Draft Black Country Plan

(73) 6 Housing

Introduction

6.1 The policies in this chapter will help to create a network of cohesive, healthy and prosperous communities across the Black Country, which is a fundamental element of the vision and objectives and which will deliver the overarching strategic priority and Strategic Priorities 3 and 4. The provision of sufficient land to promote sustainable housing growth is the corner stone of this approach. However, the policies also ensure the provision of a balanced range of housing in terms of type, tenure, wheelchair accessibility and affordability, and sufficient specialist provision for gypsies, travellers and travelling show people and for those who wish to self-build or custom build. New housing will be of a high build quality and well-designed, meeting national space and water efficiency standards, and meeting high levels of energy efficiency and adaptation to climate change, as set out in Policies ENV9 and CC1 - CC6.

6.2 Maximising sustainable transport access to key residential services and focusing high density increases in areas of greatest accessibility is at the heart of the Spatial Strategy, helping to deliver Strategic Priorities 5, 10 and 15. Providing a balanced network of quality education facilities is a further key part of this approach and to delivering economic prosperity.

Figure 4 - Housing Key Diagram

 

Delivering Sustainable Housing Growth

6.3 A key role of the BCP is to set out realistic targets for each BCA to deliver sustainable housing growth over the plan period up to 2039.
 

 

(12) Table 3 - Black Country Housing Land Supply and Indicative Phasing 2020-39

discounted by 5%    discounted by 10%    discounted by 15%

(13) Table 4 – Black Country Sources of Housing Land Supply and Phased Housing Targets for BCA 2020-39

discounted by 5%    discounted by 10%    discounted by 15%
 

(23) Justification

6.4 The BCP identifies sufficient land to provide 47,837 additional homes by 2039. This will deliver a 10% increase in housing stock and will accommodate 63% of current local housing need up to 2039 (76,076 homes) within the Black Country. 81% of supply is on brownfield land and 19% of supply is on greenfield land. The Housing Spatial Diagram illustrates the distribution of larger housing sites across the Black Country. A balanced range of sites has been provided, in terms of size, location and market attractiveness, which will help to maximise housing delivery over the Plan period. Across the BCA, 25%-45% of identified supply is on sites of under 1ha, well above the 10% required in NPPF para 068.

6.5 The detail of housing allocations for each Black Country authority is provided in Chapter 13 and all sites are shown on the Policies Map. Housing capacity has been identified in accordance with the Spatial Strategy and based on the following information:

a) Strategic Housing Land Availability Assessments (SHLAAs) and the Black Country Employment Area Review (BEAR);
b) An estimate of the likely scale of housing renewal up to 2039;
c) An estimate of likely windfall development on small sites up to 2039;
d) An assessment of the likely capacity of strategic centres above existing supply, drawing on the Black Country Centres Study;
e) Application of a density uplift to existing allocations likely to gain permission after 2024, in line with Policy HOU2;
f) A comprehensive Green Belt review and site assessment process, which has identified new sites suitable and available for release for housing development, and deliverable within the Plan period and beyond.

6.6 The housing supply from allocations on occupied employment land has been discounted by 15% in order to take account of the multiple delivery constraints that typically affect such sites and that are likely to reduce delivery on a minority of sites. Delivery constraints include poor ground conditions and the need for large-scale master-planning, land assembly, business relocations and residential service access improvements. The supply from allocations on other land in the urban area and on small (<10 home / 0.25 ha) sites without planning permission has also been discounted by 10% to allow for non-implementation, as some of these sites are also affected by delivery constraints such as poor ground conditions. The supply from sites with planning permission but not yet under construction has been discounted by 5% in accordance with historic lapse rates. These discounts are balanced rates that take account of the likely availability of external funding to address constraints, as set out in the Viability and Delivery Study. Together, these discounts provide sufficient flexibility in the housing land supply to meet any unforeseen circumstances.

6.7 No discount has been applied to allocations on sites released from the Green Belt as evidence indicates that they will not generally be affected by delivery constraints. However, for five larger sites in Walsall (Yieldsfield Farm, Stafford Road; Queslett Road East / Aldridge Road / Doe Bank Lane; Home Farm, Sandhills; north of Coronation Road / Mob Lane; Calderfields, Aldridge Road) where the Viability and Delivery Study has indicated that housing capacity up to 2039 is likely to be limited by market delivery constraints, this has been taken into account when determining the amount of housing that it is estimated the site will deliver within the BCP Plan period. It is estimated that the remaining housing capacity on these sites, which totals 1,715 homes, will be delivered beyond 2039, and will form part of the housing land supply when the BCP is reviewed and the Plan period extended. The projected rate of delivery on these sites will be kept under review during the Plan period and housing supply estimates adjusted accordingly if required.

