Comment

Draft Black Country Plan

Representation ID: 23586

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

4.3 WDL have significant concerns that despite these housing figures only meeting the minimum need required, as they are not based on the most up to date emerging evidence, the figures underestimate both need and deliverability leading to a significant shortfall. We do not in these representations seek to interrogate the housing numbers or the approach taken by the Council in relation to the level of housing accommodated in the Plan (WDL has done this through a joint submission with other developers prepared by Turleys attached as Appendix 1). However, what this does highlight is the need for the allocated sites to be fully supported by the Council to enable them to be carried forward through the Plan process and any barriers to development or restrictions on deliverability minimised.