Object

Representation ID: 44795

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Current supply – 5% discount on commitment and sites under construction

5.2 The current supply source is broken down by source/phasing and local authority below.

See attachment for Table 5.1:BCP Current Supply by Period


See attachment for Table 5.2:BCP Current Supply by Local Authority


5.3 The Councils have adjusted the BCCS discount rate of 10% on sites under construction and which have planning permission, to a lesser rate of 5%. The stated justification for the change is based only on data from Wolverhampton City and is absent of data from the three other authorities. This is considered to be insufficient evidence to warrant a

significant change in approach which affects a large proportion of the Councils’ supply (12,638 homes under construction or sites with PP or PA).

5.4 Worse still, the data obtained from Wolverhampton City Council only covers a period from 2001 and 200427. The Council then assert that of the 1,246 homes granted permission in that period, 96% had been built out in the subsequent 17 years.

5.5 This does not constitute rigorous evidence to justify the significant change proposed. There is clearly a significant data gap here – the assessment period is very short, and from almost two decades ago, in a different policy context and market conditions. This data gap must be addressed before robust conclusions can be made on what the true level of non-implementation has been in the Black Country.

5.6 The Councils should provide evidence on what the non-implementation rates have been in all of the four Black Country authorities, across a practical period, preferably more up to date and comprehensive than considering planning applications granted only between 2001 and 2004. If this evidence is not forthcoming, the Councils should revert to at least the 10% non-implementation rate on sites under-construction.

5.7 The Councils’ supply from committed sites and those sites under construction, when a 10% non-implementation discount is applied, reverts to (13,270 - the full stock of permissions without a discount applied), 11,943 homes in the plan period, a reduction of 695 homes in the plan period.