3. Development Strategy

3.12-3.19 Duty to Co-operate

It is recognised that Sandwell’s geography provides particular challenges as regards meeting identified housing and employment land needs within its own boundaries. The shortfalls identified are significant, and the impact on other authorities within the Housing Market Area are expected to be considerable. As a general principle, Sandwell Council is encouraged to fully explore all reasonable options in order to meet as much of its own identified need as possible.

The South Warwickshire authorities note that any overspill of unmet housing or employment needs brings with it a need for additional infrastructure in the areas accommodating this overspill, in order to meet the needs of residents and businesses. As such, it is anticipated that any future considerations regarding accommodating overspill within the South Warwickshire area will also need to address these additional infrastructure needs.

3.77-3.85 Green Belt

It is acknowledged that the Green Belt in Sandwell protects a relatively limited area of valuable open space within a heavily urbanised area. As such, it is agreed that it would not be appropriate to seek to release Green Belt land for development in Sandwell.

7. Sandwell’s Housing

7.12-7.13 Windfall Development

Given the shortfall in housing sites for allocation, Sandwell Council should act to maximise the amount of new housing that can come forward on windfall sites, and in particular, on existing residential sites. This could be through the development of design codes which set out ways to appropriately densify existing residential areas, for example through infill, additional storeys, sub-division, or replacement dwellings.

7.14-7.22 Housing Density, Type and Accessibility

The principle of establishing minimum densities for new housing, based on location and proximity to services and public transport, is supported. However, it is suggested that the baseline densities are in some cases inappropriately low, given the existing development pattern. It would be expected that many of Sandwell’s historic Victorian terraces would have densities well in excess of 40 dph, which demonstrates that family housing can be successfully accommodated while optimising densities.

It is also anticipated that calculating the appropriate density for an application site could be complicated and subject to challenge from applicants. There is potential ambiguity existing around whether a particular facility should be used to determine accessibility, what mode of transport to use, and what distances could be reasonably covered by that mode of transport. It would be clearer and simpler if the Council included on its policies map zones where different minimum densities would apply. For example using buffer distances from public transport and town centres.

8. Sandwell’s Economy

8.7-8.11 Providing for Economic Growth and Jobs
Given the shortfall in available employment land, Sandwell Council is encouraged to ensure that efficient use is made of the land that is available. While it may not be possible to require a minimum density as happens with housing land, there may be other ways to maximise the economic benefit from employment land.

