Object

Representation ID: 44815

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

6.8 The Black Country authorities have evidently made a set of assumptions in relation to the housing capacity and deliverability of certain sources of supply, relied upon in the Draft BCP. This report has assessed the proposed sources of supply and identified significant concerns with the assumptions being relied on, with a clear absence of any up-to-date and robust evidence. In some areas the Councils’ assumptions are not rigorous enough, the evidence base is inadequate to draw out the conclusions being relied on, and in our opinion the justification provided falls short given the context and scale of the implications of misjudging the true amount of housing supply.

6.9 Setting realistic delivery assumptions, as required by the NPPF, is essential as planning harm arises when delivery does not come to fruition. This is evident in the Black Country, where there has been clear issues in delivering sites previously identified in the Black Country Core Strategy (BCCS). Despite this, the Councils seek to simply roll forward the approach taken in that previous plan, with little scrutiny or regard to the effectiveness (or not) of that strategy. This report highlights that:

• In relation to non-implementation of commitments, the Councils seek to lower the opposed discount rate based on entirely inadequate evidence, and we propose a reduction of 695 homes to this source in the plan period;

• The Councils rely on existing allocations from previous Plan documents, which are not subject to review through the BCP but have evidently struggled to come forward in the preceding decade. We therefore propose a reduction of 4,973 homes to this source in the plan period;

• The Councils rely on a significant amount of supply from currently occupied employment land, on which there is patently no reasonable prospect that development will come forward at the point envisaged considering the local delivery track record on employment sites, and the wider economic context. The Councils’ strategy on these sites may contradict the wider context in the NPPF which also seeks to ensure a sufficient supply of employment sites. We propose a reduction of 3,091 homes to this source in the plan period; and

• The Councils rely on a significant number of dwellings in Wolverhampton City Centre, where upper floor conversions of retail units are expected to come forward at a given rate. There is no compelling evidence to include this windfall allowance in the BCP supply, and we therefore suggest removal of the entirety of this source (812 homes) in the plan period.
6.10 Based on the above, we conclude that the Draft BCP exaggerates the housing supply that is likely to come forward from its identified sources, by almost 10,000 homes. Unless additional sites are identified, this could lead to the provision of only 38,266 homes over the plan period, or 2,014 dwellings per annum, which is barely half of the identified minimum need for housing in the Black Country. With this report showing that even delivering in line with the proposed requirement would have negative consequences for the area, it follows that these consequences would be even more pronounced if delivery were to be lower still.

6.11 In progressing the BCP, the Black Country authorities are encouraged to fundamentally reconsider the proposed approach to housing provision, adding to and scrutinising the identified supply with the aim of further boosting delivery and meeting housing needs in full.