Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 285

Received: 21/12/2023

Respondent: Redrow Homes Limited

Agent: Harris Lamb

Dudley Local Plan Preferred Options Consultation
Response by Redrow Homes Limited
Harris Lamb Planning Consultancy are instructed by Redrow Homes Limited (‘Redrow’) to submit representations to the Dudley Local Plan Preferred Options consultation. Redrow is currently promoting a site for residential development in South Staffordshire which is also in the same HMA and wish to submit comments in respect of the Dudley Plan. Whilst Redrow’s interests are not explicitly located within Dudley Borough the way the Dudley Plan is currently draft will have a number of repercussions on the delivery of housing across the wider HMA. It is within this context that Redrow’s representations are submitted and you should read our comments in this context.
A shortfall in meeting Dudley’s needs
The development strategy set out within the Dudley Local Plan is to meet the Borough’s housing needs on previously developed land within the urban area. The Standard Method housing requirement for Dudley is 11,954 dwellings however there is only currently capacity to accommodate 10,876 of these. There is, therefore, a shortfall of 1,076 dwellings which are needed but which the Council is unable to accommodate within its own administrative area. The Plan is not currently proposing to release land from the Green Belt and whilst the recently updated National Planning Policy Framework (‘the Framework’) removes the requirement to review the Green Belt, the fact that it has a shortfall in the amount of housing that is needed against which it can currently provide will mean that the shortfall of 1,076 dwellings will have to be accommodated elsewhere within the HMA in adjoining authorities if housing needs are to be met in full. Paragraph 11b) still states that strategic policies should, as a minimum, provide for the objectively assessed needs for housing and other uses, as well any needs that cannot be met within neighbouring area. South Staffordshire as one of the closest adjoining authorities with a strong functional relationship to Dudley would be one such location where additional housing could be accommodated if needed.

Redrow consider this to be an unsound approach largely on the basis that if the 1,076 dwellings have to be provided elsewhere, this will reduce the availability of any alternative capacity to meet the needs of other authorities in the HMA that have much a greater unmet need, which will effectively be competing with Dudley for this capacity, when the Council has available Green Belt land within its own administrative area that it could use but which has chosen not to release. In looking to adjoining neighbouring authorities it is highly likely that if they were to agree to accommodate any of Dudley’s needs it would have to be on Green Belt
land. Clearly, if this is the case then it should be demonstrated first that Dudley has exhausted all sources of potential land within its administrative area first, including Green Belt land, before looking cross boundary. If there is no alternative then Dudley will need to work with adjoining authorities and agree with them to meet its needs. South Staffordshire, due to its close functional relationship with Dudley would be an ideal location for where new housing could be provided that would help meet Dudley’s needs.
A significant wider unmet need exists
The shortfall of land for housing is not unique to Dudley and is a long-established concern within the HMA.
Birmingham Development Plan
The Birmingham Development Plan (“BDP”) was adopted in January 2017. Policy PG1 – Overall Levels of Growth, advised that 89,000 dwellings are required during the course of the plan period (2011 to 2031) to meet the growth requirements of the City. However, only 51,100 additional dwellings can be accommodated within the City’s administrative area. This leaves a shortfall of 37,900 homes including 14,400 affordable homes (that will need to be delivered elsewhere within the Greater Birmingham Housing Market Area). The BDP stipulated that Birmingham’s unmet need was to be met by other authorities in the HMA as and when they produced individual Local Plans. This has not happened.
Birmingham City Council has now commenced a review of its Local Plan and consulted on Issues and Options for a draft Plan concluding in December 2022. The Issues and Options document advised that the Standard Method housing requirement for the period 2020 to 2042 is 149,286 dwellings. The Issues and Options consultation document suggests that the total capacity for development within the built up area of the City is 70,871 dwellings. This relies upon all SHLAA sites coming forward for development and the provision of a significant number of windfalls (the windfall sum is 11,675 dwellings). This would result in a housing shortfall in the City of 78,415 dwellings.
Black Country Core Strategy Review
Previously, the four Black Country authorities had been preparing a Joint Plan although this has now subsequently been abandoned in favour of the preparation of individual Plans for each authority. Notwithstanding the above, the Preferred Options Black Country Plan proposed a housing requirement based upon the Standard Method which was the sum of the four individual authority housing requirements. The housing requirement for the four authorities was 76,076 dwellings, however, there was only an identified capacity of 47,837 dwellings leaving a shortfall of 28,239 dwellings to be directed to other authorities. Now, each authority will calculate its own housing requirement using the standard method calculation. The requirement in Sandwell is 29,773 dwellings, however, Sandwell claim only to have capacity to deliver approximately 11,167 leaving a shortfall of 18,606 dwellings. The positions in Wolverhampton and Walsall have not yet been published although it is anticipated that there will be a further shortfall in what is required against the capacity within these two authorities.

