Synopsis

1. In commenting on the Birmingham Development Plan, the Lichfield Civic Society wishes to ensure that:
   
   a. there is an unambiguous basis for assessing Birmingham's unmet housing need^[1] which is clearly distinguishable from its housing shortfall^[2];
   
   b. that a uniform evaluation process should be applied across all local authorities in the "Greater Birmingham Housing Market Area" to see the most sustainable locations for additional housing; and
   
   c. that in considering further Green Belt land releases, the "exceptional circumstances"^[3] test should be applied consistently across all local authorities in the Greater Birmingham Housing Market Area.

2. Birmingham City Council has pointed out that local plan reviews "by definition would include any further revision(s) to the Green Belt"^[4] [Our emphasis]. We suggest that what applies in the rest of the Greater Birmingham Housing Market Area also applies to Birmingham.

3. The Birmingham Plan proposes to deliver less than 60% of its assessed housing needs within its own boundaries. The shortfall across the housing market area is over 34,000 homes, circa 17% ^[5] below the expected level of household growth. Almost all of that shortfall arises in the Birmingham sub-market (see Table 2 and Figures 1 and 2 in the full response). We note that proposed full modifications to the Tamworth Local Plan, which has a housing shortfall^[6] of 19%, make explicit policy adjustments to the Spatial Strategy Policy (SS1)^[7] and to the Green Belt Policy (EN2)^[8].

4. Given the scale of Birmingham's unmet housing need we feel a similar approach to Tamworth is justified. Accordingly we propose that:
   
   a. explicit provision should be made within Policy PG1 (Overall Levels of Growth) for an early plan review, should the SHNS findings suggest that strategy/policy changes could allow Birmingham's housing delivery target to be raised above 51,000 homes;
   
   b. there should be an early review of the Birmingham Development Plan if the SHNS process proves incapable of making a substantial a substantial contribution to reducing Birmingham's unmet housing needs; and
   
   c. it should be recognised that further necessary revision(s) of Green Belts may arise from any plan review, i.e. within Birmingham and elsewhere.

5. It is clear that, despite incorporating main modifications PMM2, the Birmingham Development Plan still fails to meet the full objectively assessed need for housing in the housing market area^[9]. The shortfall is substantial and the SHNS process is unproven, so there is a significant risk that it will not produce the required number of additional homes in an acceptable timeframe.

6. The Lichfield Civic Society does not believe that proposed main modification PMM2 rectifies the unsoundness of the submitted plan. We have suggested a revised wording, as set out in paragraphs 18 to 21 of the statement (see full response).

   Consultation Comments

   Objectively Assessed Housing Needs (OAHN)

7. The Lichfield Civic Society does not believe that proposed main modification PMM2 rectifies the unsoundness of the submitted plan. We believe that the Strategic Housing Needs Study (SHNS)^[10] can play a useful role in addressing unmet housing needs across the Housing Market Area. We also believe that Birmingham City Council should be given the opportunity to demonstrate that this is a practical mechanism to address it unmet housing needs. However, we suggest that PMM2 be amended to ensure that the Birmingham Development Plan be subject to an early review to (a) incorporate any strategy/policy changes that are identified by the SHNS (and are applicable to Birmingham) and (b) that the plan as a whole is subject to an early review should the SHNS fail to adequately address Birmingham's unmet housing need.

8. We note that the Inspector's interim findings state:

   • The Council's Housing Market Assessment^[11] did not fully comply^[12] with the requirements of the NPPF;
     
     
   • That the Council accepts that the Strategic Housing Needs Study (SHNS) "provides a sounder basis ... for assessing the housing need in Birmingham and across the Housing market Area"^[13];
     
     
   • That Birmingham's housing market area comprises 14 local authorities, which the SHNS phase 3 report has sub-divided into the Birmingham sub-market (Birmingham, Bromsgrove, Cannock, Lichfield, Redditch, Solihull, Tamworth, North Warwickshire & Stratford-on-Avon) and the Black Country sub-market (Dudley, Sandwell, Walsall, Wolverhampton & South Staffordshire).
   
   

9. The impact of proposed main modification PMM2 is that the Objectively Assessed Housing Needs (OHAN) shortfall, across the entire Housing Market Area (as defined in the paragraph above), is over 34,000 homes - see table 2 (full response). This deficit is over 15% of the Housing Market Area's expected growth of 24,000 households (2011-2031) and over 40% short of the 89,000 homes that Birmingham City Council says it needs over the plan period (2011-2031).

10. Planning Policy Guidance advises that household projections published by DCLG should provide the starting point estimate of overall housing need^[14]. We consider the reference data to be DCLG Table 406^[15]. As shown in Table 2.1 (full response), the SHNS phase 3 report purports to represent household growth data in Table 2.1, but overstates the rate of growth by 6,314 homes. While this is a small distortion in relation to the aggregate level of household growth of over 200,000 households, it is significant in relation to shortfall between housing demand and housing supply (of circa 35,000 homes) - see Table 2 (full response) and Table 2.2 of the SHNS phase 3 report. We trust the Examination will clarify the actual extent of unmet housing need.

References

[1] Birmingham's unmet housing need = Birmingham's housing shortfall minus surplus provision elsewhere in the HMA

[2] per PMM2 the housing shortfall [37,900 homes] = housing need [89,000 homes] minus housing target [51,100 homes]

[3] NPPF paragraph 83

[4] refer to letter from Waheed Nazir, Birmingham City Council, dated 20th March 2014

[5] calculated as: 34,648 / 204,168 = 16.9% (refer to Tables 1 and 2 of the full response)

[6] calculated as: 825 / 4,250 = 19%

[7] Tamworth Local Plan, Main Modification MM26

[8] Tamworth Local Plan, Main Modification MM27

[9] NPPF paragraph 47

[10] A joint study being undertaken by the Greater Birmingham and Solihull Local Enterprise Partnership

[11] Examination document EXAM H2

[12] paragraph 3; Inspector's interim findings, 05/Jan/2015 - Birmingham Development Plan Examination

[13] paragraph 5; Inspector's interim findings, 05/Jan/2015 - Birmingham Development Plan Examination

[14] PPG Ref. 2a-015-201 40306

[15] DCLG Table 406: Household projections by district, England, 2012-2037

Lichfield Civic Society
October 2015