Draft Black Country Plan

Support

Representation ID: 44891

Received: 11/10/2021

Respondent: Gladman Developments Ltd.

Gladman welcomes the review of the Black Country Plan to cover the period to 2039 and the intention to meet housing needs and attract new businesses as an integral component of the Plan’s Spatial Vision, Strategic Objectives and Strategic Priorities. Strategic Priority 3: to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents is of fundamental strategic importance and is central to the preparation of a sound Local Plan.

Comment

Representation ID: 44893

Received: 11/10/2021

Respondent: Gladman Developments Ltd.

Policy CSP1 and the associated supporting text describes the proposed development strategy for the Black Country over the period 2020 to 2039. Policy HOU1 – Delivering Sustainable Housing Growth also sets the context for the delivery of new homes over the plan period.
It is noted that the councils have updated their evidence base during 2021 to provide The Black Country Housing Market Assessment, March 2021 and the Black Country Urban Capacity Review Update, May 2021. This provides baseline evidence on the overall housing need and the extent to which these needs can be met within the urban area. Gladman welcomes the intention of the councils to periodically update the Urban Capacity Review (the next being in 2022) and see this as an essential element in making a realistic assessment of the capacity of the area to accommodate the level of housing and employment that is needed over the period to 2039.
The Plan intends to deliver at least 47,837 net new homes over the plan period and 355ha of employment land. The housing requirement equates to 2,517 dwellings per annum. The supporting text recognises that the capacity of the Black Country to accommodate development is finite and acknowledges that it will not be possible to meet development needs in full within the administrative boundaries. There is estimated to be a shortfall of 28,239 homes and 210ha of employment land against the needs identified through the evidence base of 76,076 homes and 565ha of employment land.
The Standard Method for calculating housing need in national policy produces only a “minimum” need for housing3. The PPG accepts that there will be circumstances where it is appropriate to plan for a higher housing need figure. This includes the consideration of growth strategies or strategic infrastructure investments that could drive an increase in the number of homes needed. The HMA evidently displays these characteristics and has strong economic growth ambitions, including those associated with the Midlands Engine and the country’s most significant infrastructure investment in the form of High Speed 2, alongside a range of other investments recognised within the Midlands Connect Strategy. Careful consideration will need to be given to these factors as plan making progresses across the area.
The Turley Falling Short Report (see Appendix 1), considers the wider evidence of housing need across the GBBCHMA and recommends that given the scale of the housing shortfall, a more radical approach to strategic and spatial plan-making is required to tackle the challenge of long term growth. The Report also highlights the need to revisit the ‘Position Statements’ and ‘Statements of Common Ground’ associated with development needs between neighbouring authorities as plan making across the area progresses. This will be central to the soundness of the proposed development strategy for the Black Country Plan for the period 2020 to 2039, which includes the proposed release of land from the Green Belt and to export a proportion of the development needs to authorities in the wider HMA. Where development needs are exported, it will be for the importing Local Planning Authority to determine how any such requirement can be sustainably accommodated within the context of its own spatial strategy. It is welcomed that the Black Country Authorities are committed to continued and constructive engagement, through the Duty to Co-operate, with their neighbours to secure the most appropriate and sustainable locations for housing and employment growth to meet Black Country needs over the plan period. Gladman look forward to reviewing any associated documentation as the plan making process advances.

Comment

Representation ID: 44896

Received: 11/10/2021

Respondent: Gladman Developments Ltd.

