Comment

Representation ID: 22404

Received: 11/10/2021

Respondent: RCA Regeneration Ltd

HOU1 – Delivering Sustainable Housing Growth
2.4. The BC authorities aspire to deliver 47,837 new homes over the course of the plan period 2020 to
2039. We welcome this as a minimum target.
2.5. 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 Walsall 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.
2.6. 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.

2.7. At 7,657 (Table 3), we consider the windfall allowance to be high – it represents around 16% of the
total housing target for the plan period, which is a considerably proportion. Given the
requirements of the NPPF, we consider the plan is at risk of not being ‘positively prepared’ given
this (we feel) overreliance on unallocated housing in the emerging plan. Paragraph 71 of the
NPPF sets this out clearly: ‘Where an allowance is to be made for windfall sites as part of
anticipated supply, there should be compelling evidence that they will provide a reliable source
of supply. Any allowance should be realistic having regard to the strategic housing land
availability assessment, historic windfall delivery rates and expected future trends. Plans should
consider the case for setting out policies to resist inappropriate development of residential
gardens, for example where development would cause harm to the local area.’