Comment

Representation ID: 23292

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Sources of Housing Land Supply

Table 3 – Black Country Housing Land Supply Indicative Phasing 2020-2039, identifies the various sources of housing land supply. We have a number of concerns with the sources of supply, including:

• Sites with Other Commitment – The sites in this category are expected to deliver 3,802 dwellings during the course of the Plan period. It is understood from the Black Country authorities SHLAAs that an “other commitment” is a site with a resolution to grant planning permission but the Section 106 has not been signed. This source of supply is discounted by 10% in order to allow for non-delivery.

It is not clear from the draft Plan how the 10% discount rate has been calculated. However, it is noted that the SHLAAs (eg. Walsall SHLAA 2019 paragraph 17) advise that Other Commitments are discounted by 10% as the adopted Black Country Core Strategy (“BCCS”) applied a discount rate of 10% to commitments. It is advised that a discount rate that is based on past trends may not be an appropriate way of establishing future delivery rates. Housing delivery in the Black Country has been affected by the 2008 recession and a number of government initiatives for improving future delivery, such as help to buy and ISA for first time buyers.

Whilst this may be the case, we would also suggest that it is equally unreliable to take a discount rate from the adopted BCCS, which was published in 2011. The BCCS is in excess of ten years old, and its supporting evidence documents even older. At the very least, a past trends based analysis should be undertaken in order to see if the discount rate is robust for the Other Commitments category. Furthermore, it is not clear whether sites with a resolution to grant planning permission, but the S.106 has not been signed, where the resolutions are several years old have been included. If the resolution to grant planning permission is more than 6 months old the site should not be included as a source of supply.

• Existing Housing Allocations in Strategic Centres
• Occupied Employment Land
• Green Belt sites
• Other Allocations
• Additional Site Capacity in Strategic Centres