Comment

Representation ID: 23288

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Part 1.(a) of policy CSP1 states that during the course of the Plan Period “at least” 47,837 net new homes will be provided in the Black Country. However, the housing target of 47,837 dwellings will not deliver the total number of houses that are required. Table 2 – Black Country Development Strategy 2020- 2039, of the draft Plan identifies a need for the development of 76,076 dwellings. The residual requirement of 28,239 dwellings will be directed to other local authority areas through the Duty to Cooperate. This approach has been adopted due to a lack of suitable additional sites to allocate for development within the Black Country.

We have a number of concerns with the overall housing requirement identified in the Plan and the sources of housing land supply that have been identified to meet the target. This has consequential implications for the quantum of development that will be needed to be exported to other local authority areas.