6.8 The BCP does not make or review allocations within the Strategic Centres. However, additional housing capacity above existing supply is expected to come forward within Strategic Centres over the Plan period, as set out in Tables 3 and 4. Existing allocations will be reviewed, and new allocations made in line with these targets when Local Plan documents covering Strategic Centres are updated, alongside or immediately following adoption of the BCP. A robust small windfall site allowance has been included in the supply, which reflects historic completion rates for sites of less than ten homes. Windfall sites are likely to include surplus public land, small non-conforming employment uses, sites in non-strategic centres and residential intensification sites, subject to policy, sustainability, and detailed site considerations.

6.9 Parts of Dudley have been identified as needing some form of housing market intervention. Selective renewal of the existing housing stock and the surrounding residential environment will help to create more sustainable communities and support regeneration. A combination of renovation, improvement, refurbishment, and / or redevelopment is proposed, to be determined on a site-by-site basis having regard to the most sustainable approach and the needs of the borough and its community. The likely amount of demolition across current Dudley housing renewal sites has been estimated for the purposes of the BCP (see Table 3).

6.10 The Plan period has been divided into three phases, covering five years, ten years, and 15 years from the year of adoption - 2024. Housing targets for each Black Country authority, for each phase, are provided in Table 4. These are based on the Black Country housing trajectory set out in Appendix 17, with further detail provided in the Black Country SHLAAs. The trajectory demonstrates a steady supply of housing completions over the Plan period, justifying consistent housing targets throughout the Plan period.
 

(4) Evidence

• Dudley, Sandwell, Walsall, and Wolverhampton SHLAAs (2021)
• Black Country Urban Capacity Review Update (2021)
• Black Country Employment Areas Review (2021)
• Black Country Viability and Delivery Study (2021)
   

(1) Delivery

• Annual update of SHLAAs
• Review of Local Plans covering the four Strategic Centres
• Housing renewal will be delivered through local authority intervention
• Securing funding to facilitate delivery
• Working with key partners and delivery agencies
   

(7) Issues and Options Consultation Responses

6.11 Many respondents highlighted under-delivery of housing against previous targets and the need to review existing, predominantly brownfield, sources of housing land supply and to identify new sources, including greenfield land and sites in the green belt.

6.12 The need for a sequential approach that prioritised sites in the urban area and did not prejudice their early delivery was generally supported, together with increased external funding to support delivery. However, many acknowledged that, given the scale of housing need in the Black Country, phasing of sites outside the urban area might not be possible.

6.13 There was support for retaining reasonable discounts on sites in the urban area to reflect delivery issues, and the need for robust evidence to support windfall allowances was highlighted.
 

Housing Density, Type and Accessibility

6.14 It is important that the new homes delivered over the plan period are located in places with good sustainable transport access to key residential services and provide a mix of types and densities which are appropriate to their location and help to meet local needs.
 

 

(2) Table 5 - Black Country Housing Accessibility Standards

 

(3) Justification

6.15 Achieving an appropriate density and house type mix is crucial both to the success of each new housing development and the overall sustainability of the Spatial Strategy. It is important that every major development, of ten homes or more, contributes to providing an appropriate house type mix and density, aligned with current local needs. Achieving the right density and mix of house types will also help to protect and improve physical, social and mental health and wellbeing, as set out in the Health and Wellbeing Chapter.

6.16 The accessibility of all housing developments to a range of residential services by walking, cycling or public transport is key to achieving sustainable communities. As higher density developments tend to accommodate more people, they should generally be located in those areas with best access to services, to encourage use of sustainable transport modes. The highest densities of 100 homes per hectare should be in areas with the best access to public transport and services, but also where a high proportion of flats will provide design solutions that best reflect historic character and local distinctiveness. Therefore, such densities will only be acceptable within Strategic Centres and Town Centres. Conversely, lower density developments, accommodating more families, should have enjoy high levels of accessibility to schools. Not all developments with good sustainable access to services will be suited to the highest densities – in some cases a lower density will be more appropriate, for example in areas of historic character, to reflect the density of adjacent uses or to meet the need for a mix of housing types.