Vision and Spatial Strategy for Sandwell
3.2 Turning to the proposed vision for Sandwell, the second to last paragraph on page 35 of the consultation document, seeks to ensure that by 2041:
“There is a wide range of housing available to Sandwell residents, aiming to help meet housing needs, designed to support green living and suitable for adaptation to benefit all sections of the community. Affordable, social, and local authority-provided homes are available to those who need them. New developments are located within attractively landscaped areas, with access to district and low-cost energy and heating projects, sustainable drainage designed to improve the local environment as well as provide reliable protection against flooding and run-off and all necessary services and facilities within walking and cycling distance or a short bus ride away.”
3.3 Wain Estates support the broad intentions of this part of the vision, with regards to helping to meet the wide range of housing needs within Sandwell, supporting green living and being located in close proximity to local services and facilities via sustainable transport modes. However, within the associated Priorities, Strategic Objectives and Policies set out within Table 3 to support this vision, there is no recognition of the chronic shortage in housing provision to date and how a marked change in strategy will be required to try and address both the historic shortfalls and future demands. Instead, Objective 6 – Housing to Meet all Needs is relatively generic and indicates there is no proposed change in approach or strategy for new development, particularly the provision of housing.
3.4 Reference is then made to the relevant emerging policies which support the capability to meet this objective and help deliver the vision for Sandwell. Wain Estates are of the view that if these policies are progressed as proposed, they do not provide the capability to meet objective 6 and the provision of housing to meet all needs, including the borough’s chronic shortfall in both affordable and market housing, which is a fundamental part of the proposed vision for Sandwell.
3.5 The principle emerging policy which demonstrates this inability to meet the basic housing needs of Sandwell, as established via their own objectively assessed needs (OAN) is Policy SDS1 – Development Strategy. This emerging policy proposes to deliver at least 11,167 net new homes over the 2022 -2041 plan period. However, this 11,167 figure is minimal when compared to the identified housing need of 29,773 new homes throughout the same time period, identifying a shortfall of 18,606 homes.
3.6 As a percentage, the proposed supply in the draft plan represents just 38% (rounded) of the borough’s total housing needs. This is unacceptable, in both the immediate context and historic undersupply, but also when looking at the wider national level and Government objectives enshrined within the NPPF, particularly at paragraph 60 which requires the supply of homes to be “significantly boosted” and importantly that a sufficient amount and variety of land can come forward where it is needed and to ensure the needs of groups with specific housing requirements are addressed. Due to this, difficult decisions need to be made with regards to the proposed spatial strategy, including consideration of Green Belt land release, without which is artificially restricting the development potential within Sandwell.
3.7 The starting point of a new Local Plan cannot be the continued chronic under-provision of housing, such that the exist delivery issues will be further exacerbated. As evidenced by the latest Housing Delivery Test Result (2021 measurement, the updated version due for January 2023) – being at just 52%, one of the lowest in the county and automatically evoking the “presumption in favour” and “titled planning balance” when it comes to determining applications. This coupled with the latest Five-Year Housing Land Supply Figures released in October 2023, which have only worsened since the previous year, dropping from 3,092 homes (1.6 years) to 2,850 homes (1.57 years) provides clear evidence that the current spatial strategy is not fit for purpose. This historic underperformance in meeting housing needs, also needs to be viewed within the context of the NPPF’s emphasis on needing to boost the supply of housing, and the clear upward direction of travel of national policy in this respect.
3.8 To help address this shortfall, emerging Policy SH03 Housing Density, Type and Accessibility seeks to provide substantial uplifts to minimum density requirements to maximise on the most efficient use of land. This has resulted in a range from 40dph, to 45dph to 100dph in West Brom, this are much higher than the typical 25-30dph figures. The policy notes that further detailed design requirements will come forward in relation to these densities as part of future Sandwell Design Codes. However, with the growing pressures on development to provide more than just housing, such as the 10% BNG (with onsite provision as a preference), accessibility requirements such as the minimum of 15% provision of part M4(3) dwellings for developments of 10 or more dwellings (emerging Policy SH05), the need for sites of 2ha or larger to provide new unrestricted open space at a minimum ratio of 3.63 hectares of space per 1,000 population on site (emerging Policy SH4W) all place additional demand for space on site, which may mean that the high minimum density standards cannot be met, resulting in an even lower number of housing units being capable of being provided within Sandwell.
3.9 To further help to address the shortfall, Sandwell are proposing to utilise the Duty-to- Cooperate with neighbouring authorities within the same Housing Market Area, or with which Sandwell has a physical or functional relationship. The details of which are to be provided in the Draft Plan Statement of Consultation – which is to be elaborated upon further at the Publication Stage of the plan. This is despite the fact that Birmingham City Council has already said that it does not have enough space to meet its own housing need and might not have enough space to meet its own employment land needs.
3.10 Sandwell note that this approach may only address a small proportion of the identified housing shortfall and therefore if this position remains then further work will be undertaken as appropriate to identify how this shortfall can be addressed. This position is reflected in the supporting Sustainability Appraisal (SA) which concludes that,
