The Black Country’s next top model

The Government has gone to great lengths to standardise the approach to assessing housing needs in the National Planning Policy Framework (2021) [NPPF] and has made it quite clear that unmet needs should be met in neighbouring areas. However, there is no single, definitive, approach either to compel an adjoining authority to take on board that need, nor to determine the proportion of unmet need that they should seek to accommodate.

Whilst the GBBCHMA’s approach began with an evidence-led whole-HMA approach, with the 2018 Strategic Growth Study (’the 2018 SGS’) being commissioned to assist in quantifying and distributing the regions unmet housing needs, many authorities have – politically – distanced themselves from the outcomes of the study.

Although there are emerging contributions proposed, fundamentally there has not been a consistent or coordinated approach that has been used to define and test the appropriate level of unmet housing need which should be addressed.

By way of example, Solihull has taken a capacity-led approach to determine its contribution to Birmingham’s unmet needs. In contrast, the recently adopted North Warwickshire Local Plan considered the proximity, connectivity and strength of functional inter-relationships with Birmingham; an approachwhich the Inspector supported. This was similar to the approach taken in distributing Coventry’s unmet needs across the Coventry & Warwickshire HMA. Again, the Inspector for the Stratford-on-Avon Core Strategy (2017) endorsed this approach.

With acute shortages forecast until 2039 at the minimum, there is a cogent need for the GBBCHMA authorities to work together to address this matter in an efficient, sustainable and appropriate way, underpinned by a robust evidence base.

 

So, how can this strategic and cross-boundary issue be addressed? It would be illogical to meet these needs markedly beyond the GBBCHMA, as the Stratford-on-Avon Inspector noted. It is also clear that a ‘fair share’ approach is unlikely to solve this issue, as many of the GBBCHMA authorities are nearly as constrained as those authorities declaring unmet housing needs in the first instance. Lichfields considers that a functional relationship approach is the best place to start, and to this end, prepared this report to identify how the unmet needs of the Black Country could be distributed based upon the functional relationships between the authorities (please note - this is not an ‘Objectively Assessed Needs [OAN] report).