Executive Summary
Turley is instructed by a Consortium of housebuilders and land promoters to take stock of the position relating to housing need and land supply across the Greater Birmingham and Black Country Housing Market Area (“GBBCHMA”) (“HMA”) in order to quantify the true scale of unmet need to 2031, and beyond.
In September 2020, the 14 local authorities1 which make up the GBBCHMA published their third “Position Statement”2 (“3PS”) on the HMA’s housing need and land supply to identify the unmet need. The headline conclusion was that “the 2011-31 shortfall is now estimated to be 2,597 [dwellings]”.
The 3PS comprises the up-to-date agreed position of the 14 local authorities on this important strategic and cross-boundary issue and it is now being relied upon as robust evidence by local authorities in plan-making. The authorities anticipate it forming the “… starting point from which future Statements of Common Ground … can develop” and this process is already underway.
Turley has undertaken independent analysis of the 3PS and sets out recommendations for the 14 local authorities in terms of ensuring the unmet housing need is determined through the collation of clear evidence on need and supply, kept under regular review and, most importantly, ensuring ongoing collaboration so that the unmet need is effectively planned for, and delivered, through emerging local plans.
Background to the evolving need
Since regional planning was revoked in 2010, there has been an evolving position in terms of evidence on the HMA’s unmet housing need, which has resulted in a “moving target” for local plans. The 2015 SHNS initially established an unmet need of 37,600 dwellings between 2011 and 2031, and this evidence was endorsed during the BDP examination, with Birmingham’s own shortfall confirmed as 37,900 homes (2017) (to 2031). There has been limited progress over the past four years in terms of local plans being advanced to submission, examination and / or adoption which offer contributions to either the City’s shortfall or the HMA shortfall. In broad terms, the combined contribution from submitted / examined / adopted local plans is in the order of c.8,600 dwellings, which obviously falls well short of either the HMA and/ or Birmingham City unmet need. If the City’s claimed supply in the 3PS was delivered, the shortfall would still stand at c.15,000 dwellings.
In 2018, the SGS updated the Strategic Housing Needs Study, identifying:
• A need for between 205,000 and 246,000 homes across the HMA to 2031; and between
256,000 and 310,000 homes to 2036.
• A supply of 180,000 dwellings to 2031 and
198,000 dwellings to 2036. Helpfully, this supply was independently assessed to arrive at a consistent position.
• A baseline and minimum unmet need of 28,000 dwellings to 2031 and 61,000 dwellings to 2036. However, the shortfalls against the “Economy Plus” scenarios would be far greater; 69,000 dwellings to 2031 and 116,000 dwellings to 2036.
More recently, the HMA authorities have published position statements to support local plan reviews. These focus purely on the minimum need position to 2031, disregarding the need to 2036, and ignoring the SGS’ “Economy Plus” need projection.
Land Supply Position Statement (July 2020)
The second PS (2018) claimed an increased housing supply at 2017 resulting in a minimum unmet need of 11,000 dwellings to 2031. However, the supply was “unadjusted” as it did not adopt the SGS’ approach to non-implementation discount rates. Moreover, the supply data was not made accessible and has not been tested or examined.
The 3PS was published in September 2020 and now forms the up-to-date and agreed position between the 14 authorities. It “estimates” the unmet need to 2031 has diminished to just 2,597 dwellings. This is clearly a huge reduction on the unmet need figures identified through the 2015 and 2018 need studies, as well as the shortfall figure established in the BDP (2017).
The impact of 3PS
The 3PS comprises the up-to-date agreed position of the 14 local authorities on the critical cross-boundary issue of strategic housing need. It paints a picture of significant local plan progress across the HMA which is misleading given only a handful of plans have reached submission, examination or adoption since the shortfall was identified in the BDP (2017) and SGS (2018).
The 3PS is now being relied upon by several local authorities as robust evidence to underpin their emerging local plans, many of which have interpreted it as confirming that the unmet need to 2031 has effectively been resolved. In Lichfield’s case, they have significantly reduced their HMA contribution to 2040.
We have significant concerns in respect to the soundness of the 3PS:
• It only covers 2011 to 2031 when local plan reviews are working well beyond this date (post-2040 in several cases). This is short sighted, especially when the SGS covered the period to 2036, and does not assist local authorities in planning for long-term strategic housing needs, as demonstrated in Solihull (where several HMA local authorities have objected to its proposed contribution).
• It only considers the minimum need from the SGS, and does not reflect the standard method. It totally disregards the “Economy Plus” scenario from the SGS which indicates a far greater need to 2031 and 2036.
• The supply data is “unadjusted” unlike the data presented in the SGS, in terms of not being independently reviewed and with some authorities not applying any form of non-implementation discount. Furthermore, the raw data has not been made readily accessible alongside the 3PS so it is difficult to scrutinise and it has yet to be properly tested through a local plan examination.
The scale of need to 2031 (and beyond)
The 3PS cites the SGS baseline scenario in describing a minimum need for 205,099 homes between 2011 and 2031, but this takes no account of the standard method which can be reasonably incorporated for the latter half of this period to suggest a greater need for at least 221,230 homes.
This increases to at least 238,519 homes when allowing for the removal of Birmingham’s cap in 2022, with this resultant level of need approaching that of the “Economy Plus” scenario presented in the SGS (245,545). The level of need suggested by this scenario increases to some 310,188 homes when extended to 2036, remaining slightly higher than implied over the same period by our approach that incorporates the standard method (307,464).
This latter approach can also be extended to 2040 on the same basis, which indicates an overall need for 362,620 homes between 2011 and 2040.
These results are presented in the table below and revisited in Section 6 when calculating the unmet need:
Table 1: Estimates of housing need across the HMA
Analysis of supply in 3PS
Our high-level analysis of the 3PS’ supply data suggests that the claimed supply is over optimistic. We have identified the following specific items which warrant reductions in the supply position:
• 1,089 dwellings should be deducted from Birmingham’s “allocations – adopted Plans” component as the available evidence suggests Langley is unlikely to deliver homes pre-2031.
• At least 400 dwellings should be deducted from Stratford’s “allocations” component to reflect the uncertainties associated with the long-term delivery of LMA given it is beholden upon construction of the SWRR.
• Four authorities do not apply any form of discount for non-implementation which presents an inconsistent approach across the HMA and is contrary to the approach adopted in the SGS. The standard discount rates from the SGS should be applied to Birmingham, Bromsgrove, Redditch and Stratford-on-Avon (i.e. 5% for committed sites and 10% for planning permissions). When this is applied, there is a reduction of 4,728 dwellings.
Taking all of the above in to account, we consider that the HMA supply to 2031 should be reduced by at least 6,217 dwellings. This would result in a reduced supply to 2031 of 199,165 dwellings.
Bearing in mind that the raw data on supply has not all been made accessible/available and the supply remains to be tested in detail (e.g. “additional urban supply”), we consider this to be a conservative reduction (5%), but it does present a more realistic picture of supply to 2031 compared to the 3PS.
We highlight that this adjusted level of supply still significantly exceeds the baseline supply from the SGS (180,000) and even exceeds the projected supply to 2036 (198,000).
Quantifying the unmet need to 2031 (and beyond)
As shown below the various scenarios presented reveal that a significant unmet need remains across the HMA to 2031.
Figure 1: The HMA’s unmet need to 2031
The local authorities should be planning positively to deliver the standard method between 2021 and 2031 and even if Birmingham’s cap were to be retained over this period and the “best case” 3PS supply were to be delivered there would still be a
significant shortfall of at least 18,700 dwellings. A more realistic level of supply indicates that the shortfall is at least 25,000 dwellings, which
closely aligns with the SGS Baseline unmet need figure from 2018 (28,000).
With the Birmingham cap lifted from 2022, the minimum shortfall (ranging between 36,000 and 42,000) would return to the level identified in the SHNS (37,600), and becomes more aligned with the SGS “Economy Plus” shortfall. It is recognised that delivering this level of uplift over the next 10 years is likely to be major challenge for the HMA.
The 3PS fails to provide a robust evidence base on the HMA’s unmet need by relying upon the minimum baseline need from the SGS (which is now out of date) and presenting an over optimistic supply position.
The shortfall of 2,597 should not be afforded any weight in plan-making and examinations. It is paramount that the local authorities jointly prepare an accurate and up-to-date position statement to determine the accurate unmet need to at least 2031.
This should be a priority given the urgency of resolving the shortfall over the next ten years, and mindful of the time it takes to progress local plans through examination to adoption. Failing to plan for the true shortfall to 2031 immediately will simply store up the problems for housing delivery beyond 2031.
Figure 2: The HMA’s unmet beyond 2031
Looking beyond 2031, the unmet need could be between 53,000 and 64,000 homes by 2036 and in excess of 70,000 homes by 2040. The emerging local plans across the HMA must plan for this shortfall now given they are working to these time horizons (and further ahead in certain cases).
Recommendations
In response to our findings we make the following recommendations:
• Preparation of a fourth Position Statement – providing a sound assessment of HMA-wide need to at least 2031 using the standard method, set against a realistic supply position, in order to accurately quantify the unmet housing need. Our evidence clearly shows that, best case, the shortfall to 2031 is nearly 19,000 dwellings.
• A commitment to prepare further Position Statements, or HMA wide monitoring reports – to regularly update the HMA-wide position based upon updated data on supply. This will be essential for forthcoming local plan examinations.
• Following quantifying and agreeing the true unmet need to 2031, agree how it will be distributed and delivered – this can be agreed via a statement of common ground or memorandum of agreement.
• Take a more radical approach to longer term needs – a strategic plan or framework will be necessary to address longer-term growth post-2031 given the scale of the housing shortfall and the strategic planning vacuum across the region.
1. Introduction and purpose
Turley is instructed by a Consortium of housebuilders and land promoters to take stock of the position relating to housing need and land supply across the Greater Birmingham and Black Country Housing Market Area (“GBBCHMA”) (“HMA”) in order to quantify the true scale of unmet need to 2031, and beyond.
The third Position Statement (3PS)
In September 2020, the 14 local authorities5 which make up the GBBCHMA published their third “Position Statement”6 (“3PS”) on the HMA’s housing need and land supply to identify the unmet need. The headline conclusion was that “the 2011-31 shortfall is now estimated to be 2,597 [dwellings]”7 .
Image 1.1: Plan of Greater Birmingham and Black Country Housing Market Area
The 3PS comprises the up-to-date agreed position of the 14 local authorities on this important strategic and cross-boundary issue and it is now being relied upon as robust evidence by local authorities in plan-making. The authorities anticipate it forming the “… starting point from which future Statements of Common Ground … can develop”8 and this process is already underway (see Section 3 of this report).
Purpose of this report
This report provides the Consortium’s independent assessment of the overall housing need and supply position so as to identify the true scale of unmet need, focussed on the period to 2031.
The focus upon 2011 to 2031 is because this is the timeframe covered by the 3PS, as well as various other evidence base studies concerning need and supply prepared since 2013. The report does however also consider the position beyond 2031 in high-level terms, mindful that National planning Policy Framework (July 2021) (“NPPF”) paragraph 22 requires strategic policies to look ahead over a minimum of 15 year period and set a vision that looks further ahead (at least 30 years) emerging local plans are now seeking to deliver strategic growth into the late 2030s or, in several cases, beyond 2040.
The report presents the findings of
Turley’s independent analysis and sets out recommendations for the 14 local authorities in terms of ensuring the unmet housing need is determined through the collation of clear evidence on need and supply, kept under regular review and, most importantly, ensuring ongoing collaboration so that the unmet need is effectively planned for, and delivered, through emerging local plans.
It is anticipated that the report will provide helpful evidence for the 14 local authorities. The findings will be drawn upon by the Consortium to support representations to emerging local plans and the report will be presented before Planning Inspectors appointed to examine them.
The Consortium
The Consortium comprises the following housebuilders and land promoters, all of whom play a key role in the strategic planning of sustainable housing delivery across the HMA and wider West Midlands region:
• Barratt Developments Plc
• Catesby Estates Plc
• Countryside
• Gladman
• Harworth Group Plc
• HIMOR
• Redrow Homes Midlands
• Summix Developments
• Taylor Wimpey
• Vistry Group Plc
• William Davis Homes
Report structure
The report is structured as follows:
• Section 2 explains how the HMA’s unmet need has evolved since 2010.
• Section 3 summarises the 3PS.
• Section 4 assesses the scale of housing need to 2031, and beyond.
• Section 5 provides a high-level review of the
HMA supply, as presented in the 3PS.
• Section 6 draws conclusions on the scale of unmet need to 2031 and beyond.
• Section 7 draws overall conclusions and presents recommendations to ensure the HMA’s unmet need is accurately quantified and agreed, regularly reviewed and, most importantly, planned for through emerging local plans.
2. Background to the evolving unmet need
Below we provide an overview of key milestones in planning for strategic housing needs across the HMA over the last decade, following the demise of regional planning in 2010. The HMA’s unmet need over the last decade has evolved as a result of various studies and position statements, and it is important to understand recent history because this provides the context to the 3PS (which we consider in Section 3).
Strategic Housing Needs Study (2013–2015)
In 2013, the Greater Birmingham and Solihull LEP (“GBSLEP”) and Black Country authorities commissioned PBA to assess the HMA’s need and supply between 2011 and 2031, as well as to set out spatial options/scenarios to accommodate the unmet need.
It was envisaged that this evidence would inform the LEP’s “Spatial Plan for Growth” (which has never been progressed) as well as emerging local plans. This study also defined the geographical extent of the GBBCHMA.
The key conclusion was an objectively assessed minimum need for 207,100 dwellings against an estimated supply of 169,520, resulting in a shortfall of 37,600 dwellings10 (2011-2031).
Birmingham Development Plan (BDP) (2017)
PBA’s study overlapped with the submission of the BDP for examination in July 2014. The Inspector’s “Interim Findings” were published in early 2015 which endorsed the need for between 89,000 and 116,000 dwellings in the City between 2011 and 2031 (PBA’s “Stage 2” report11), but requested further work. This further work was provided by PBA12.
The Inspector’s Final Report (March 2016) concluded that the BDP was sound subject to specific modifications and endorsed the lower need figure of 89,000 dwellings over the plan period. The BDP was adopted in January 2017.
Policy PG1 states that the City’s need between 2011 and 2031 is 89,000 homes but qualifies that only 51,100 homes can be accommodated within the City boundary (although the 3PS’ supply evidence suggests that capacity in the City is now much greater – see below). The policy committed the Council to work actively through the Duty to Co-operate to ensure that provision is made elsewhere within the HMA to meet the shortfall of 37,900 homes to 2031.
The City’s shortfall forms a key milestone because it comprises the most up-to-date position on unmet housing needs across the HMA in terms of being independently examined, found sound by an Inspector and adopted in a local plan.
However, there are two reasons why the BDP shortfall figure should no longer form the principal target for emerging local plans across the HMA:
a. There have been fundamental changes to national planning policy and guidance on how housing need should be calculated in the meantime. The BDP shortfall figure was derived from evidence produced in 2014 and 2015 so is seven years old and relied upon 2012-based sub-national population projections (“SNPP”) with no uplift applied toreflect market signals. The standard method for calculating local housing need in national planning policy and guidance has since come in toforce which formalised the increasingly standard practice of applying an uplift. This generates uplifts to reflect housing affordability, as well as a requirement for the 20 largest urban areas to apply a “cities and urban centre uplift”, which in the GBBCHMA applies to Birmingham and Wolverhampton; and
b. The 37,900 figure is the City’s shortfall, as opposed to the unmet need across the whole of the HMA. As explained further below, aside from any shortfall for Birmingham there is a significant shortfall in the Black Country (including to 2031) and it is critical that the overall unmet needs across the HMA are identified and met over a consistent timeframe.
In terms of (a), it is worth noting that the City Council has recently resolved to commence a review of the BDP with the standard method being a key factor in this decision (see below). Indeed, the BDP will be five years old in January2022. The Council has therefore acknowledged that the objectively assessed housing need in the BDP is likely to be out-of-date for the remainder of the plan period to 2031.
Our recommended approach to determining the up-to-date HMA need to 2031 and beyond is set out in Section 4 and from this we quantify the scale of unmet need in Section 6.
Notwithstanding the above, it is important to summarise the progress made across the HMA in working towards meeting the City’s shortfall since 2017.
BDP shortfall review mechanism and wider contributions Policy TP48 commits the City Council to “…play an active role in promoting, and monitor progress in, the provision and delivery of the 37,900 homes required elsewhere in GBHMA to meet the shortfall in the city…”.
TP48 states that “If it becomes clear that progress is falling short of the level required, the Council will undertake a review of the reasons for this, and if this indicates that it is necessary toreassess the capacity for housing provision in Birmingham, a full or partial review of this Plan will be undertaken”.
There are three review “triggers”:
• Failure of a council to submit a local plan for examination which provides an appropriate contribution towards the City’s shortfall, within 3 years of BDP adoption; this milestone expired on 10 January 2020;
• Failure of the HMA to maintain a 5 year housing land supply (over a 3 year period); and/or
• HMA housing completions falling 10% beneath the targets in housing trajectories over any 3 year period.
Since 2017, several emerging local plans have proposed contributions to the City’s shortfall, although only two have reached “submission” stage and only one has been deemed sound (at the time of writing):
• North Warwickshire’s Local Plan was submitted in March 2018 with the Inspector’s Final Report published in July 2021. The Inspector concludes that the proposed contribution of 3,790 dwellings (10%) towards the City’s unmet needs to 2031 is sound (note that this incorporates a provision towards Tamworth’s unmet needs as well so is effectively a HMA-wide contribution); and
• Solihull’s Local Plan was submitted in May2021 with examination hearings to be held between September and December 2021. The Submission version13 proposes to contribute 2,105 dwellings to the City’s unmet need14 to 2031, with no further HMA contribution beyond this date.