“On balance, Option E is identified as the best performing option, assuming that a large proportion of growth under this option would be on previously developed land and within the existing centres, with the benefits in terms of regeneration meaning this option slightly out-performs Option D, although both would not deliver sufficient housing to satisfy the identified need.”
3.11 As part of a wider consortium, Wain Estates has instructed the “Falling Even Shorter: an updated review of unmet housing needs in the Greater Birmingham and Black Country Housing Market Area” report (copy enclosed at Appendix 4). This report finds that the wider HMA has a shortfall of between 34,742 and 40,676 homes up to 2031, 62,373 homes up to 2036, and 79,737 homes up to 2040 based on each Council’s most up-to- date supply evidence. This shortfall will only be exacerbated by Sandwell’s approach, with other HMA authorities likely to be able to make a very limited contribution to Sandwell’s shortfall.
3.12 It therefore is clear that the additional work identified in the SA will be required to meet the housing shortfall, the historic approach to the spatial strategy is being undertaken as part of the emerging local plan, a strategy which was in place for the currently adopted Local Plan, which has resulted in the chronic under delivery of both market and affordable housing.
3.13 Wain Estates are of the view that the scale of Sandwell’s own shortfall alone, beyond considering the unmet needs of the wider HMA, amount to exceptional circumstances for reviewing the Green Belt boundaries. This additional work should therefore begin now and a fresh approach to assessing the capacity for housing within the borough should be undertaken, which includes an assessment of Green Belt sites for potential release.
3.14 The site on land north of Wilderness Lane is a clear example of the availability of such sites, which are not technically constrained, are in an accessible location, provide the ability to offer enhanced access to the open countryside for recreation purposes and also provide housing in the least sensitive areas of the Green Belt (whilst retaining the majority of it), adjacent to existing built form – in this case situated along Wilderness Lane.
3.15 At present, it is concluded that the overall vision and spatial strategy proposed by the emerging SLP would not be effective in meeting the tests for soundness, as set out in paragraph 35 of the NPPF. In particular, criterion (a) which requires plans to be:
“Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is 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.”
3.16 The council by their own admission have submitted a strategy which falls substantially short of providing a strategy which meets their OAN, which should be seen as a minimum requirement within the extract above. Even in meeting the substantially short figures there is a reliance on maximising out housing densities, in an era where development pressures to deliver supporting features beyond just housing – BNG, sustainability measures etc often restrict this capability. The duty-to-cooperate is also proposed to be utilised to account for this unmet need, but there is no clear strategy or commitment from neighbouring authorities that this would be achievable in part or as a whole. This is therefore not a sustainable approach to development and will inevitably result in the very purpose of the SLP – being to promote growth in planned manner, falling away, likely resulting in mass speculative development, in order for housing needs to be met.
3.17 Wain Estates are of the view that exceptional circumstances for reviewing Sandwell’s Green Belt boundaries. A further review of the Green Belt is therefore necessary in order to assess how the boundaries should be amended to maximise the potential for the most sustainable sites.
3.18 An example of this is the land north of Wilderness Lane site, for up to 150 homes, 40% affordable housing, a countryside park and associated infrastructure. This application is currently being determined by the LPA (LPA ref: DC/23/68822), demonstrating both developer intention and deliverability to bring the site forward and how cumulative amendments to the Green Belt can form an important and necessary contribution to meeting the current and future housing needs of Sandwell.
Limitations to Housing Provision for Sandwell
3.19 Turning more specifically to emerging Policy SH01 Delivering Sustainable Housing Growth and the elements which make up the proposed housing supply of 11,167 new homes, Wain Estates also have significant concerns regarding the sources which make up this already insufficient number of homes.
3.20 Within Table 5 of the above emerging policy, the first source of the housing land supply is made up of sites currently under construction (1,060 homes), with planning permission or prior approval (998 homes) and sites with other commitments (61 homes)1. Therefore, 2,119 homes included within the figures, are made up of the current supply.
3.21 The second source is made up of housing allocations, comprising occupied employment land (2,234 homes), other (3,094 homes), sites with planning permission (1,545 homes) and sites under construction (78 homes). Therefore, 1,623 homes included within the housing allocations are made up of current / existing supply (calculated by adding together sites with existing planning permission and sites under construction). Of the remaining allocations, despite the occupied employment land (2,234 homes) having a 15% discount figure applied, in recognition of the fact that there can be multiple delivery constraints, this in itself does not mean that there is capability of the full 2,234 homes to be delivered given that these sites are in active use for employment.
3.22 It has also been demonstrated through the previous Black Country Plan that such approaches are not effective for delivering housing. As part of the Black Country Core Strategy (BCCS) a total of 16,182 homes were allocated on occupied employment land. Based on the Urban Capacity Review Update (May 2021) only 679 (4.2%) of those homes have been delivered to date (with less than five years of the plan period remaining).