6.17 Table 5 provides access standards for differing house type mixes / densities, in relation to four priority residential services: employment, health, fresh food and education. Proxies have been selected for each service. Employment is represented by Strategic Centres and retained employment areas. The proxy used for fresh food is a centre, or an existing food store outside a centre that currently provides a range and choice of fresh food. The access standards have been developed based on survey evidence regarding the distance people are prepared to travel to each service by foot and public transport and are designed to help create well-connected and walkable neighbourhoods. Although open space does not form one of the priority residential services for the purposes of establishing the appropriate density and type of housing, Policy ENV8 taken together with local standards and policies will ensure that a sufficient quantity and quality of different types of open space is available close to where people live.

6.18 Housing developments of ten homes or more will be expected to meet the accessibility standards set out in Table 5, which vary according to density and likely house type mix. Where there is an identified gap in service provision against one or more of these standards, investment will be sought to improve either service provision or access to existing services sufficient to ensure standards are met. New service provision, including for centre uses, should be located, and justified in accordance with Policies CEN5 and HOU5 in particular.

6.19 Current accessibility to residential services by sustainable transport modes across the Black Country has been modelled. This modelling shows the high levels of accessibility achieved by the Spatial Strategy. However, there are some gaps in provision that will need to be addressed through service or access improvements. For strategic allocations, the approach to be taken towards addressing any gaps, for example through service provision on site, is set out in Chapter 13. The model will be updated on a regular basis to reflect changes in service provision and public transport services. Local circumstances, such as planned changes to service provision, will be considered when assessing accessibility on a site by site basis.

6.20 The Black Country Housing Market Assessment (HMA) 2021 demonstrates that new households generated by 2039 will need the following mix of home tenures and types:

It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs for each of the four local authorities, as set out in the HMA.
 

Evidence

• Black Country Housing Market Assessment (2021)
• Black Country Urban Capacity Review Update (2021)
   

Delivery

• Through Local Plan Documents and Supplementary Planning Documents
• Through the Development Management process
   

(6) Issues and Options Consultation Responses

6.21 Respondents generally supported the need to increase densities in strategic centres and areas with good levels of sustainable transport access to residential services, to maximise efficient use of land, where this was in line with national guidance and backed up by robust evidence.

6.22 However, it was also argued that there were limits to market demand for high density housing and that flexibility should be retained to take account of local character and viability issues.

6.23 There were mixed views on the appropriate density for green belt release sites, with some arguing for lower densities than in the urban area and others that densities should be the same.

6.24 There was general support for use of up-to-date evidence, including the SHMA, to inform house type requirements, subject to flexibility to reflect local character and viability issues.
 

Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

6.25 In order to meet local needs, a sufficient proportion of new homes provided over the plan period should be affordable and wheelchair accessible, and enough plots should be provided to meet local demand for self-build and custom build housing. Viability should be taken into account when setting targets

 

(1)
Justification

6.26 Rising house prices and low average incomes over a long period have made market housing increasingly unaffordable for many Black Country households. The Black Country SHMA (2021) identifies a requirement for 15.7% of new homes to be made available for affordable or social rent, 8.3% to be shared ownership and 8.7% to be First Homes. To meet this level of need over the Plan period, 32.7% of new housing would have to be affordable.

6.27 The Viability and Delivery Study demonstrates that viability varies greatly according to local housing values (as set out in figure 5) and whether the site is greenfield or brownfield. Therefore, a sliding scale of affordable housing requirements, ranging from 10% to 30%, has been set out in Policy HOU3 which reflects this variation. This approach should ensure that viability appraisals are not required at planning application stage for the majority of sites. However, viability issues can vary significantly from site to site and are often caused by poor ground conditions, the extent of which cannot be accurately assessed until planning application stage. Therefore, to maximise delivery of affordable housing over the Plan period, it is important that affordable housing is sought on all eligible sites, that viability is assessed on a site by site basis where required, and that a flexible approach is employed wherever possible to allow for changing market conditions.

Figure 5 – Black Country Housing Value Zones

(Source: Black Country Viability and Delivery Study 2021) 

6.28 The tenure of affordable housing required over the Plan period will vary according to local housing need and market conditions and will also be constrained by the requirements of national planning policy. In general, a mix of tenures will be sought on all sites of ten homes or more, to help create mixed communities across the Black Country. However, there may be circumstances where this goal is better achieved through the provision of a 100% affordable housing development to boost affordable housing provision, or through a 100% market housing development with off-site provision of the affordable housing requirement.

