Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 635

Received: 16/01/2024

Respondent: Walsall Council

A reduction in the supply of land for housing is proposed compared with the BCP. This
is as a result of the intention not to allocate land that is currently in the green belt within
Dudley. The BCP proposals for Dudley included the provision of housing slightly in
excess of local need to contribute towards the needs of Sandwell, and to a lesser
extent Wolverhampton. The draft Dudley local plan, however, proposes to supply less
than enough to meet local needs, which means that this shortfall will need to be
exported to neighbouring authorities.
As was the case with the BCP, the Dudley local plan also significantly under-supplies
sufficient employment land to meet the borough’s needs, although the proposed
supply is slightly higher than that in the BCP.
A direct comparison with the BCP is not straightforward because the two plans were
intended to cover different time periods, and the need for both housing and
employment has changed since the preparation of the BCP as a result of the way in
which need is calculated, as well as the different time periods for the two documents.
The Dudley local plan however appears to under-state the extent of the proposed
housing supply shortfall.
The BCP proposed that 13,235 net additional homes would be provided in Dudley over
the period 2020-39. The local need under the national standard method was 636
homes per year (2021 basis). This meant that 1,151 homes would have been available
to meet needs arising elsewhere in the Black Country.
The Dudley local plan proposes 10,876 homes over the period 2023-41. Need in
Dudley over this period is 11,954 homes (664 homes per year). The plan states that
this will result in 1,078 homes having to be provided in other authority areas. The
reduction in supply compared with the BCP is effectively this ‘export’ figure added to
the number that are no longer proposed to meet need arising elsewhere in the Black
Country, i.e. 1,078 plus 1,151 or 2,229 homes.
We recognise the local concerns have resulted in Dudley being unwilling to consider
the use of green belt to help meet the need for housing. However, the resulting undersupply
will place additional pressures on the housing supply in other authority areas
and make it more difficult to demonstrate to authorities outside the Black Country thatauthorities within the Black Country have sought to maximise their supply before
seeking to export some of it.
We understand the draft plan was written in the context of the proposed amendments
to the NPPF that were published in December 2022. Amongst other amendments, it
was proposed to delete the reference in paragraph 35 to local plans being “informed
by agreements with other authorities, so that unmet need from neighbouring areas is
accommodated where it is practical to do so and is consistent with achieving
sustainable development.” The Dudley local plan proposes 25ha of additional employment land compared with the 22ha proposed in the BCP. Both these figures are well below the net need of 72ha. This means that 47ha of employment land to serve Dudley will need to be ‘exported’. The supply of suitable land for employment development in Dudley is physically
constrained, so we have no concerns on this topic.
We note that the sustainability appraisal examines three options for housing and two
for employment. Housing options 1 and 2 are rejected on the grounds that they would
not sufficiently meet housing needs in the borough. Paragraph 3.4.1 of the SA report
states that option 3 is selected, as it would address housing need through a balanced
spatial approach. However, table 3.1 states that this option would require a
contribution from duty to co-operate partners towards the potential shortfall, to enable
the total housing need for the borough to be met. Under option 3, the plan itself would
not address the total housing need and delivery of the requisite number of homes
would rely on the plans of other local authorities. We would, therefore, advise that you
review the conclusion reached with regards to option 3.