1 10 units are also included for Gypsy and Traveller pitches, but this element of the supply is not discussed as part of these representations

3.23 Furthermore, as recognised in our previous representations, not only is the delivery of housing on such sites questionable, but it also reduces the ability for the Council to provide a sufficient supply of employment sites, of which the Council recognise there are also not enough being provided for as part of the emerging SLP. Paragraph 8.11 of the emerging SLP notes that, 143ha of the employment land need arising in Sandwell cannot be met solely within the Borough, and that the unmet need is to be exported to neighbouring authorities, as part of ongoing duty-to-cooperate work, which is yet to be secured.
3.24 It is good practice to ensure that any elements of housing supply included in a council’s figures, are suitable, available, and achievable of being viably developed. Wain Estates are of the view that there has not been enough evidence provided for the proposed allocations on occupied employment land, as a robust element of the housing supply.
3.25 Taking the above into account, only 3,094 homes (see Table 5 Housing Land Supply Sources within emerging Policy SH01) are allocated which are not made up of existing commitments or situated on occupied employment land, this is a very minor figure when compared to both the proposed delivery of 11,167 net new homes over the plan period and even more so when compared to the actual housing need of 29,773 new homes.
3.26 Looking into more detail at some of the proposed allocations, as recognised by the Council when looking at Appendix B of the SLP, they are also not without their constraints and limitations, further demonstrating that the indicative capacity could be further reduced, resulting in an even lower number of housing allocations. For example:
• SH2 (SA 12) Land adjacent to Asda, Wolverhampton Road, Oldbury is proposed for 62 homes, but it has access issues which need to be overcome in order to be deliverable, questioning the suitability of this allocation.
• SH26 (66) Lower City Road, Oldbury is proposed for 73 homes but has constraints including land remediation and site assembly issues, there also only appears to be interest from some land owners looking to bring the site forward, so also potential ownership issues to overcome, questioning the suitability and availability of this land to support an allocation.
• SH25 (SA 65) Bradleys Lane / High Street, Tipton proposed for 189 homes however, this site also has site assembly and land contamination issues to be overcome, it also requires the current owners to find a place to relocate their business before development can come forwards, again questioning the suitability and availability of this land to support an allocation.
• SM2 SA199 Lion Farm Oldbury, is proposed for a mix of uses, including the provision of 200 homes. However, it relies on relocation of 6 sports pitches to the south of borough, which is arguably not a minor feat. This brings into question the availability and achievability of the land to support an allocation.
• SM1 SA 91 Chances Glass Works, is proposed for a mix of uses including 276 homes, this is a heritage led regeneration project given its recognised constraints which are a Grade II listed building, Scheduled Ancient Monument and Galton Valley Conservation Area, the complexity of such a project brings into question the timescales and the potential delivery of the proposed housing numbers, given the statutory protections given to these heritage constraints, again questioning the suitability and achievability of this site to support an allocation.
3.27 The third part of the housing supply is made up of windfall units, a total of 1,868 are being proposed. However, the delivery of this level of homes is questioned when the restrictive nature of windfall provision within the SLP is assessed. Often and as recognised within the NPPF, the provision of windfall units can help contribute to meeting anticipated housing supply needs, where this aligns with compelling evidence, they can provide a reliable source of supply (paragraph 71). Emerging Policy SH01 Delivering Sustainable Housing Growth, does indeed include for an element of windfall provision – some 1,868 homes over the plan period. However, the delivery of such windfall units will be highly restricted given the limitations placed within emerging Policy SH02 – Windfall developments. The policy allows for windfall development on previously developed land without exception, but for greenfield sites, windfall development is only allowed subject to certain conditions. These conditions are:
• That the site is not protected as community open space or
• The site is council owned land surplus to requirements or
• The development of the site will bring an under-used piece of land back into beneficial use and will not harm the environmental, ecological, or historic value of the site and the wider area, in accordance with other relevant policies in the SLP
3.28 The justification text to the policy notes that windfall sites are likely to include surplus public land, small non-conforming employment uses and some residential intensification sites where appropriate. However, greenfield sites are only permitted where they conform with the bulleted list above. Such restrictions are overly onerous and severely limit the capability for windfall sites on greenfield land to come forwards. This is also not in conformity with the definition of windfall development contained within the NPPF (Appendix M – Glossary), which simply states that windfall sites are sites not specifically identified in the development plan. Again, placing unnecessary restrictions on the delivery of housing, for a number that is already significantly below the required capacity.
