Support

Representation ID: 4318

Received: 21/12/2022

Respondent: Wolverhampton City Council

CWC considers that the SSLP has been prepared in a manner which is legally compliant and meets the Duty to Cooperate. The Draft BCP identified a shortfall of some 28,000 homes to 2039 across the four Council areas. For Wolverhampton, the housing shortfall is substantial at some 7,900 homes. The BCP identifies a shortfall of some 210ha of employment land to 2039, this being the sum of shortfalls across the four Council areas. The EDNA confirms that the Wolverhampton element of this shortfall is between 40ha to 80ha. We do not anticipate that this work will reveal any significant sources of additional land to meet housing or employment needs. Wolverhampton has significant unmet housing need, taking into account capacity in the urban area and limited, sustainable green belt release.

In order to provide certainty for the progression of the WLP and to inform our ongoing Duty to Cooperate engagement with other neighbouring Local Plans, it is critical that a Wolverhampton element of the 4,000 homes contribution is confirmed as soon as possible. We recommend that migration patterns between South Staffordshire and those neighbouring authorities which can demonstrate unmet housing need would provide a reasonable and robust evidential basis. migration patterns over the period 2002-2019 between South Staffordshire and the Black Country / Birmingham shows that Wolverhampton accounts for 37% of net inflows, Walsall 25%, Birmingham 3%, Sandwell 11% and Dudley 24%. However it is not currently clear if either the Dudley Local Plan or the Walsall Local Plan will generate a residual housing shortfall. It would be appropriate for the 4,000 homes to be divided between Wolverhampton, Sandwell and Birmingham in proportion to their share of historic net migration inflows, with Wolverhampton allocated some 72.5%, or 2,900 homes.

We request that affordable housing provided on these sites should be available to City residents, specifically that 50% of the affordable rent housing secured on the sites is allocated (both at first let and subsequent re-lets) through nomination rights for Wolverhampton residents.

CWC accepts that the contribution of 4,000 homes by the SSLP to the HMA is a reasonable one and should not be increased. The Council supports the SSLP contribution of 100.2ha towards unmet Black Country employment land needs. CWC commit to explore the potential for gypsy and traveller sites in Wolverhampton to help address that unmet need through the WLP process.