Object

Representation ID: 44935

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HOU1 - Delivering Sustainable
Housing Growth

11.1 For the reasons set out in our response to Policy CSP1 Taylor Wimpey objects to Policy HOU1 which states that sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020 – 2039.

11.2 Draft Policy HOU1 is unsound as the BCPs own identified unmet housing need has been deferred rather than dealt with, contrary to the Framework (§35(c)), and the Duty to Cooperate has not been fulfilled.

11.3 The BCP has failed to provide sufficient land to meet the minimum housing needs, as per the Framework §11(b), and it will need to ensure that additional housing land is provided through further Green Belt release and the allocation of additional housing sites. In order to ensure that the plan is sound is considered that the minimum housing target for each authority area needs to be increased accordingly.

Housing Land Supply

11.4 In accordance with the Framework (§68 and §76) the BCP should ensure the availability of a sufficient supply of deliverable and developable land to meet the housing needs, ensure the maintenance of 5 Years Housing Land Supply (YHLS) and achieve Housing Delivery Test (HDT) performance measurements.

11.5 Taylor Wimpey notes that the majority of housing growth (40,117 dwellings) will be located within the existing built-up area. The use of brownfield sites has been optimised and BCA have undertaken a densification of existing and new allocations. However, whilst 81% of supply is on brownfield land and only 19% of supply is on greenfield land, there is limited information available from which to assess the robustness of the BCA proposals for the densification of sites in Strategic Centres (over 1,300 dwellings) and on new allocations, and densities may be overly ambitious.

11.6 Table 3 of the Draft BCP suggests that the supply for the period 2022 to 2039 will include 4,973 dwellings on existing allocations in Strategic Centres. We note that these sites are not subject to review in the BCP and there needs to be some assurance that these dwellings are deliverable given that they have been allocated for some time. In this regard, we note the findings of the BCP Viability Study (§7.7) which casts doubt over their deliverability:

“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”.

11.7 The BCP proposes that a total of 7,720 dwellings will be allocated on sites removed from the Green Belt, which are mainly located in the Neighbourhood Growth Areas and the remainder on smaller sites on the edge of the Towns and Neighbourhoods Areas in the form of rounding-off or through the redevelopment of previously developed land. Taylor Wimpey supports the release
of Green Belt land including that released to accommodate Strategic Allocation WSA.2.
However, additional Green Belt release is required for the reasons we have identified in these representations.

11.8 Taylor Wimpey considers it is critical that an accurate assessment of availability, suitability, deliverability, developability and viability is undertaken. The BCA assumptions on lead in times and delivery rates should be correct and supported by parties responsible for the delivery of housing on each individual site.

11.9 The Framework (§71) requires that where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. The windfall allowance of 7,651 dwellings should be robustly evidenced and there should be no double counting between windfall allowances, additional capacity and Wolverhampton upper floor conversions.

11.10 The discounts of 5% for other commitments and existing allocations, 10% for other BCP
allocations, and 10% & 15% for occupied employment land should also be robustly evidenced.

11.11Taylor Wimpey also considers that flexibility needs to be provided in the supply. At present, the supply matches the housing requirement of 47,837 dwelling identified in the Draft BCP. There is no headroom to account for slippage in anticipated delivery rates and additional flexibility needs to be provided in order to ensure that sufficient housing land is provided. The allocation of additional housing land, including Taylor Wimpey’s sites at Chester Road, Streetly and Clent View Road, Stourbridge, would contribute to providing this flexibility. As the BCP is highly dependent upon development in the existing built-up area (40,117 dwellings) and brownfield sites (81% of HLS) and the BCP Viability Study confirms that 65% typologies tested are marginally viable (27%) or unviable (38%), Taylor Wimpey considers that a significant flexibility
allowance is justified.

11.12 We are also concerned that insufficient detailed background information on each site has been provided to allow delivery assumptions to be transparently assessed. The Framework (§74) is clear that strategic policies should include a trajectory illustrating the expected rate of housing delivery over the plan period and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites.. The Housing Trajectories in Appendix 17 of the BCP show projected yearly completions but are not site specific. More detailed site specific evidence should be provided in order that deliverability can be robustly assessed.

11.13 The Framework (§68) requires planning policies to identify specific, deliverable sites to provide a 5 year housing land supply [5 YHLS]. A 5 YHLS Statement has not been provided by the BCA. and if a 5 YHLS cannot be demonstrated on adoption of the BCP and maintained throughout the plan period, the BCP should not be found sound. In addition, it is unclear whether the BCA are wishing to demonstrate 5 YHLS via adoption of the BCP as set out in the Framework (para 74b).

Viability and Deliverability

11.14 Viability will be central to determining the soundness of the BCP. The BCP Viability Study tests the cumulative impact of proposed policies on a representative sample of development site and scheme typologies. It notes that viability and delivery advice in respect of a portfolio of Key Large Sites is provided in a separate confidential report. Taylor Wimpey considers that this information should be provided as part of the BCP evidence base in order that the cost applied for such provision can be properly reviewed to ensure that it is sound.

11.15 The Viability Study concludes that of the total housing capacity tested 38% are assessed as unviable and 27% are assessed as marginally viable based on the original target rates of affordable housing contributions of 30% for greenfield sites and 25% for brownfield sites. In accordance with the Framework (§34), the contributions expected from development including the level & types of affordable housing provision required and other infrastructure for education, health, transport, flood & water management, open space, digital communication, etc. should be set out in the BCP , and development should not be subject to such a scale of obligations that the deliverability of the BCP is threatened. If a robust approach is not undertaken, the BCP will be unsound. Landowners and developers will have to submit site- specific assessments to challenge assumptions in the Black Country Viability & Delivery Study and such negotiations at planning application stage causes uncertainty for both the BCA and developers, which may result in significant delay to housing delivery or even non-delivery.

11.16 We have provided further commentary on viability issues in our representations to individual policies in this report. Further commentary on the BCP Viability Study has been prepared by Bruton Knowles on behalf of Taylor Wimpey and is attached at Appendix 5.

11.17 Before the pre-submission BCP consultation, further viability work should be undertaken to address the concerns raised.

Part 4
11.18 Part 4 of the policy states that Masterplans and Supplementary Planning Documents will be produced, where appropriate, to provide detailed guidance on the development of strategic allocations. Taylor Wimpey considers that this guidance would best be provided in the BCP in order to ensure that sites are genuinely deliverable and the viability implications of any infrastructure provision etc. can be properly considered at examination prior to the adoption of
the plan.