Stratford-on-Avon’s Core Strategy 2011 to 2031 was adopted in advance of BDP adoption in July 2016 (before the City’s shortfall was confirmed) although the HMA authorities consider that it makes a contribution to the HMA of 2,720 dwellings.
Based upon the above, there is a combined contribution of c.8,600 dwellings towards the unmet need to 2031 in terms of examined/ submitted/adopted local plans. This would fall well short of the City’s 37,900 unmet need, equating to 23%.
It should be noted that the 3PS claims that the City’s own supply will increase to 64,400 dwellings to 2031; an increase of 14,300 over the BDP housing requirement. When this is combined with the above contributions the BDP shortfall would reduce to c.15,000 dwellings.
Other emerging local plans are proposing contributions to the HMA shortfall including Cannock Chase, Lichfield and South Staffordshire but these are yet to be submitted for examination and it remains to be seen if these contributions are City-specific or HMA-wide(e.g. the Black Country shortfall).
Despite the lack of progress since 2017 in terms of local plan contributions to the shortfall being submitted, examined and adopted, up until 2020 Birmingham City Council considered that none of the “indicators” in TP48 were engaged to trigger a review of the BDP (stated through various Annual Monitoring Reports). In terms of the indicators we are not aware that a HMA- wide 5 year housing land supply exercise has ever been undertaken.
However, on 29 June 2021 the City Council’s Cabinet resolved to review the BDP as a result of significant changes in circumstances, including the Standard Method “uplift” for the top 20 cities. The Council is planning to submit the new Local Plan in late 2024 with adoption anticipated in late 2025
We return to local plan contributions in Section 3 in relation to the influence the 3PS is having on emerging local plans.
Greater Birmingham HMA Strategic Growth Study (SGS) (2018)
In 2018, GL Hearn and Wood were commissioned by the 14 HMA authorities to provide the SGS16. This built upon the PBA study (above), including updating need and assessing a consistent supply position so as to identify the unmet need to 2031 and 2036. We summarise the principal findings below, looking at need, supply and unmet need in turn. These are integral to the current position presented in the 3PS.
Need
The “Baseline” need was clearly expressed as a minimum level of provision; 205,000 to 2031 and 255,000 to 2036.
At the other end of the spectrum, an “Economy Plus” housing projection (reflecting the WMCA Strategic Economic Plan17) indicated a significantly higher need; 246,000 dwellings to 2031 and 310,000 dwellings to 2036.
The SGS concluded that provision of between 205,000 and 246,000 homes is needed across the HMA to 2031; and between 256,000 and 310,000 homes to 2036 (from a 2011 baseline). The HMA’s agreed contribution to the Coventry & Warwickshire HMA was added to the Baseline need (2,880 to 2031 and 3,600 to 2046), resulting in a minimum provision of 208,000 dwellings to 2031 and 258,500 dwellings to 2036.
Supply
GL Hearn made adjustments to local authority data to present a consistent position across the HMA, including a standard approach to windfall assumptions and a standard non-implementation discount. The report concluded on a supply of 180,000 dwellings to 2031 and 198,000 dwellings to 2036. It is worth noting that the 3PS is now indicating that supply is much higher than both of these figures, even just to 2031.
Shortfalls
Deducting supply from the Baseline need resulted in a minimum shortfall of 28,000 dwellings to 2031 and 61,000 dwellings to 2036:
Table 2.1: Summary of SGS minimum shortfalls (SGS Table 2)
A second PS was published in September 2018. This drew upon the SGS data but updated the position to reflect new supply information as at April 2017. The second PS provided context for the North Warwickshire Local Plan examination as well as for BDP monitoring.
HMA Position Statements
The 14 HMA local authorities have jointly published three Position Statements (“PS”) following publication of the SGS to provide updates on the unmet need.
February 2018 PS
The first PS was issued alongside the SGS and confirmed that the SGS is an independently prepared, objective study which is not policy, but provides a “…thorough evidence base to take matters forward through the local plan review process”. Importantly, the first PS restated the SGS Baseline need and acknowledged the “significant” minimum shortfall figures (Table 2.1 above). However, it was silent on the shortfall arising from the Economy Plus scenario. across the HMA. Nor was the raw data made available as part of the second PS so it has not been tested or examined.
The upshot of this increased unadjusted supply is a diminished unmet need; just under 11,000 dwellings at April 2017.
The 3PS represents an update to the second PS and is summarised in Section 3.
Black Country Plan 2039 (emerging) unmet need
In parallel with the SGS and the various PS referred to above, since 2016 the four Black Country authorities have been preparing the Black Country Plan 2039, which will replace the adopted Core Strategy (2011). The Draft
Plan19 was published for consultation in August 2021. It is anticipated the Submission Plan will be published for consultation in August 2022, with submission following in March 2023 and adoption in spring 2024.
The Draft Plan indicates that the Black Country’s housing need between 2020 and 2039 is 76,076 dwellings and, having regard to the Urban Capacity Review Update and proposed allocations in the Draft Plan (including Green Belt releases), there remains a shortfall of 28,239 homes to 2039.
Since regional planning was revoked in 2010, there has been an evolving position in terms of evidence on the HMA’s unmet housing need”.
Clearly, this is a significant unmet need which will have to be delivered across the wider HMA (or beyond). The Association of Black Country Authorities has already formally written to HMA members and other adjoining authorities to notify them of the shortfall and to request assistance.
This shortfall covers a different timeframe (2020- 2039) to the BDP, SGS and PS (2011-31/36), and is based upon the standard method, so it is not simply a case of combining the various shortfall figures to arrive at an up-to-date overall HMA shortfall figure.
Given the different timeframes, for the purposes of this report we focus on the period 2011 and 2031, given that there is data available for this period on need and supply across the whole HMA. The Black Country shortfall over this period will therefore be automatically captured.
Summary
Since regional planning was revoked in 2010, there has been an evolving position in terms of evidence on the HMA’s unmet housing need, which has resulted in a “moving target” for local plans.
The 2015 SHNS initially established an unmet need of 37,600 dwellings between 2011 and 2031, and this evidence was endorsed during the BDP examination, with Birmingham’s own shortfall confirmed as 37,900 homes (2017) (to 2031).
There has been limited progress over the past four years in terms of local plans being advanced to submission, examination and / or adoption which offer contributions to either the City’s shortfall or the HMA shortfall.
In broad terms, the combined contribution from submitted / examined / adopted local plans is in the order of c.8,600 dwellings, which obviously falls well short of either the HMA and / or Birmingham City unmet need. If the City’s claimed supply in the 3PS was delivered, the shortfall would still stand at c.15,000 dwellings.
In 2018, the SGS updated the Strategic Housing Needs Study, identifying:
• A need for between 205,000 and 246,000 homes across the HMA to 2031; and between 256,000 and 310,000 homes to 2036.
• A supply of 180,000 dwellings to 2031 and 198,000 dwellings to 2036. Helpfully, this supply was independently assessed to arrive at a consistent position.
• A baseline and minimum unmet need of 28,000 dwellings to 2031 and 61,000 dwellings to 2036. However, the shortfalls against the “Economy Plus” scenarios would be far greater; 69,000 dwellings to 2031 and 116,000 dwellings to 2036.
More recently, the HMA authorities have published position statements to support local plan reviews. These focus purely on the minimum need position to 2031, disregarding the need to 2036, and ignoring the SGS’ “Economy Plus” need projection.
The second PS (2018) claimed an increased housing supply at 2017 resulting in a minimum unmet need of 11,000 dwellings to 2031. However, the supply was “unadjusted” as it did not adopt the SGS’ approach to non-implementation discount rates. Moreover, the supply data was not made accessible and has not been tested or examined.
The 3PS was published in September 2020 and now forms the up-to-date and agreed position between the 14 authorities. It “estimates” the unmet need to 2031 has diminished to just 2,597 dwellings. This is clearly a huge reduction on the unmet need figures identified through the 2015 and 2018 need studies, as well as the shortfall figure established in the BDP (2017).
The next section considers the 3PS in further detail.
3. The impact of 3PS
In September 2020, the 14 HMA local authorities published the 3PS on the HMA’s housing need and land supply to identify the up-to-date unmet need / shortfall.
The 3PS covers the period 2011 to 2031 and the base date for supply data is 31 March 2019. Two years have since passed meaning the PS does not allow for housing completions or additional supply which has come forward in the intervening period. Nonetheless, it comprises the up-to-date agreed position of the 14 local authorities on this important strategic and cross-boundary issue and is now being relied upon as robust evidence to underpin emerging local plans.
Evidence supporting the Solihull Local Plan indicates that work has commenced on a fourth PS although it is unclear when this will be published.
Key points and general observations
Our high-level review of the 3PS’ supply assumptions is provided in Section 5 but key headlines and observations are summarised in the following table:
Table 3.1: Summary of key points and general observations on 3PS
Total supply is claimed to have increased to 205,382 dwellings compared to 180,000 in SGS, representing an increase of 25,000. The supply is broken down into different categories for the 14 authorities at Appendix 6. However, the raw data underpinning this has not been provided or appended making it difficult to scrutinise. In addition, this supply data has not been independently examined.
Reports a significant increase in Birmingham’s supply; +13,942 dwellings (+27%) from the baseline figures in the SGS.
The supply is “unadjusted” as it does not apply the standardised non- implementation discount rates from the SGS which provided a consistent approach across the HMA. Instead, only local discount rates are applied meaning that several authorities do not apply any discounts for non-delivery (Birmingham, Bromsgrove, Redditch and Stratford).
Shortfall
The total shortfall to 2031 is claimed to have diminished to 2,597 dwellings, representing a huge reduction on the unmet need figures identified through the 2015 and 2018 HMA need studies, as well as to the City’s shortfall figure established in the BDP (2017).
How is 3PS influencing plan making?
Paragraph 1.6 of the 3PS claims that “…there has been significant progress in reviewing local plans…”. Whilst many plans have been prepared and consulted upon, only two have reached “submission” stage and only one has been deemed sound since adoption of the BDP in 2017 (at the time of writing).
The 3PS is now having an impact on plan- making across the HMA (and beyond). Despite the supply data not being made readily accessible and therefore untested, it is now being relied upon as robust evidence to underpin emerging local plans. We provide a snapshot below of how the 3PS is influencing emerging plans.
Birmingham
Whilst the BDP review has only just commenced, the Council has acknowledged the 3PS21; “It is considered that the pre 2031 shortfall will continue to fall as local plan reviews progress”.
Cannock Chase
Cannock Chase’s Local Plan Preferred Options was published for consultation in February 2021. Whilst earlier consultations considered a contribution of up to 2,500 dwellings the Preferred Options version confirms that it has “…resolved to contribute 500 dwellings … to meet a shortfall arising from the GBBCHMA…” (included at Policy SO3.1).
Solihull
Solihull’s Local Plan was submitted for examination in May 2021 and the first round of hearings are scheduled for late September2021.
Solihull proposes to contribute 2,105 dwellings to the City’s unmet need to 2031. The plan period extends to 2036 but there is no HMA contribution beyond 2031.
The Duty to Cooperate Topic Paper22 refers to the 3PS and states that engagement has been effective, having “…resulted in unmet housing need (to 2031) … being reduced …to 2,597 dwellings…”. It goes on to highlight that proposed contributions from Lichfield and South Staffordshire are not included in the 3PS supply and alludes to these mopping up the residual need to 2031.
It concludes “Accordingly … there is no unmet need for Solihull to meet to 2031 (beyond the 2,000 units assumed to be provided)…”.
Several statements of common ground have been submitted as part of the examination, and several HMA authorities have expressed significant concerns with Solihull’s level of contribution; “disappointing”, “not committed”, a “modest” contribution and “serious failings”, as well as raising concerns at the lack of contributions towards post-2031 needs.
Lichfield
The Local Plan 2040 Regulation 19 plan (July 2021) proposes a total contribution of 2,665 homes towards the unmet HMA needs between 2027 and 2040 (2,000 being “capped” for the Black Country), equating to a HMA contribution of 820 dwellings in the period to 2031.
This contribution represents a significant reduction on Lichfield’s earlier proposed contribution of 4,500 dwellings, as recorded in the 3PS, which appears to reflect the 3PS – paragraph 4.21 states that “…the need arising from Birmingham in particular has primarily now been met”. However, the 3PS reflects the position across the HMA as a whole, so takes full account of the Black Country and is not limited to Birmingham, so it is unclear how this conclusion has been reached.
South Staffordshire
The Local Plan Review is in its early stages26 (Regulation 18) with broad strategy options and locations being consulted on. The December
2019 consultation alluded to a potential HMA contribution of up to 4,000 dwellings between 2018 and 2037 although it is unclear what proportion would be delivered by 2031, and the Council note that if the HMA shortfall significantly reduces prior to submission – which the 3PS claims has happened – the level of contribution may reduce27.
Stratford-on-Avon
The Council is in the process of preparing a Site Allocations Plan to support the Core Strategy and the “Preferred Option”28 refers to the 3PS as showing “…a significant reduction in the shortfall to 2,597 homes…”29 and that the Council “…is working with its partner authorities … to contribute 1/9th of the shortfall…”.
Conclusions
The 3PS comprises the up-to-date agreed position of the 14 local authorities on the critical cross-boundary issue of strategic housing
need. It paints a picture of significant local plan progress across the HMA which is misleading given only a handful of plans have reached submission, examination or adoption since the shortfall was identified in the BDP (2017) and SGS (2018).
The 3PS is now being relied upon by several local authorities as robust evidence to underpin their emerging local plans, many of which have interpreted it as confirming that the unmet need to 2031 has effectively been resolved. In Lichfield’s case, they have significantly reduced their HMA contribution to 2040.
We have significant concerns over the soundness of the 3PS:
• It only covers 2011 to 2031 when local plan reviews are working well beyond this date (post-2040 in several cases). This is short sighted, especially when the SGS covered the period to 2036, and does not assist local authorities in planning for long-term strategic housing needs, as demonstrated in Solihull (where several HMA local authorities have objected to its proposed contribution).
• It only considers the minimum need from the SGS, and does not reflect the standard method. It totally disregards the “Economy Plus” scenario from the SGS which indicates a far greater need to 2031 and 2036.
• The supply data is “unadjusted” unlike the data presented in the SGS, in terms of not being independently reviewed and with some authorities not applying any form of non-implementation discount. Furthermore, the raw data has not been made readily accessible alongside the 3PS so it is difficult to scrutinise and it has yet to be properly tested through a local plan examination.
Our high-level review of the 3PS’ supply data and assumptions is provided at Section 5 of this report.