Overall Shortfall
If the housing shortfall figure identified in Policy PG1 of the BDP and the emerging shortfalls in both the Dudley and Sandwell Preferred Options are added together it totals 57,582 dwellings. If the shortfall arising in Dudley and Sandwell is added to the emerging shortfall identified in the Birmingham Issues and Options this increases to 98,097 dwellings. As noted above, this has the potential to increase even further when any shortfall arising in Wolverhampton and Walsall is added. This is a substantial number of homes and represents a substantial number of people and families that will go without homes should a definitive solution not be found.
Where will the housing shortfall arising from Dudley be met
Paragraph 24 of the Framework confirms that Local Planning Authorities are under a duty to cooperate with each other on strategic matters that cross administrative boundaries. Paragraph 26 goes on to state that joint working should help to determine where additional infrastructure is necessary and where development needs that cannot be met wholly within a particular area could be met elsewhere. The level of unmet need arising within the HMA is one such area where the Duty to Cooperate should be employed in order to determine where this unmet need should be directed.
Having regard to the Greater Birmingham Housing Market Area there are 14 authorities within it which include Birmingham, the four Black Country authorities and 9 other surrounding authorities. In light of the shortfall arising in Birmingham, Dudley and Sandwell this effectively leaves 11 remaining authorities where the need could be distributed.
Turning to each of the remaining authorities it is highlighted above that there is potentially a shortfall that will arise in both Wolverhampton and Walsall when they come to publish their Preferred Options Local Plan. Redditch Borough is effectively built up to its boundary and already has to look to its adjoining neighbour, Bromsgrove, in order to accommodate its housing need. It would be unable to accommodate any further unmet. Similarly, Tamworth had to look to its adjoining neighbours of Lichfield and North Warwickshire in order to meet its current housing requirement in its adopted Local Plan. It too would be unlikely to be able to accommodate any unmet need arising. Cannock Chase’s capacity is restricted due to environmental constraints including the Cannock Chase’s SAC and AONB. A small part of Stratford-upon-Avon District falls within the Housing Market Area whilst North Warwickshire have previously committed to delivering 3,790 dwellings to meeting Birmingham’s needs up to 2031 in its adopted Local Plan (2021). Solihull’s Local Plan is currently at examination and is on hold awaiting publication of the updated Framework and currently proposes approximately 2,000 dwellings to meet the needs of Birmingham. If the Plan progress towards adoption in its current form there would be no scope to seek any increase in the size of the contribution from Solihull until such time as they commenced a further review.
This effectively leaves Lichfield, South Staffordshire and Bromsgrove as the three remaining authorities that would be able to make any meaningful contribution to meeting housing needs arising in the wider HMA. However, a review of what these local authorities has been proposing to help meet the housing shortfall across the HMA falls woefully short of what is needed.
South Staffordshire have previously proposed to accommodate 4,000 dwellings to meet the needs arising in the Black Country. Lichfield were proposing around 2,000 homes before withdrawing their plan. Bromsgrove has yet to publish a draft plan and so it is yet to state how many dwellings it may be prepared to accommodate. Collectively this equates to less than 12,000 (plus the homes that Bromsgrove may provide) and on the face of it will fall woefully short of addressing the housing need of local people and families across the HMA.

