (2018) of 28,000 dwellings and has not yet been tested.
In addition, the Strategic Growth Study (2018) looked forward to 2036 and identified a
minimum baseline figure of almost 61,000 dwellings and hence this will add to both the
Birmingham and the Black County requirement – which looks further forward to 2039.
Currently (as I write) the Solihull Local Plan Inquiry is considering these figures (alongside
other assessments of housing shortfall from the private sector) as part of the parallel debate
about Solihull’s true housing requirements and hence – in the absence of any agreed figures
(or a strategic planning input) decisions about the overall shortfall will be made by the
Solihull Inspectors which could have a wider bearing on the Black Country Local Plan.
The situation in the Black Country creates a further shortfall. The Draft BCP states that the
capacity of the Black Country is finite and not all of the Black Country’s housing needs will be
met within its own administrative boundaries (see para 3.20). The Draft BCP sets a housing
target for the Black Country of 47,837 dwellings over the plan period 2020 – 2039 or 2,518
dwellings per annum against a minimum Local Housing Need of 76,076 dwellings (see para
3.21 & Policy CSP1).
Measuring the housing requirement against the Local Housing Need (LHN) from the
government’s Standard Methodology the combined figures produce a minimum LHN of
76,361 dwellings (or 4019 per year) between 2020-2039, which according to paragraph 60 of
the NPPF are intended to be regarded as a minimum. This comprises:
12,084 new homes in Dudley (636 per year)28,272 new homes in Sandwell (1,488 per year)
16,758 new homes in Walsall (882 per year)
19,247 new homes in Wolverhampton (1,103 per year) – including a 35% uplift.
76,361 new homes for Black Country area.
The Turley report comments that despite the challenge of meeting potentially 76,361 new
homes in the Black Country, the resultant figures from the Standard Method are not
especially high in terms of growth in relation to existing stock. Indeed, despite the City of
Wolverhampton receiving a 35% uplift, as one of the country’s 20 largest cities, its ultimate
target is relatively modest and it is only the tight administrative boundaries which make it
difficult to meet its expected contribution towards a nationwide need for housing. The
adjacent authority of South Staffordshire – and especially Codsall which borders
Wolverhampton, provides a valuable opportunity to provide new housing very close by.

Comment

Representation ID: 23461

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

Housing Shortfall in the Black Country.
As a result of the foregoing analysis, Table 2 of the Black Country Development Strategy
2020 – 2039 expects a housing shortfall of 28,239 dwellings to be exported to other
authorities through the operation of the Duty to Co-operate. This ignores any shortfall from
the wider Greater Birmingham area. As I indicate above, currently there are no firm
commitments from other authorities to accommodate this shortfall despite all authorities
within the GBBCHMA having been asked to contribute (as indicated within the Duty to Cooperate
section. Furthermore, as we indicate above, there is an outstanding shortfall from the Birmingham
Housing Needs Assessment which could lie somewhere between 2,597 dwellings (the
number declared in the joint position statement and 28,0000 highlighted in the GL Hearn
report to 2031 – or indeed higher). This would be in addition to the shortfall of 28,239
dwellings now evident in the Black Country which creates an overall shortfall of up to
50,000-60,000 dwellings in the GBBCHMA.
However, Turley’s previous report ‘Falling Short – Taking stock of unmet needs across the
Greater Birmingham and Black Country Housing Market Area’ published in August 2021
identified a housing shortfall across the Greater Birmingham and Black Country Housing
Market Area (GBBCHMA) of between 68,700 and 78,000 homes up to 2040. This tends to
suggest that the acknowledged shortfall of 28,239 represents a serious under-estimate.
As I have described above, there are only two local authorities – Telford & Wrekin BC and
South Staffordshire DC – within the wider Housing Market Area who have expressed any
willingness or indeed have the capacity to absorb any major overspill – with the possibly
addition of Shropshire Council who are now well advanced in their own plan and have
rejected proposals for development at Junction 3 (M54) within the green belt. However,
this does not necessarily represent the full shortfall. Private sector interests co-ordinated by
planning consultants Turley, have undertaken further research which looks at the pressures
for development in and around the Birmingham and Black Country HMA.
Housing Land Supply.
The achievement of the net provision of 47,837 dwellings over the plan period 2020 – 2039
or 2,518 dwellings per annum, relies entirely on achieving and delivering sufficient readily
available land to build enough homes – and that those homes will be viable to build and will
appeal to the market (or tenants) and hence will be delivered and occupied. Any significant
shortfall will result in further overspill to adjacent areas -added to the 28,239 dwellings
which are estimated to be required elsewhere to satisfy the Black Country’s housing needs.
A separate exercise by consultants, Turley, submitted on behalf of a number of housebuilders,
highlights the very high reliance on brownfield land (85%) and estimates that some
10,000 plots which are included in the Councils’ Black Country Local Plan may not be
achieved for a variety of reasons. This likely shortfall is also picked up in the HBF’s response
where they identify many sites within the Strategic Centres as being unviable, based on the
Councils’ own ‘Black Country Viability and Delivery Study’. The Turley report comments that
many existing housing allocations especially those on established employment land have not
been delivered and the decision to simply roll these forward presents a high-risk approach in
terms of achieving delivery. They calculate the need for firstly, reductions to commitments (-
695 homes), secondly, existing allocations (-4,973 homes), thirdly, occupied employment
land (-3,091 homes) and finally upper floor conversions in Wolverhampton (-812 homes),
equating to 9,571 dwellings in all.
There is also concern within the HBF response that high levels of affordable housing
(including what could be onerous requirements for First Homes, rented housing and
Accessibility housing) and also high densities and pressures from Biodiversity requirements –
important though they are – may frustrate the ability of developers to deliver the scale of
housing within the Black Country. They also note that the figures provided provide little
flexibility in numbers so that all virtually all the housing land provision identified will need to
be built to achieve the Councils’ targets with little or no room for flexibility.