The 3PS is now having an impact on plan- making across the HMA (and beyond)”.
4. The scale of need to 2031 (and beyond)
This Section assesses the scale of need across the HMA in the period to 2031 and up to 2040. This is the critical first step in determining whether or not there is an unmet need across the HMA.
At the outset, it is worth reiterating that the BDP shortfall figure no longer represents the most appropriate up-to-date target for strategic planning across the HMA (our reasoning is provided at Section 2). It is therefore necessary to reassess the up-to-date need position, in advance of reviewing supply.
The need to 2031 according to the 3PS
As explained in Section 3, the level of housing need referenced in the 3PS continues to be linked to the SGS “baseline” scenario; a minimum need for 205,099 homes across the HMA (2011 to 2031), equivalent to 10,255 homes per annum on average.
In order to assess need against supply the 3PS adds a further 2,880 homes by way of a contribution to the Coventry and Warwickshire HMA (C&WHMA) (consistent with the SGS), which results in a stated minimum requirement for 207,979 homes to 2031.
For clarity, the figures presented below are purely the HMA’s need so do not factor in the C&WHMA contribution. However, we take this additional provision in to account in Section 6 when we seek to identify the HMA’s unmet need by deducting supply from the need. This is necessary because the 3PS’ supply for Stratford and North Warwickshire factors in this contribution.
Accounting for the standard method – a picture of rising need to 2031
As acknowledged within the 3PS, it is challenging to undertake a consistent assessment of need where local plans have progressed to varying programmes and the Government has continued to update and evolve the method for calculating housing need, as set out in the NPPF and Planning Practice Guidance (“PPG”).
However, the standard method now allows for a clear and consistent assessment of the minimum need for housing as of 2021 and beyond. This suggests a need for at least 11,868 homes per annum across the HMA as a whole. When applied across a comparable 20 year period to that referenced in the 3PS, this implies a need for 237,360 homes.
This should not necessarily supersede the SGS minimum need figure referenced in the 3PS as that related to the period from 2011 onwards and the standard method is not designed to be applied so retrospectively.
A sensible and rational approach, which provides a level of consistency with the existing evidence base and adheres to current national policy, would be to align with the SGS “baseline” scenario for the first ten years (2011-21), before aligning with the outcome of the standard method for the second ten year period (2021-31). This would result in a minimum need for 221,230 homes, some 8% more than suggested by the 3PS, clearly affirming the rising pressures facing the HMA.
This is still likely to remain an underestimate of housing need, where the figure for Birmingham is affected by the cap which “reduces the minimum number generated by the standard method, but does not reduce housing need itself”30(our emphasis).