The outcome of the above is that there is a significant unmet housing need arising principally from Birmingham and Sandwell, with Walsall and Wolverhampton likely to add to this, and at the current time there is no agreement or clear strategy between the 14 HMA authorities as to where or how this unmet need is to be met. Furthermore, in the few authorities that have the ability to assist in meeting the overspill, with land available around the conurbation to assist with meeting the housing overspill no agreement has yet been reached with them.
It is clear from the above that the emerging position across the HMA is one where there is a significant housing need that exists, but where certain authorities, such as Sandwell and Birmingham and to a lesser extent Dudley, cannot currently meet its needs in full. Redrow contend that these needs must be met by the HMA authorities in the next round of plans that are now being prepared. If this need is not met in full, it risks giving rise to a number of significant knock on effects on the delivery and provision of housing across the Greater Birmingham area. These impacts include:
•
worsening affordability as demand outstrips supply,
•
worsening delivery and provision of affordable housing,
•
increased homelessness
•
Worsening overcrowding and living conditions,
•
Increased pressure on private rental sector with associated issues of unsecure tenancies and susceptibility to rent increases,
•
Increasing ageing population with resultant increase in demand on social and health care services,
•
economic impacts on the working age population as those adults who are able to work may not have suitable accommodation to live in thus resulting in increased commuting distances, worsening impacts on congestion and air quality, and
•
the inability to attract workers into the HMA could have significant repercussions for the wider economy if the right type of houses are not available for those wanting to live and work in the conurbation.
Next Steps
In light of the Council's need and the shortfall that the Council is faced with, Redrow urge the Council to first consider how it can first meet its own needs with land within its own administrative area first before looking to go cross boundary. If it is confirmed that there is no other alternative other than to look to adjoining neighbours the Council are urged to enter into constructive and productive discussions with the other HMA authorities, including South Staffordshire, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.
It is our view that the focus for addressing the shortfall in Dudley should be in Dudley first but then in the authorities closest to them such as South Staffordshire, who have a meaningful ability to address the shortfall with land available adjacent to the conurbation.
We trust you take our comments into consideration and we look forward to being notified of further stages of consultation on the Local Plan. If you have any questions or need to discuss please do not hesitate to contact me.

Comment

Representation ID: 286

Received: 21/12/2023

Respondent: Redrow Homes Limited

Agent: Harris Lamb

Dudley Local Plan Preferred Options Consultation
Response by Redrow Homes Limited
Harris Lamb Planning Consultancy are instructed by Redrow Homes Limited (‘Redrow’) to submit representations to the Dudley Local Plan Preferred Options consultation. Redrow is currently promoting a site for residential development in South Staffordshire which is also in the same HMA and wish to submit comments in respect of the Dudley Plan. Whilst Redrow’s interests are not explicitly located within Dudley Borough the way the Dudley Plan is currently draft will have a number of repercussions on the delivery of housing across the wider HMA. It is within this context that Redrow’s representations are submitted and you should read our comments in this context.
A shortfall in meeting Dudley’s needs
The development strategy set out within the Dudley Local Plan is to meet the Borough’s housing needs on previously developed land within the urban area. The Standard Method housing requirement for Dudley is 11,954 dwellings however there is only currently capacity to accommodate 10,876 of these. There is, therefore, a shortfall of 1,076 dwellings which are needed but which the Council is unable to accommodate within its own administrative area. The Plan is not currently proposing to release land from the Green Belt and whilst the recently updated National Planning Policy Framework (‘the Framework’) removes the requirement to review the Green Belt, the fact that it has a shortfall in the amount of housing that is needed against which it can currently provide will mean that the shortfall of 1,076 dwellings will have to be accommodated elsewhere within the HMA in adjoining authorities if housing needs are to be met in full. Paragraph 11b) still states that strategic policies should, as a minimum, provide for the objectively assessed needs for housing and other uses, as well any needs that cannot be met within neighbouring area. South Staffordshire as one of the closest adjoining authorities with a strong functional relationship to Dudley would be one such location where additional housing could be accommodated if needed.

