Savills : Impact of Standard Method approach on the West Midlands local plan process

For plan-making, there is a transition period for the authorities where this uplift applies. Authorities already at Regulation 19 stage have 6 months from 16th December 2020 to submit their Local Plans for Examination without applying this uplift. Authorities which are very close to publishing their Regulation 19 plan, will be given 3 months from 16th December 2020 to publish it, as well as a further 6 months from the date they publish the Regulation 19 plan to submit their plan for Examination.

The expectation from the Government is that the uplift will be met by the top 20 cities and urban centres themselves rather than the surrounding areas, with priority given to brownfield land and optimising densities to promote the most efficient use of land. In the West Midlands Birmingham, Coventry and Wolverhampton are included in the top 20 cities and urban centres list. These locations, like several others in the top 20, are already experiencing issues with meeting their housing needs within their own administrative boundaries.

The standard method 35% uplift takes Birmingham's annual need from 3,577 dwellings to 4,829 dwellings (against an adopted plan target of 2,555 dwellings), Coventry's annual need from 1,722 dwellings to 2,325 dwellings (against an adopted plan target of 1,230 dwellings) and Wolverhampton's annual need from 750 dwellings to 1,013 dwellings (against an adopted plan target of 694 dwellings). Each of these authorities will now need to plan for almost double the housing they are currently planning for in their adopted plans.

The current plans for Birmingham and Coventry were adopted in 2017 with shortfalls of 37,900 dwellings and 14,000 dwellings respectively (to be met within their wider Housing Market Areas). Full agreement has not yet been reached on how Birmingham's shortfall would be delivered within the surrounding authorities. The emerging Black Country Plan review (which includes Wolverhampton) has also proposed that the Black Country authorities are unable to meet their own housing needs.

Birmingham, Coventry and Wolverhampton are not at, or very close to, Regulation 19 stage and will therefore need to address the standard method requirement, including additional uplift, through the current review of their adopted plans.

There are currently insufficient available and deliverable brownfield sites within these three cities to meet the 35% uplift unless further significant opportunities for change of use / regeneration of the existing urban area can be identified. Whilst brownfield land opportunities and increased densities in appropriate locations within these urban areas can continue to form part of the housing land supply, we consider that there will still be a need to review potential Green Belt and/or other greenfield land opportunities both within these authorities and within the surrounding areas.

The approach to meeting this increased need will therefore also need to be considered through the plan reviews in the surrounding authorities (of which only Solihull, Lichfield and North Warwickshire are currently close to or beyond Regulation 19 stage).

The challenge is therefore working out how West Midlands authorities could collectively meet the increased need for the 3 urban areas whilst also meeting their own local need and ensuring that sufficient homes can be delivered and not just planned for. Can this be achieved without using Green Belt?