Comment

Representation ID: 23462

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

The impact on the Black Country’s Green Belt.
The Black Country Green belt is unusual insofar as it comprises a network of green wedges
which separate induvial settlements within the Black Country communities. Unlike the
London Metropolitan or Birmingham Green Belts it does not simply surround the
conurbation.
The BCP makes the controversial proposal to remove areas of green belt to provide room for
some 7,720 dwellings across the Black Country. This comprises land for:
1,117 homes in Dudley,
171 homes in Sandwell,
5,418 homes in Walsall, and
1,103 homes in Wolverhampton
Understandably, these proposals have proved unpopular with local people and with local
politicians to the point where public statements have been made challenging the loss of
green belt and it is doubtful whether the Black Country Local Plan will ultimately receive
members’ support. The West Midlands Mayor (who doesn’t have strategic planning powers)
but does seem to have a wider influence, has also declared himself resistant to green belt
development within the boundaries of the conurbation.
Under Paragraph 140 of the NPPF Government guidance stresses that ‘green belt boundaries
can only be altered where exceptional circumstances are fully evidenced and justified,
through the preparation or updating of plans. Strategic policies should establish the need for
any changes to green belt boundaries…’
Whilst in circumstances such as these it is likely to be feasible to meet the criteria for some
green belt releases through the Local Plan process, but it is important to recognise that
paragraph 141 stresses that ‘Before concluding that exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to
demonstrate that it has examined fully all other reasonable options for meeting its identified
need for development. This will be assessed through the examination of its strategic policies’.
In this particular case, it is important to note that other opportunities to develop beyond the
green belt in and around Telford do exist without affecting green belt land in the Black
Country. Indeed, in years gone by, Telford New Town served as a formal overspill function
and provided just such a ‘safety valve’ to enable people to move elsewhere in the sub-region
to enjoy new opportunities, whilst not encroaching on the West Midlands green belt.
(Those formal overspill arrangements have long since expired, but the new town of Telford
has still not reached its original target population of 225,000 and yet still enjoys the benefit
of extensive infrastructure provided by the Exchequer to service the overspill population).
Furthermore, arguably, in a post-covid world, the Black Country now badly needs to protect
its landscape, environmental and ecological assets (as well as its recreational green space)
rather than gradually encroaching on its green belt and filling in the network of gaps
between established settlements which makes the Black Country so unique. At the same
time, it is entirely feasible that many people may relish the prospect of moving to a new
sustainable waterside development in Telford – against the background where many people
now appreciate the value of better space standards and greater open space which a new site
at Telford – or indeed at Codsall can offer. These opportunities need to be explored.