Object

Representation ID: 21436

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

Draft Policy HOU1 (Delivering Sustainable Housing Growth) states that sufficient land will be provided to deliver at least 47,837 dwellings (2020-2039) with the majority of the requirement to be met through sites with existing planning permission and sites allocated for housing. Below we set out our concerns regarding sites identified in the UCS which not only brings into question the reliance that should be placed on the UCS and proposed housing sites identified, but also the identified shortfall of circa 28,239 homes which we consider to be even greater.
We therefore object to draft policy HOU1 and the evidence base used to support it.

Based on the information we have gathered, a list of sites which are deemed to be undeliverable within the plan period has been compiled. Along with Savills Development colleagues (who are active in the Black Country residential land market), we have extended our review of the sites proposed in the UCR to include a view on potential development and viability issues.
From our review of the sites set out in the UCR it is estimated that around 5,000 dwellings are likely to be undeliverable for a variety of planning and deliverability. This figure could be higher should any of the existing employment sites identified for housing not come forward.
We consider that not all sites included within the draft Black Country Plan are deliverable and this juxtaposed with the housing shortfall in the Black Country clearly means that additional sites will be required to meet the Black Country’s housing need. In that regard, we consider that the housing “offers” currently proposed fall significantly short of what is needed to deliver an effective and sound strategy for meeting the Black County (and wider HMA) housing shortfall which is clearly evidenced and significantly worse than is being presented.