Support

Representation ID: 22373

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Policy HOU1 – Delivering Sustainable Housing Growth sets out minimum targets for future housing growth by each BCA up to 2039. RSL fully support this approach and acknowledge the important statement at Paragraph 6.4 which recognises that in the context of the Plan area and nature of its housing land supply, it is essential that a balanced range of sites is provided in terms of size, location and market attractiveness, as this will help maximise housing delivery over the Plan period.

Whilst RSL concur that it is useful for Tables 3 and 4 to provide details of the likely housing land supply components and their associated indicative phasing over the Plan period, all of which have been informed by reasonable assumptions, it is critical to ensuring a constant supply of housing is delivered throughout the Plan period that these targets are indicative as this provides sufficient flexibility, particularly in view of the nature of a large proportion of the supply within the urban area which typically suffers from multiple delivery constraints. Realistic assumptions and ensuring a portfolio of sites are allocated will be essential in ensuring a steady supply of land for housing is brought forward from the outset following adoption of the BCP to ensure the housing trajectory remains on target. As detailed within Appendix 17 of the BCP, even based on delivering only 63% of the Plan area’s housing need, annual housing delivery will need to achieve a significant uplift from that which has been achieved in recent years.

It is noted that at paragraph 6.12, some respondents at the Issues and Options stage suggested that a sequential approach that prioritised sites in the urban area should be adopted. Conversely, it is also acknowledged that given the scale of housing need within the Black Country, phasing of sites outside the urban area might not be possible. RSL support the approach taken in the BCP of only providing indicative phasing and minimum targets which has been fully informed by a detailed analysis of individual sites. Any form of restriction on the delivery of housing sites is more than likely to have the effect of significantly reducing the scale of housing delivery, particularly in the early years of the Plan period.