3.29 The fourth part of the housing supply is made up of additional floorspace in centres (219 homes). This element makes up a very small part of the overall proposed supply figures. It demonstrates the limitations that emerge from seeking to maximise land on brownfield sites, and the misconception that such spaces are often not being utilised to the best of their ability.
3.30 Overall, the elements which make up the already under-delivering housing land supply as part of the emerging SLP are seen to be questionable.
• Firstly, there is a large reliance on existing commitments, as sites with planning permission or already under construction to make up the housing numbers.
• Secondly, the level of allocations which are included on occupied employment sites is high and such sites are known to be slow at delivering and riddled with issues which slow down or prevent the development for more vulnerable residential uses, in addition to the fact they will result in a loss of employment floorspace, for which there is a recognised need within the borough.
• Thirdly, the proposed allocations themselves are not without issues to overcome – such as access, site assembly, land ownership and remediation – which are not insubstantial.
• Finally, the overly restrictive nature of the windfall housing policy means there is a severe limit as to where such sites can come forward and on what type of land, despite the NPPF not stipulating such limitations exist.
3.31 In light of the above, Wain Estates are of the view that exceptional circumstances exist in terms of both the scale of unmet need and the likely under delivery of the proposed supply. It is therefore essential that Sandwell reviews its Green Belt boundaries, to ensure it meets its housing needs in the least sensitive locations.
3.32 It is well evidenced that greenfield land will deliver much quicker than brownfield land, where issues of land assembly and remediation severely delay the delivery of housing. It should also be acknowledged that removing land from the Green Belt can also be offset through compensatory improvements to the environmental quality and the accessibility of remaining Green Belt land as well as providing improvements to Green Infrastructure (GI) provision. Overall, the Council must “turn on all taps of supply” if it is to meet its housing needs.
3.33 As emphasised throughout this representation, an example of this is the land north of Wilderness Lane site, for up to 150 homes, a countryside park and enhancements to existing biodiversity and Green Infrastructure within the area. This site is currently being determined by the LPA (LPA ref: DC/23/68822), demonstrating both developer intention and deliverability to bring the site forward and how cumulative amendments to the Green Belt can form an important and necessary contribution to meeting the current and future housing needs of Sandwell.
Limitations to Affordable Housing Provision for Sandwell
3.34 Turning to affordable housing, which is a key issue in terms of the housing supply within the borough, whereby a chronic shortfall has been identified and has historically only worsened. The 25% requirement figure contained within emerging Policy SH04 represents a 5% increase on the existing requirement, which has not been delivering to the levels expected. This demonstrates that the Council must increase its overall supply, in order to increase the supply of affordable housing.
3.35 Indeed the proposals for land north of Wilderness Lane site include the provision 40% affordable housing, this can viably be done given the site’s greenfield nature. On brownfield sites where additional remediation costs are to be factored into viability considerations, meeting increased and even the basic affordable housing requirements is challenging, demonstrating why Green Belt release of greenfield sites would further assist in meeting the chronic shortfall in both market and specifically affordable housing needs within Sandwell.
3.36 Reference within the policy also notes the aspiration of providing affordable housing through a range of schemes delivering up to 100% funding through grant and other financial sources. However, as reflected in the wording of the policy, this is just that – aspirational. It is likely to be particularly difficult given the already stretched nature of government funding and the lengthy process of applying for such funding.
3.37 Wain Estates suggest that further evidence of the delivery of such schemes coming forward or having funding secured needs to be included within the evidence base to support this policy, in order to make it more robust and increase the chances of such developments coming forward.
3.38 Appendix 1 of the previous representations submitted (see Appendix 1 of this document) contains an Affordable Housing Statement which assesses this issue in further detail.
Exceptional Circumstances for Green Belt Release
3.39 The purpose of plan-making is to be positively prepared and set out a long term vision for the area, in a way that is aspirational but deliverable (paragraph 16 of the NPPF). A plan that only provides for around a third of its housing requirement, using the standard method baseline, cannot possibly meet these purposes or deliver the minimum requirement for housing. This is simply not acceptable and does not represent an effective use of the plan-led system.