This cap only applies for the five years following adoption of the BDP, so will notably be removed in less than six months – after 10 January 2022 – when the City’s housing needs will automatically rise from 4,829 homes per annum to some 6,750 homes.
This represents almost 2,000 additional homes per year, and when added from 2022 onwards the overall estimate of need across the HMA between 2011 and 2031 is elevated by some 17,289 homes to at least 238,519 homes.
Figure 4.1: Turley estimates of overall housing need (2011-31)
Removing Birmingham's cap from 2022 onwards
Looking beyond 2031
While the above – like the 3PS – provides an estimate of need to 2031, it can be easily extended to cover a longer period such as 2036 or 2040.
This is important because emerging local plans across the HMA are seeking to deliver strategic growth into the late 2030s or, in several cases, beyond 2040 (Birmingham, Bromsgrove, Lichfield and Stratford-on-Avon).
The SGS “baseline” scenario already covers the period 2011 to 2036 and suggests that at least 254,873 homes are needed over this extended period. No estimate to 2040 is presented, however. In looking to incorporate the standard method from 2021 onwards, the PPG makes clear that while it technically draws upon a ten year baseline, the annual number can be extrapolated as necessary to cover a whole plan period31.
Applying such an approach and using the uncapped outcome of the standard method as the basis of housing needs after 2031 – as illustrated at Figure 4.1 – suggests that some 307,464 homes could be needed over the period from 2011 to 2036. This rises to 362,620 homes when extended to 2040.
Figure 4.2: Estimating housing needs to 2036 and 2040
Standard method, uncapped from 2022 (13,789dpa) Standard method, capped for Birmingham (11,868dpa) SGS Baseline (10,255dpa)
A risk that the standard method falls short of capturing the full needs
The Government’s revision to the standard method affirms the importance of ensuring a boosting of supply nationally to achieve its target of 300,000 homes per annum.
The revised method now expects supply to be increased more than previously in larger urban conurbations, with Birmingham and Wolverhampton two of the twenty cities and urban centres for which the need figures are increased by 35%.
Even allowing for this additional step in the standard method, it clearly remains the case that it produces only a “minimum” need for housing32. The PPG accepts that there will be circumstances where it is appropriate to plan for a higher housing need figure, whether – though not only – as a result of growth strategies or strategic infrastructure investments that could drive an increase in the number of homes needed.
The HMA evidently displays these characteristics, where it sits at the fulcrum of the Midlands Engine and is set to benefit from the country’s most significant infrastructure investment in the form of High Speed 2 alongside a range of other investments recognised within the Midlands Connect Strategy.
As explained in Section 2, the effect of stronger economic growth on housing need across the HMA was considered in detail – albeit now some time ago – within the SGS, which included an “Economy Plus” scenario that assumed “further and faster” economic growth that would lead to the West Midlands making a “stronger
Table 4.1: Estimates of housing need across the HMA contribution to the national economy”.
Significantly, the SGS found that some 245,545 homes could be needed to 2031 in this scenario, increasing to 310,188 homes over the period to 2036. This would respectively add 7,026 and 2,724 homes to the totals presented at Figure 4.2 of this report.
Summary
The 3PS cites the SGS baseline scenario in describing a minimum need for 205,099 homes between 2011 and 2031, but this takes no account of the standard method which can be reasonably incorporated for the latter half of this period to suggest a greater need for at least 221,230 homes.
This increases to at least 238,519 homes when allowing for the removal of Birmingham’s cap in 2022, with this resultant level of need approaching that of the “Economy Plus” scenario presented in the SGS (245,545). The level of need suggested by this scenario increases to some 310,188 homes when extended to 2036, remaining slightly higher than implied over the same period by our approach that incorporates the standard method (307,464).
This latter approach can also be extended to 2040 on the same basis, which indicates an overall need for 362,620 homes between 2011 and 2040.
These results are presented in Table 4.1 and revisited in Section 6 when calculating the unmet need:
5. Analysis of supply in 3PS
3PS supply position
The baseline supply data underpinning the 3PS is claimed to be 205,382 homes between 2011 and 2031 (Table 5 of the 3PS).
The supply has significantly increased from the figure of 180,000 identified in the SGS; a significant increase of 25,000 dwellings. Indeed, it even exceeds the SGS’ figure of projected supply through to 2036 (198,000).
Appendix 6 of the 3PS provides a breakdown of the supply for each of the 14 authorities, using the following categories:
• Sites with planning permission
• Allocations in adopted plans
• Proposed allocations (current SADs / new Local Plans)
• Additional urban supply
• Windfalls
• Completions 2011/12 to 2018/19
The data underpinning Appendix 6 has not been made readily available meaning it is difficult to scrutinise. In addition, this data has not been independently audited, unlike the in the SGS which allowed for a consistent “baseline” position. The table below compares the SGS’ “baseline” (adjusted) supply with the 3PS supply (2011-31):
Table 5.1: Comparison of SGS “adjusted” supply and 3PS supply for 2011-31
This comprises the baseline supply presented in Table 28 of the Strategic Growth Study. It was produced following a review of local authority supplied data and also includes standard discount rates for non-implementation.
Whilst the two supply figures above cover the same timeframe they have different base dates so supply will have shifted between categories during the intervening 2/3 years e.g. some permissions will have become completions. However, the above indicates a major uplift in completions over the 3 year period (2016-2019).
Overall, there has been a significant increase in supply over the 2/3 year period; c.25,000 dwellings. The 3PS36 suggests the main source of the capacity increase is from Birmingham with an increase of 13,942 dwellings (+27%) from the baseline figures in the SGS.
Method of analysis
Arriving at an accurate picture of overall supply across the HMA is obviously a critical factor in determining whether or not there is an unmet housing need. In particular, it is important that the actual deliverability of supply components is realistic in the period to 2031 e.g. realistic delivery rates should be applied to strategic permissions and allocations.
We have sought to analyse the supply in high- level terms by obtaining and exploring the raw data which underpins Appendix 6 of the 3PS. To inform our assessment we approached all authorities to request a copy of the data. The following authorities provided the relevant data:
• Birmingham City Council
• Bromsgrove District Council
• Dudley Council
• Lichfield District Council
• Redditch Borough Council
• Sandwell Council
• South Staffordshire Council
• Stratford on Avon District Council
• Walsall Council
• Wolverhampton Council
For those authorities which provided the data, the specific source of data which has informed the 3PS varies, including Strategic Housing and Employment Land Availability Assessments (“SHELAA”), combined capacity studies, 5 year housing land supply data and high-level summaries following the categories set out at paragraph 5.3 above.
This does result in a somewhat inconsistent approach to data collection and components of the supply across the HMA, which has been difficult to scrutinise.
At the time of writing, no data has been received from the following authorities:
• Cannock Chase District Council
• North Warwickshire Borough Council
• Solihull Council
• Tamworth Borough Council
For the four missing data sets we have had to make assumptions using monitoring data and SHELAAs published by these authorities.
To ensure our assessment is on a like-for-like basis it applies the same base date; 31 March 2019, so any subsequent supply data has not been considered (for instance monitoring data for 2019/20 and 2020/21 to confirm if each authorities’ projections were in fact correct).
It is important to understand that our analysis does not amount to a rigorous line-by-line review of the deliverability / developability of supply components, nor of all sites, as this would obviously be a major undertaking. Rather, our approach has been to “sense check” the figures presented in Appendix 6 of the 3PS and, in certain instances, delve further in to specific authority sub-totals which has prompted a review of assumptions applied for specific strategic sites.
The results of our analysis are presented below.
Allocations – Adopted Plans
There are regionally significant allocations included in the “allocations – adopted Plans” category, including Long Marston Airfield (“LMA”) in Stratford (Stratford Core
Strategy policy Proposal LMA) and Langley in Birmingham (BDP policy GA5). The 3PS supply includes 2,450 dwellings at LMA and 2,951 dwellings at Langley up to 2031 based on the data provided by the councils. We do not consider it realistic for all of this housing to be delivered at these two strategic sites in the period to 2031.
Langley
Birmingham’s data on Adopted Allocations provided to inform the 3PS is not clear as to what this component specifically comprises, but when checked against its Strategic Housing Land Availability Assessment 2019 (December 2019)37, it appears to be based on the remaining capacity of all allocations i.e. the total allocation housing quantum, after deducting completions, under construction and committed (both outline and detailed) dwellings). The appraisal of Langley within the Strategic Land Availability Assessment 2019 (proforma N646) confirms this to be 2,951 dwellings.
This is unrealistic. No application has been submitted to date for the Langley SUE, although we understand that pre-application discussions are now well advanced and an application is to be submitted imminently (which will be taken into account in preparing any further revisions of this report, should we need to respond to any future Position Statements).
Birmingham City’s Strategic Housing Land Availability Assessment (the most up to date evidence in respect to Langley’s delivery) anticipates that development will commence in 2024/25 (107 dwellings), with annual delivery reaching 1,089 dwellings in 2030/31. As no application has yet been submitted, as a minimum it is realistic to push back delivery by one year. This would result in the final year of delivery no longer being counted before 2030/31, so based on the Council’s own evidence Langley would only be capable of delivering 1,862 dwellings.
The above was reflected in the evidence given by the Council’s own witness to the North Worcestershire Golf Course appeal (PINS ref: 3192918), there they accepted that Langley was “…likely to deliver about 2,000 dwellings within the BDP plan period” (paragraph 8.34 of the Inspector’s Report for that decision).
Notwithstanding the above, based on similar scale SUEs elsewhere across the region and the findings of Lichfields’ Start to Finish report (February 2020)38, it is likely this still represents an ambitious estimation as it is reliant on the Council determining any application for Langley expediently.
Also there is significant infrastructure delivery required within the first five years of delivery (highways infrastructure, primary school, community hub including a health centre and retail, green infrastructure and off-site highway improvements). As such, we recommend that Birmingham’s “allocations – adopted Plans” component of the supply should be reduced by at least 1,089 dwellings to 6,748 homes.
Long Marston Airfield
Up to 2031 Stratford’s supply includes 2,450 new homes at phase two of LMA. That site is currently subject to an outline planning application for 3,100 new homes (ref: 18/01892/ OUT). The application was submitted in June 2018 but remains under determination.
Core Strategy policy “Proposal LMA: Long Marston Airfield” is clear that completion of the south-western relief road (SWRR) is required before more than 400 dwellings at can be occupied. The first 400 dwellings (phase 1) at the site are already subject to detailed consent (ref: 17/03258/REM) and are being constructed, but the remaining 3,100 dwellings (phase 2) subject to outline planning application 18/01892/OUT cannot be occupied until the SWRR is complete.