Redrow consider this to be an unsound approach largely on the basis that if the 1,076 dwellings have to be provided elsewhere, this will reduce the availability of any alternative capacity to meet the needs of other authorities in the HMA that have much a greater unmet need, which will effectively be competing with Dudley for this capacity, when the Council has available Green Belt land within its own administrative area that it could use but which has chosen not to release. In looking to adjoining neighbouring authorities it is highly likely that if they were to agree to accommodate any of Dudley’s needs it would have to be on Green Belt
land. Clearly, if this is the case then it should be demonstrated first that Dudley has exhausted all sources of potential land within its administrative area first, including Green Belt land, before looking cross boundary. If there is no alternative then Dudley will need to work with adjoining authorities and agree with them to meet its needs. South Staffordshire, due to its close functional relationship with Dudley would be an ideal location for where new housing could be provided that would help meet Dudley’s needs.
A significant wider unmet need exists
The shortfall of land for housing is not unique to Dudley and is a long-established concern within the HMA.
Birmingham Development Plan
The Birmingham Development Plan (“BDP”) was adopted in January 2017. Policy PG1 – Overall Levels of Growth, advised that 89,000 dwellings are required during the course of the plan period (2011 to 2031) to meet the growth requirements of the City. However, only 51,100 additional dwellings can be accommodated within the City’s administrative area. This leaves a shortfall of 37,900 homes including 14,400 affordable homes (that will need to be delivered elsewhere within the Greater Birmingham Housing Market Area). The BDP stipulated that Birmingham’s unmet need was to be met by other authorities in the HMA as and when they produced individual Local Plans. This has not happened.
Birmingham City Council has now commenced a review of its Local Plan and consulted on Issues and Options for a draft Plan concluding in December 2022. The Issues and Options document advised that the Standard Method housing requirement for the period 2020 to 2042 is 149,286 dwellings. The Issues and Options consultation document suggests that the total capacity for development within the built up area of the City is 70,871 dwellings. This relies upon all SHLAA sites coming forward for development and the provision of a significant number of windfalls (the windfall sum is 11,675 dwellings). This would result in a housing shortfall in the City of 78,415 dwellings.
Black Country Core Strategy Review
Previously, the four Black Country authorities had been preparing a Joint Plan although this has now subsequently been abandoned in favour of the preparation of individual Plans for each authority. Notwithstanding the above, the Preferred Options Black Country Plan proposed a housing requirement based upon the Standard Method which was the sum of the four individual authority housing requirements. The housing requirement for the four authorities was 76,076 dwellings, however, there was only an identified capacity of 47,837 dwellings leaving a shortfall of 28,239 dwellings to be directed to other authorities. Now, each authority will calculate its own housing requirement using the standard method calculation. The requirement in Sandwell is 29,773 dwellings, however, Sandwell claim only to have capacity to deliver approximately 11,167 leaving a shortfall of 18,606 dwellings. The positions in Wolverhampton and Walsall have not yet been published although it is anticipated that there will be a further shortfall in what is required against the capacity within these two authorities.

