Object
Draft Black Country Plan
Representation ID: 43863
Received: 05/10/2021
Respondent: Taylor Wimpey
Agent: Pegasus
7.1 The preamble to the chapter identifies that the provision of sufficient land to promote sustainable housing growth is the cornerstone of delivering cohesive, healthy and prosperous communities across the Black Country. It also indicates that the policies in the Plan ensure the provision of a balanced range of housing in terms of type, tenure, wheelchair accessibility and affordability. The supporting text does not, however, refer to the need to provide a range of housing sites in differing locations in order to meet the needs of the population as a whole. This factor is a key part of providing a balanced range of housing and should be referred to explicitly in the text.
7.2 Policy HOU1 relates to delivering sustainable housing growth. It sets out that sufficient land will be provided to deliver at least 47,837 (net) new homes over the period of 2020-2039. Taylor Wimpey supports the reference to both net new homes and also that the housing land supply will deliver 'at least' 47,837 new homes.
7.3 However, Policy HOU1 does not refer to the fact that the housing need for the Black Country collectively amounts to 76,076 homes across the Plan Period (4,004 per annum). The fact that the Plan only intends to provide 47,837 dwellings leaves a significant 28,239 dwelling shortfall that the Plan is proposing to apportion via the duty-to-cooperate. Reference should be made to the shortfall and the means by which this housing supply shortfall could be made up, particularly in the event that the full extent of the shortfall cannot be accommodated through agreement with neighbouring authorities.
7.4 Paragraph 6.4 sets out that a balanced range of sites had been provided within the Plan in terms of size, location, and market attractiveness, which will help to maximise housing delivery over the plan period. This recognition of the need for variety in location and market attractiveness is supported by Taylor Wimpey and should be referenced within Policy HOU1 as it is considered to be integral to the overall housing strategy.