The SWRR is a considerable infrastructure project subject to a separate planning application (ref: 18/01883/FUL) which is also still under determination and currently subject to holding objections from Highways England and the Environment Agency. That application anticipates that construction would take 18 to 24 months to complete, and had assumed completion in 2021 to 2022. However, even if planning permission were to be granted the SWRR is still reliant on public sector funding with the County Council’s application to Homes England for c.£86m of Housing Infrastructure Fund being unsuccessful in early 2020.
As such, there remains no clarity as to when either application will be determined and when funding will be secured. As such there is significant doubt LMA Phase 2 will deliver any new homes in the next five years. This would see delivery not commencing until the 2026/27.
As a minimum, this would push back Stratford’s trajectory for the site by two years so we recommend that Stratford’s “allocations – adopted plans” component be reduced by at least 400 dwellings.
Additional urban supply and windfalls
The “additional urban supply” component makes up approximately 13% of the total supply between 2019 and 2031.
There is no clear explanation or evidence provided within the 3PS on the “additional urban supply” component. The SGS identifies this component (at paragraph 4.8) as “…sites within existing urban areas which do not have planning consent, and are not allocated in the adopted or emerging Local Plan (including Neighbourhood Plans), but which have been identified as suitable for residential development and could be delivered by 2036”.
The NPPF defines windfall development (page 73) as “…sites not specifically identified in the development plan”.
Based on the above definitions, the ‘additional urban supply’ and ‘windfall’ components both comprise sites not identified in the adopted or emerging development plan. There is a lack of clear evidence as to what this component specifically comprises and there may be a risk of double counting between these two components.
As an example, the biggest contributor to ‘additional urban supply’ is Birmingham – almost 13,000 dwellings – which represents 66% of total additional urban supply across the HMA and this is in addition to its own windfall allowance of nearly 5,000 dwellings. The “additional urban supply” component within Birmingham’s Strategic Housing Land Availability Assessment 2019 is made up of ‘other opportunity within BDP growth area’ (7,212 dwellings) and ‘other opportunity outside BDP growth area’ (5,711 dwellings). The Strategic Housing Land Availability Assessment is not clear which sites fall within these two categories.
Going forward, further clarity must be provided as to which sites are included in the ‘additional urban supply’ component, so there is no confusion as to whether this component is deliverable/realistic and to ensure there is no double counting with the windfall component.
Non-implementation rate discounts
Based on the evidence each authority provided to the SGS, the report advocates a consistent and realistic approach to making assumptions on non- implementation rate discounts across the HMA (paragraphs 1.18 and 4.122-4.127), these include:
• 5% discount in all areas for committed dwellings (i.e. with outline or full planning permission).
• A 15% discount in the four Black Country authorities for sites without planning permission, reflecting the amount of the supply which comprises employment sites and there are delivery challenges associated with land assembly, business relocation and viability.
• In other HMA authorities, a 10% discount on sites without planning permission.
Table 4 of the 3PS reveals that non- implementation rate discounts have now been applied on a local basis across the GBBCHMA. This is largely due to non-implementation rates being agreed when a plan is examined. Notwithstanding this, non-implementation rate discounts have not been applied for Birmingham, Bromsgrove, Redditch or Stratford-on-Avon.
To ensure that there is a degree of consistency across the HMA-wide supply we have applied the SGS standard discounts to these 3 authorities which results in the following deductions:
• Birmingham – 3,347 dwelling reduction (this takes in to account the Langley deduction above, to avoid any “double” discount)
• Bromsgrove – 271 dwelling reduction
• Redditch – 516 dwelling reduction
• Stratford-on-Avon – 594 dwelling reduction (this takes in to account the Long Marston Airfield deduction above, to avoid any “double” discount)
Based upon the above, there should be a reduction of 4,728 dwellings.
Conclusions on the 3PS supply
Our high-level analysis of the 3PS’ supply data suggests that the claimed supply is over optimistic. We have identified the following specific items which warrant reductions in the supply position:
• 1,089 dwellings should be deducted from Birmingham’s “allocations – adopted Plans” component as the available evidence suggests Langley is unlikely to deliver homes pre-2031.
• At least 400 dwellings should be deducted from Stratford’s “allocations” component to reflect the uncertainties associated with the long-term delivery of LMA given it is beholden upon construction of the SWRR.
• Four authorities do not apply any form of discount for non-implementation which presents an inconsistent approach across the HMA and is contrary to the approach adopted in the SGS. The standard discount rates from the SGS should be applied to Birmingham, Bromsgrove, Redditch and Stratford-on- Avon (i.e. 5% for committed sites and 10% for planning permissions). When this is applied, there is a reduction of 4,728 dwellings.
Taking all of the above in to account, we consider that the HMA supply to 2031 should be reduced by at least 6,217 dwellings. This would result in a reduced supply to 2031 of 199,165 dwellings.
Bearing in mind that the raw data on supply has not all been made accessible/available and the supply remains to be tested in detail (e.g. “additional urban supply”), we consider this to be a conservative reduction (5%), but it does present a more realistic picture of supply to 2031 compared to the 3PS.
We highlight that this adjusted level of supply still significantly exceeds the baseline supply from the SGS (180,000) and even exceeds the projected supply to 2036 (198,000).
We consider that the HMA supply to 2031 should be reduced by at least 6,217 dwellings.
6. Quantifying the unmet need to 2031 (and beyond)
Having presented up-to-date scenarios of the HMA’s need (Section 4) and having reviewed the supply position from the 3PS (Section 5), it is possible to quantify the true scale of the HMA’s unmet need between 2011 and 2031.
We also provide below an indication of the scale of unmet need post-2031. However, this should be considered purely as indicative as there is currently an incomplete picture as regards to housing supply across the HMA post-2031 and we have therefore relied upon the 3PS housing supply figure (explained further below).
Please note that the figures presented below take account of the contribution from North Warwickshire and Stratford to the C&WHMA. This approach is consistent with the 3PS and reflects the fact that the supply figures for these authorities in the 3PS includes this contribution so they must be balanced out.
What is the unmet need to 2031?The table below draws together all of the data from preceding Sections to arrive at the unmet need between 2011 and 2031. The results are presented visually in the figure overleaf:
Table 6.1: Need, supply and unmet need to 2031
Figure 6.1: The HMA’s unmet need to 2031
3PS supply – The best case scenario
The 3PS presents the “best case” supply position so would lead to the optimal position in terms of unmet needs. The 3PS applies this supply to the SGS “Baseline” need with the minimum shortfall to 2031 diminishing to just 2,597 dwellings. This best case therefore still leads to a shortfall which local plans must address.
However, the standard method was introduced after the SGS was published, so the Baseline need should now be updated to align with national policy and guidance so that the standard method is applied from 2021 onwards, as explained in Section 4.
When applying the 3PS supply to the standard method scenario which retains the Birmingham “cap” beyond 2022 there remains a significant minimum unmet need of 18,700 dwellings to 2031. When the Birmingham cap is lifted (from 2022) the shortfall increases to at least 36,000 dwellings.
At the other end of the spectrum is the SGS’ “Economy Plus” scenario. Even with the best case supply it would fall short by at least 43,000 dwellings.
Turley supply – A realistic position
Our high-level analysis of the 3PS’ supply data reveals that some of the claimed supply is unrealistic (not deliverable to 2031) and we have therefore recommended a deduction of 6,217 dwellings. This reduces the overall supply to 2031 to 199,165 dwellings.
Applying this adjusted and realistic level of supply to the SGS “Baseline” reveals a minimum shortfall to 2031 of 8,000 dwellings.
Turning to the two standard method scenarios:
• There is an unmet need of at least 25,000 dwellings to 2031, when the Birmingham cap is retained to 2031.
• When the Birmingham cap is lifted, the shortfall to 2031 increases to at least 42,000 dwellings.
Applying the SGS’ “Economy Plus” scenario results in a shortfall of over 49,000 dwellings.
Conclusions on the unmet need to 2031
The various scenarios presented reveal that a significant unmet need remains across the HMA to 2031.
The local authorities should be planning positively to deliver the standard method between 2021 and 2031 and even if Birmingham’s cap were to be retained over this period and the “best case” 3PS supply were to be delivered there would still be a significant shortfall of at least 18,700 dwellings. A more realistic level of supply indicates that the shortfall is at least 25,000 dwellings, which closely aligns with the SGS Baseline unmet need figure from 2018 (28,000).
With the Birmingham cap lifted from 2022, the minimum shortfall (ranging between 36,000 and 42,000) would return to the level identified in the SHNS (37,600), and becomes more aligned with the SGS “Economy Plus” shortfall. It is recognised that delivering this level of uplift over the next 10 years is likely to be major challenge for the HMA.
The 3PS fails to provide a robust evidence base on the HMA’s unmet need by relying upon the minimum baseline need from the SGS (which is now out of date) and presenting an over optimistic supply position. The shortfall of 2,597 should not be afforded any weight in plan- making and examinations.
It is paramount that the local authorities jointly prepare an accurate and up-to-date position statement to determine the accurate unmet need to at least 2031.
This should be a priority given the urgency of resolving the shortfall over the next ten years, and mindful of the time it takes to progress local plans through examination to adoption. Failing to plan for the true shortfall to 2031 immediately will simply store up the problems for housing delivery beyond 2031.
Looking ahead – an indication of the shortfall to 2036 and 2040
It is difficult to accurately quantify the unmet needs beyond 2031 because there is an incomplete picture in terms of the HMA’s housing supply beyond this date. We provide an indication of the potential scale of unmet need between 2011 and 2036 and 2011 and 2040.
It is recognised that North Warwickshire’s plan will shortly be adopted and will deliver housing beyond 2031 but this will only extend to 2033. There are three HMA local plans emerging which provide specific draft allocations to meet needs beyond 2031 (Black Country, Lichfield and Solihull), as well as the emerging Shropshire Local Plan, but these are all still subject to examination so cannot be relied upon as sound/ developable allocations at the current time.
With respect to the 3PS supply of 205,382 up to 2031, we highlight that this still exceeds the “adjusted” land supply figure from the SGS which covered the period 2011-2036; 197,618. It also exceeds the initial supply data to 2036 which was provided to GL Hearn by the local authorities as part of the SGS; 202,921.
Notwithstanding the above, this data for post 2031 is not complete. From reviewing the raw data which underpins the 3PS, it is clear there is no supply information for the majority of authorities post 2031. In terms of calculating the supply position to 2036 and 2040 we therefore consider that a more reasonable approach is to extrapolate the 2011-2031 3PS supply (205,382 homes) and Turley adjusted supply (199,165 homes) beyond 2031. This can be done by annualising the supplies (10,269 homes and 9,958 homes rounded respectively) and applying the annual figure each year beyond 2031.
The above advocated approach is relatively simplistic and crude as it is arguable as to whether the urban areas can continue to deliver at rates similar to 2011-2031 and Local Plans such as Lichfield are proposing lower rates of growth in emerging plans, but serves to provide an indication of the potential scale of the shortfall post-2031.