3.40 Wain Estates consider that the Council’s inability to meet their own housing need in the midst of a housing crisis, is an important factor that constitutes the exceptional circumstances that justify Green Belt release. As this is a housing focused representation, employment needs are not explored in detail, however it is clear from reviewing the proposed plan that it proposes not only significant unmet housing need but also a significant unmet employment need. This will only be exacerbated by the anticipated loss of current employment sites for housing, as identified within emerging policy SH01 and the 2,234 homes proposed to come forward as allocations on occupied employment land. The adverse consequences of not meeting the basic housing or employment needs, demonstrate the exceptional circumstances which are required to justify Green Belt release.
3.41 The approach to Green Belt boundary reviews is set out in the NPPF at paragraphs 141 and 142. Paragraph 141 states that the policy making authority need to “examine fully all other reasonable options for meeting its identified need for development” before concluding if exceptional circumstances exist to justify changes to Green Belt boundaries. It then goes on to state account needs to be taken for whether the strategy:
“(a) makes as much use as possible of suitable brownfield sites and underutilised land;
(b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
(c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
3.42 As discussed previously, all three of these elements have been included within the proposed spatial strategy, however, are not without their own constraints and when combined, still fall woefully short of meeting the minimum requirements of the identified OAN for Sandwell. This alone demonstrates that exceptional circumstances exist for Sandwell to review its Green Belt boundaries. The release of land within the Green Belt needs to be further explored, to allow for plan-led development in the future, particularly when also coupled with the inability to also meet required employment land needs. For this reason, Wain Estates suggest a further review of the Green Belt is undertaken, to identify the most sustainably located sites, in line with paragraph 142 of the NPPF.
3.43 A clear example of such a site is land North of Wilderness Lane, which is currently pending determination for up to 150 new homes, a countryside park, 40% affordable housing provision and associated infrastructure. The accompanying Green Belt Assessment contained within the LVA supporting the application, concludes that the harm to the Green Belt arising from development on the site would be low. Development of the site would maintain the physical and visual separation of the different parts of the wider suburban area and would have a very limited effect on encroachment on the countryside. Spatial and visual openness would be minimally affected. The significant new Wilderness countryside park will provide new public access to local people, and the habitat value of the site will be enhanced. The compensatory improvements to the land remaining in the Green Belt would be significant. Whilst we recognise that the LVA has been produced for the purposes of a planning application, it demonstrates that the contribution of the site to the purposes of the Green Belt is limited, and it is suitable for release and allocation for residential development.
Proposed Amendments to the Green Belt Policy
3.44 Emerging Policy SDS6 provides guidance for the approach to Sandwell’s Green Belt, which will be applied to any development proposed in the Green Belt once the plan is adopted.
3.45 Criterion 2 of the policy notes that: “Sandwell green belt’s nature conservation, landscape, heritage and agricultural value will be protected and enhanced.” Wain Estates draw issue with this wording, as it implies that the Green Belt is a designation of both environmental and heritage value, this is not the case, it is a spatial designation for which there can also be both environmental and heritage features and designations within it. This type of wording adds confusion to the purposes of the Green Belt and the value placed upon its protection. This is recognised in the supporting text to the policy at paragraph 3.84 which states that:
“While green belt is not itself a reflection of landscape quality or value, large parts of the local green belt are also identified as being of significant historic, environmental and landscape importance.”
3.46 Wain Estates suggest that the policy wording is amended to make clearer the difference between the spatial designation and the purposes of the Green Belt and the distinction between this and environmental and heritage designations, whilst recognising their potential concurrent nature.
3.47 Criterion 3 of the policy states that:
“Opportunities will be taken to improve the value and recreational role of the green belt in Sandwell Valley:
a. through improving safe accessibility for all users;
b. by providing facilities for active and passive recreation (if this preserves the openness of the Green Belt and does not conflict with the purposes of including land within it”
3.48 It must be recognised that in order to improve the value and recreational role of the Green Belt in Sandwell, development will likely need to occur. Land within private ownership is not accessible to the public for these purposes, enhancing access will only come as a compensatory improvement as part of future development proposals through planning applications.
3.49 Providing such improvements would form part of a two-way process of negotiation as part of future planning applications, with the provision of housing potentially acting as an enabler, to allow the council to meet the enhanced recreational role of the Green Belt. This also supports Sandwell’s wider vision, which seeks to increase accessible open spaces, such spaces need to come from somewhere, the Green Belt is a key facilitator for this, however it will not come forward of its own accord.

