Object

Representation ID: 44770

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

In terms of the proposed supply, there are a number of sources which are proposed on existing vacant or occupied employment land (6% of the total proposed supply). This approach significantly risks the NPPF’s requirement for the plan to provide a sufficient supply of employment sites, as well as for housing supplies to only include land with a realistic prospect that it is available and could be viably developed. It also contradicts the plan’s objective to support economic growth.

The above is not a new approach. The Black Country Core Strategy (BCCS) also allocated a total of 16,182 homes on occupied employment land. Based on the Urban Capacity Review Update (May 2021) only 679 (4.2%) of those homes have been delivered to date (with less than five years of the plan period remaining).