The results are presented in the table figure and figure overleaf:
Table 6.2: Need, 3PS supply and unmet need to 2036 and 2040
Figure 6.2: The HMA’s unmet need to 2031
The above clearly indicates the magnitude of the shortfall to 2036 and 2040.
When applying the standard method from 2021 or applying the SGS “Economy Plus” scenario, additional land will be required to deliver a minimum of 53,000 dwellings to 2036. This rises to a minimum of 69,000 dwellings (rounded) to 2040 applying the standard method from 2021.
The emerging local plans across the HMA should be planning for this shortfall now given that they are working towards these plan periods, and further ahead in certain cases; Solihull is working to 2036, Birmingham to 2042 and Stratford-on-Avon is considering an end date of 2050 for the South Warwickshire Plan.
7. Conclusions and recommendations
In September 2020, the 14 local authorities which make up the Greater Birmingham and Black Country Housing Market Area (“GBBCHMA”) published their third “Position Statement” (“3PS”). The headline conclusion was that “the 2011-31 shortfall is now estimated to be 2,597”.
This report has been commissioned by a Consortium of housebuilders and land promoters to take stock of the position in order to quantify the true scale of unmet need to 2031, and beyond.
The report has focused upon 2011 to 2031 as the timeframe covered by the 3PS, as well as various other evidence base studies concerning need and supply and the Birmingham Development Plan. However, it has also looked beyond 2031 in high- level terms, mindful that emerging local plans are seeking to deliver growth into the late 2030s or, in several cases, beyond 2040. The conclusions and recommendations are set out below.
Key conclusions
An evolving unmet need
Since 2010, there has been an evolving position on the HMA’s unmet housing need. The 2015 Strategic Housing Needs Study (“SHNS”) established an unmet need of 37,600 dwellings (2011 to 2031) and this evidence was endorsed during the Birmingham Development Plan (“BDP”) examination, with Birmingham’s own shortfall confirmed as 37,900 homes (2017).
Birmingham City’s shortfall forms a key milestone because it comprises the most up-to-date position on unmet housing needs across the HMA in terms of being independently examined, found sound by an Inspector and adopted in a local plan. Taking in to account the 3PS’ claimed supply for the City to 2031 and contributions from Solihull, North Warwickshire and Stratford, the BDP shortfall would stand at c.15,000 dwellings.
However, there are two reasons why the BDP shortfall figure should no longer represent the principal target for emerging local plans:
a. Fundamental changes to national planning policy and guidance on how housing need should be calculated have been brought into force in the meantime. The Council has resolved to commence a review of the BDP with the standard method being a key factor in this decision (its need will be five years in a matter of months); and
b. The 37,900 figure is the City’s shortfall, as opposed to the unmet need across the whole HMA. It is critical that the overall unmet need is identified and addressed over a consistent timeframe.
The 2018 Strategic Growth Study (“SGS”) identified a baseline minimum unmet need of 28,000 dwellings to 2031 and 61,000 dwellings to 2036. However, shortfalls against the “Economy Plus” scenarios were far greater.
The HMA authorities have since published position statements to support local plan reviews. The 3PS forms the up-to-date and agreed position between the authorities on unmet need to 2031, estimating that it has diminished to 2,597 dwellings.
The 3PS paints a picture of significant progress across the HMA which is misleading given only a handful of plans have reached submission, examination or adoption since BDP adoption in 2017 and publication of the SGS in 2018.
The 3PS is now being relied upon by local authorities as robust evidence to underpin emerging local plans. However, there are significant concerns over its soundness:
• It only covers 2011 to 2031 when local plan reviews are working well beyond this date.
• It only considers the minimum SGS need and does not reflect the standard method. It also disregards the SGS “Economy Plus” scenario.
• The supply data is “unadjusted”, in terms of not being independently reviewed or examined and with aspects of supply not being subject to non-implementation discounts. Importantly, the raw data has not been made readily available and is difficult to scrutinise.
The true scale of unmet need to 2031 and beyond
Our independent assessment has reassessed the HMA need to 2031 (and beyond) and scrutinised the 3PS’ supply. In terms of the former, the standard method should be applied from 2021. In terms of the latter, we conclude that elements of the 3PS’ supply are unsound and contend that the figure should be reduced to 199,165.
The scenarios presented reveal that a significant unmet need remains across the HMA to 2031:
• Even if Birmingham’s cap were to be retained and the “best case” 3PS supply were delivered there would remain a significant shortfall of at least 18,700 dwellings. When applying our (realistic) level of supply the shortfall rises to at least 25,000 dwellings.
• With the Birmingham cap lifted from 2022, the minimum shortfall to 2031 will increase to between 36,000 and 42,000 dwellings (depending upon which supply figure is used).
It can be concluded that the 3PS fails to provide robust evidence on the HMA’s unmet need and the claimed shortfall of 2,597 should not be afforded any weight in plan-making.
Looking beyond 2031, the unmet need could be between 53,000 and 64,000 homes by 2036 and in excess of 70,000 homes by 2040. The emerging local plans across the HMA must plan for this shortfall now given they are working to these time horizons (and further ahead in certain cases).
Recommendations
A Fourth Position Statement