Overall Shortfall
If the housing shortfall figure identified in Policy PG1 of the BDP and the emerging shortfalls in both the Dudley and Sandwell Preferred Options are added together it totals 57,582 dwellings. If the shortfall arising in Dudley and Sandwell is added to the emerging shortfall identified in the Birmingham Issues and Options this increases to 98,097 dwellings. As noted above, this has the potential to increase even further when any shortfall arising in Wolverhampton and Walsall is added. This is a substantial number of homes and represents a substantial number of people and families that will go without homes should a definitive solution not be found.
Where will the housing shortfall arising from Dudley be met
Paragraph 24 of the Framework confirms that Local Planning Authorities are under a duty to cooperate with each other on strategic matters that cross administrative boundaries. Paragraph 26 goes on to state that joint working should help to determine where additional infrastructure is necessary and where development needs that cannot be met wholly within a particular area could be met elsewhere. The level of unmet need arising within the HMA is one such area where the Duty to Cooperate should be employed in order to determine where this unmet need should be directed.
Having regard to the Greater Birmingham Housing Market Area there are 14 authorities within it which include Birmingham, the four Black Country authorities and 9 other surrounding authorities. In light of the shortfall arising in Birmingham, Dudley and Sandwell this effectively leaves 11 remaining authorities where the need could be distributed.
Turning to each of the remaining authorities it is highlighted above that there is potentially a shortfall that will arise in both Wolverhampton and Walsall when they come to publish their Preferred Options Local Plan. Redditch Borough is effectively built up to its boundary and already has to look to its adjoining neighbour, Bromsgrove, in order to accommodate its housing need. It would be unable to accommodate any further unmet. Similarly, Tamworth had to look to its adjoining neighbours of Lichfield and North Warwickshire in order to meet its current housing requirement in its adopted Local Plan. It too would be unlikely to be able to accommodate any unmet need arising. Cannock Chase’s capacity is restricted due to environmental constraints including the Cannock Chase’s SAC and AONB. A small part of Stratford-upon-Avon District falls within the Housing Market Area whilst North Warwickshire have previously committed to delivering 3,790 dwellings to meeting Birmingham’s needs up to 2031 in its adopted Local Plan (2021). Solihull’s Local Plan is currently at examination and is on hold awaiting publication of the updated Framework and currently proposes approximately 2,000 dwellings to meet the needs of Birmingham. If the Plan progress towards adoption in its current form there would be no scope to seek any increase in the size of the contribution from Solihull until such time as they commenced a further review.
This effectively leaves Lichfield, South Staffordshire and Bromsgrove as the three remaining authorities that would be able to make any meaningful contribution to meeting housing needs arising in the wider HMA. However, a review of what these local authorities has been proposing to help meet the housing shortfall across the HMA falls woefully short of what is needed.
South Staffordshire have previously proposed to accommodate 4,000 dwellings to meet the needs arising in the Black Country. Lichfield were proposing around 2,000 homes before withdrawing their plan. Bromsgrove has yet to publish a draft plan and so it is yet to state how many dwellings it may be prepared to accommodate. Collectively this equates to less than 12,000 (plus the homes that Bromsgrove may provide) and on the face of it will fall woefully short of addressing the housing need of local people and families across the HMA.

The outcome of the above is that there is a significant unmet housing need arising principally from Birmingham and Sandwell, with Walsall and Wolverhampton likely to add to this, and at the current time there is no agreement or clear strategy between the 14 HMA authorities as to where or how this unmet need is to be met. Furthermore, in the few authorities that have the ability to assist in meeting the overspill, with land available around the conurbation to assist with meeting the housing overspill no agreement has yet been reached with them.
It is clear from the above that the emerging position across the HMA is one where there is a significant housing need that exists, but where certain authorities, such as Sandwell and Birmingham and to a lesser extent Dudley, cannot currently meet its needs in full. Redrow contend that these needs must be met by the HMA authorities in the next round of plans that are now being prepared. If this need is not met in full, it risks giving rise to a number of significant knock on effects on the delivery and provision of housing across the Greater Birmingham area. These impacts include:
•
worsening affordability as demand outstrips supply,
•
worsening delivery and provision of affordable housing,
•
increased homelessness
•
Worsening overcrowding and living conditions,
•
Increased pressure on private rental sector with associated issues of unsecure tenancies and susceptibility to rent increases,
•
Increasing ageing population with resultant increase in demand on social and health care services,
•
economic impacts on the working age population as those adults who are able to work may not have suitable accommodation to live in thus resulting in increased commuting distances, worsening impacts on congestion and air quality, and
•
the inability to attract workers into the HMA could have significant repercussions for the wider economy if the right type of houses are not available for those wanting to live and work in the conurbation.
Next Steps
In light of the Council's need and the shortfall that the Council is faced with, Redrow urge the Council to first consider how it can first meet its own needs with land within its own administrative area first before looking to go cross boundary. If it is confirmed that there is no other alternative other than to look to adjoining neighbours the Council are urged to enter into constructive and productive discussions with the other HMA authorities, including South Staffordshire, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.
It is our view that the focus for addressing the shortfall in Dudley should be in Dudley first but then in the authorities closest to them such as South Staffordshire, who have a meaningful ability to address the shortfall with land available adjacent to the conurbation.
We trust you take our comments into consideration and we look forward to being notified of further stages of consultation on the Local Plan. If you have any questions or need to discuss please do not hesitate to contact me.