Comment

Representation ID: 22158

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

. We note that in Table 4, there has been a lapse rate allowance of 10% discounted to allow for some sites which may not come forward over the course of the plan. We would like to know whether this truly represents the historic lapse rate pattern, as we are aware of a substantial number of sites within Dudley Borough that have not come forward because of persistent viability problems associated with heritage, site contamination and other issues which include tensions between commercial/industrial land values being similar to those of residential (post• remediation). We are not clear whether this has been considered carefully enough.

Further, the BC authorities propose to 'export' 28,239 dwellings outside of its boundary- but as South Staffordshire Council have just publicised their preferred options Local Plan, it remains the case that they propose to take c.4,000 dwelling as (unmet need), but it is not clear whether this is unmet need from the GBSLEP area, or the Black Country. This needs clarification.