Comment

Representation ID: 43931

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Infrastructure
3.26 At the current stage of the preparation of the draft BCP, it is acknowledged that the
evidence base is still being prepared, and this is particularly true with regards to
infrastructure.

Policy DEL1 (infrastructure provision)
3.27 The Councils need to be cautious with their approach to viability given the scale of
brownfield land in the proposed supply. The draft BCP is highly dependent upon
development in the existing built-up area (40,117 dwellings) and brownfield sites
(81%). The Black Country’s Viability & Delivery Study (September 2021) confirms that
65% of urban typologies tested are marginally viable (27%) or unviable (38%). This
Councils must grapple with this matter as part of the plan and in identifying its
proposed supply.