A substantial shortfall and need to find a definitive solution.

The strategy as presented leaves a shortfall of 18,606 dwellings that cannot be accommodated in the Council’s administrative area. 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.

Redrow would like to implore Sandwell Council to engage with the other authorities within the HMA to find a location to secure the delivery of these 18,606 dwellings. As will be demonstrated below, the housing shortfall has reached critical levels across the HMA and the onus is on the authorities where the housing need cannot be met to secure the support of the authorities with land available, including Green Belt land, to assist.

Meeting the needs of all part of the population

The pressure to find a definitive solution to address the housing shortfall, is only further emphasised by the fact that the delivery of affordable housing on those sites within the Sandwell administrative area will fall woefully short of the affordable housing need identified. The Black Country Housing Market Assessment Report (March 2021) identified a need for 4,605 social rented properties and 1,913 shared ownership dwellings (accounting for nearly 24% of the total housing requirement). The release of Green Belt sites in the HMA to meet the overspill from both Sandwell and Dudley will deliver not only market, but much need affordable homes for those parts of the population that most need it.

Supporting Economic Growth

Delivering the right number of homes, in the right location is an important component in fostering economic growth. For Sandwell, this means securing the delivery of homes as close to and / or in locations well connected to Sandwell as possible. The obvious location being South Staffordshire, when you account for the adjoining authorities not having the capacity to assist with meeting Sandwell’s need. It is Redrow’s view that the starting point should be sites on the edge of the conurbation to provide homes close to where the demand arises and that can provide a range of homes, including more executive homes for the owners of new businesses.

Shortfall in housing land across the HMA

The shortfall of land for housing is not unique to Sandwell and is a long-established concern within the HMA.

Birmingham Development Plan

The Birmingham Development Plan (“BDP”) was adopted in January 2017 and was the first authority in the HMA to conclude it could not meet its housing need within its administrative area. 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 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 Dudley is 11,954 dwellings however, Dudley claims it only has capacity to accommodate 10,876 of these leaving a shortfall of 1,076. 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, which will broadly



align with the shortfall previously identified in the Black Country Core Strategy review when added to the shortfall from Dudley and Sandwell.


Total 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.

Duty to Cooperate and who can assist in meeting the housing shortfall arising from Sandwell

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 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 arise. 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 2000 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, full opportunity of the land available around the conurbation to assist with meeting the housing overspill is not being taken.

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, 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,
• 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 significant shortfall that the Council is faced with, Redrow urge the Council 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 Sandwell should be those authorities closest to them. South Staffordshire as one the closest authorities with a meaningful ability to address the shortfall and with land available adjacent to the conurbation should be a preferred location for directing additional growth.