Comment

Representation ID: 47034

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

The Councils need to be cautious with their approach to viability given the scale of brownfield land in the proposed supply. The draft BCP is highly dependent upon development in the existing built-up area (40,117 dwellings) and brownfield sites (81%). The Black Country’s Viability & Delivery Study (September 2021) confirms that 65% of urban typologies tested are marginally viable (27%) or unviable (38%). The Councils must grapple with this matter as part of the plan and in identifying its proposed supply.