Comment

Representation ID: 23588

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

4.0 Policy HOU1 – Delivering Sustainable Housing Growth
4.1 The Plan identifies an overall need for 4,004 dwellings per annum over the plan period (2020-39) – or 76,076 homes in total. While not specified, it is assumed that this has been calculated using the ‘standard method’ for determining ‘the minimum number of homes needed’, as is required in all but ‘exceptional circumstances’ according to the NPPF (Paragraph 61).
4.2 However, the Plan intends to only make provision through Policy HOU1 for 2,518 homes each year, or 47,837 homes in total. The justification for this policy clearly identifies that this will only accommodate 63% of current Local Housing Need up to 2039 within the Black Country. We assume, as it is not stated, that the Council will expect the shortfall of circa 28,198 homes to be met by the neighbouring authorities.
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.
4.4 WDL also note that in addition to the sites already allocated in the Plan, there may be a need to identify additional sites to supplement these figures and to ensure that the Plan is prepared positively. It appears that currently the Plan cannot be found sound on the basis that the Council’s full level of housing need is not being met in its Plan.
4.5 Policy HOU1 provides the total number of houses to be delivered in the Plan period but does not specifically identify any individual housing sites. The proposed housing allocations are shown on ‘Figure 4 – Housing Key Diagram’, and Section 13 of the Plan contains a table setting out the allocations in each area. However, as neither the tables are worded as ‘policy’, nor the individual site descriptions in Section 13 within Policy HOU1 or that the individual site allocations are worded as a separate policy. This will ensure that the Plan is clear, and the individual allocations are accorded the appropriate weight.