Object

Representation ID: 43845

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.6. The BC authorities aspire to deliver 47,837 new homes over the course of the plan period 2020 to 2039. 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 Wolverhampton 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.

2.7. 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.

2.8. 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 o f 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. '