There is an immediate and urgent need for the HMA authorities to produce an up-to-date Position Statement in order to provide a sound assessment of HMA-wide need to (at least) 2031 using the standard method, set against a realistic supply position, in order to accurately quantify the unmet housing need. Our evidence clearly shows that, best case, the shortfall to 2031 is nearly 19,000 dwellings.
This report has presented two need scenarios which incorporate the standard method which can be easily applied. The standard method presents a straightforward means of calculating need for local authorities so there is no reason why the need cannot be completed swiftly. Indeed, many authorities have already applied the SM as part of their emerging local plans.
Turning to supply, the authorities must present and publish the full supply data in a consistent format to ensure it can be independently tested and examined. It is simply not acceptable to present supply figures without any data to back it up.
Future Position Statements
The authorities should commit to the publication of annual Position Statements, or monitoring reports, to regularly update the HMA-wide position based upon updated data on supply. This will be essential for forthcoming local plan examinations (including Solihull and Lichfield) as well as for ongoing local plan reviews.
Delivering the unmet need to 2031
Quantifying and agreeing the unmet need to 2031 is the first step, but it will also be critical for the authorities to reach a level of consensus on how the shortfall will be distributed and delivered.
A statement of common ground or memorandum of agreement should be produced as quickly as possible, ideally over the next twelve months, to demonstrate how the shortfall will be delivered by the relevant authorities through to 2031. If there are specific areas of disagreement these can be clearly articulated.
This will allow the forthcoming local plan reviews to progress to adoption as quickly as possible, and will avoid the need for a plethora of statements of common ground for each examination (as has happened for Solihull). The C&WHMA authorities have already demonstrated how an unmet HMA need can be distributed by applying a basic “functional relationship” method.
A more radical approach for longer term needs
Given the scale of the housing shortfall post- 2031 a more radical approach to strategic and spatial plan-making is required. Simply put, strategic planning across the GBBCHMA has been operating in a vacuum since the revocation of regional planning in 2010 and the ad-hoc and piecemeal approach cannot continue any longer otherwise sustainable development will not be secured.
A strategic plan or framework is required to cover longer-term growth, potentially to 2040 or beyond. This does not need to comprise a statutory plan but could form a non-statutory vision document such as the Strategic Growth Plan prepared by the Leicestershire authorities.
This has been proposed by the GBSLEP several years ago (“The Spatial Plan for Growth”) and was advocated by the West Midlands Land Commission in 2018 but neither has come to fruition.
We urge the fourteen authorities to engage with the development industry so that the long-term approach to strategic planning across the GBBCHMA can be scoped and implemented.
updating local plans. It is therefore vitally important that transparent evidence is provided to demonstrate that plans are being prepared positively to ensure that policy frameworks are put in place to address the housing and employment needs of the wider area in full. The Duty to Cooperate is central to this and therefore robust evidence is required to underpin any associated position statements or statements of common ground. In this regard, Gladman has joined a consortium of developers involved in strategic planning and sustainable housing delivery across the West Midlands Region in commissioning Turley to assess the overall housing need and supply position so as to identify the true scale of unmet need in the region. Further details are provided in response to the Draft Plan in Section 4 below and through Turley’s Report “Falling Short: Taking stock of unmet needs across the Greater Birmingham and Black Country Housing Market Area, August 2021” which can be found at Appendix 1 of this submission.