Object

Representation ID: 44797

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Current supply – 10% discount on existing allocations

5.8 A total of 4,973 new homes are identified as being deliverable from this source of supply over the new plan period (2020-39) with the largest contributions to supply coming from Dudley (2,506 homes) and Wolverhampton (2,248 homes).

5.9 The ‘Existing Allocations’ included in this source of supply are stated by Table 4 in the Draft BCP as to be located in defined Strategic Centres.

5.10 As a result of being located in Strategic Centres, these sites are allocated in the subsequent Area Action Plans (AAPs) that were intended to deliver the strategic policies for those areas of the BCCS. As far as we can tell, there is no new evidence in relation to them in the Draft BCP. The sites are not, for example, listed individually in the Draft BCP but do appear in the SHLAA.

5.11 The evidence in relation to the deliverability of these sites is therefore included in the AAPs, within which (from our assessment) there is limited evidence of developer involvement or justification/explanation that the allocations were sound, developable or deliverable.

5.12 There are numerous examples in the supporting evidence base and documentation where it is acknowledged by the Councils themselves that there are possible constraints including land ownership, viability, need to relocate existing uses and remediation issues. This immediately casts doubt on whether the sites can be considered developable, which requires the sites to be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged.

5.13 The BCP Evidence Base includes a Viability and Delivery Study (May 2021), where at para 7.7 it is concluded that:

“The analysis also excludes housing development in Strategic Centres, given that the BCP will not allocate land in the Strategic Centres. No specific sites have been identified in those centres for the purposes of this assessment. The viability assessment above has however found that development there is unviable, even with zero developer contributions. Without grant support therefore, it is likely that no housing – either market or affordable – would be delivered in the Strategic Centres. The viability assessment does not consider what level of grant would be required to make development viable in the centres - because each strategic centre scheme is likely to be unique, with its own set of challenges and subject to site-specific assessment.”

5.14 This is a critical finding when considering whether these sites can be relied on to be developed in the plan period.

5.15 Turley have analysed the status of existing allocations in the Councils’ evidence base and consider each authority area in turn below.