6.29 There are currently 153 individuals on Black Country authority self-build and custom build registers, of which 83 are in Dudley, eight in Sandwell, 32 in Walsall and 30 in Wolverhampton. This represents a low level of demand compared to neighbouring authorities. Therefore, to meet the modest need for self-build and custom build plots across the Black Country, developers of larger sites will be expected to make available a small proportion of the development as serviced self-build and custom build plots, as defined in national guidance and legislation. These plots will not form part of the affordable housing requirement for the development. Detailed guidance for the plots, for example on design, will be provided at a local level where appropriate.

6.30 The Black Country authorities will work with partners to meet identified needs to accommodate older people, people with disabilities and those with other special needs. The Black Country SHMA (2021) concludes that 17,866 accessible and adaptable homes, including 1,674 wheelchair user homes, will be required by Black Country households in 2039 due to disability or old age. There is a need for these types of home across all tenures. This implies that a significant uplift will be required to the number of homes that meet these standards currently. Although some improvements to existing homes funded through Disabled Facilities Grants may contribute towards this uplift, the provision of new homes meeting the standards would reduce the need for adaptations to be retrofitted and make the housing stock more responsive to the evolving needs of the local population.

6.31 People's housing needs change as they get older, and homes designed in a way that makes them more easily accessible and adaptable allows people to stay in their own homes for longer. With public health and social care strategies placing more emphasis on supporting people in their own homes rather than moving to residential care it is important that more adaptable and accessible homes are provided. Studies have shown that older properties are generally less accessible, and harder to adapt.

6.32 Accessible and adaptable homes that meet the M4(2) Building Regulations are designed and built to a standard that meets the needs of occupants with differing needs, including some older or disabled people, and are only slightly more expensive to build than standard housing. They must also allow adaptation to meet the changing needs of occupants over time. Homes built to this standard are more flexible and readily adaptable as people's needs change, for example if they have children and require easy access for pushchairs, if they have a temporary or permanent disability or health issue, or as they gradually age and their mobility decreases. Wheelchair user homes that meet the M4(3) Building Regulations are required by less households but involve a significantly increased cost.

6.33 Therefore, all major housing developments will be expected to provide 20% of homes at the M4(2) standard, where this is financially viable. For major housing developments on greenfield sites in medium and higher value zones, where viability is less likely to be a constraint, there will be a requirement for 15% wheelchair user homes at the M4(3) standard, with the remainder of homes required to meet the M4(2) standard.

6.34 The standards will be applied through planning conditions or section 106 agreements, which will require an agreed number of units to be constructed to the specified Building Regulations requirements.

6.35 Policy HOU3 allows for an element of flexibility in recognition of the practicalities of delivering these standards, in particular given the challenges that may arise given the topography of some sites, where access within the gradients specified in the Building Regulations Approved Document may not be achievable. Where step free access to dwellings cannot feasibly be achieved due to site specific factors, the optional standards will not be required for the homes affected. Where multi storey flats or apartments are being developed without lift provision, homes on the first floor or above will not be required to meet the M4(2) or M4(3) standards. Ground floor flats in multi storey developments will still be required to meet the optional standards. Where lifts are provided the standards will be applied in accordance with the Policy.
 

(2) Evidence

• Black Country Strategic Housing Market Assessment (2021)
• Black Country Viability and Delivery Study (2021)
• Dudley, Sandwell, Walsall, and Wolverhampton Housing Strategies
• Dudley, Sandwell, Walsall, and Wolverhampton SHLAA's (2020)
   

Delivery

• Local Plan documents and negotiations with developers through the Development Management process
• Implementation of Housing Strategies
• Securing funding to facilitate delivery
• Working with key partners and delivery agencies
   

(2) Issues and Options Consultation Responses

6.36 There was general support for use of the most up-to-date evidence, including the SHMA, to inform housing tenure requirements. Most respondents supported retention of the 25% affordable housing requirement, and some supported an increased requirement for green belt release sites and reducing the affordable housing threshold to ten homes, where supported by up-to-date housing need and viability evidence.

6.37 Some respondents supported the provision of housing to meet the needs of the elderly, which is addressed through the Policy HOU3 requirement for M4(2) and M4(3) standards.

6.38 Most respondents did not support the introduction of a policy requiring a proportion of self-build and custom build plots on larger housing sites, preferring the allocation of specific targets and/or sites. However, given the low levels of demand in the Black Country, it is not felt reasonable or justified to require certain sites to be reserved for self or custom build.

6.39 The Viability and Delivery Study concludes that the 5% requirement for larger sites will not affect viability and the requirement will be flexible and responsive to local demand.
 

Accommodation for Gypsies and Travellers and Travelling Show people

6.40 The Black Country has small settled communities of gypsies and travellers, and travelling showpeople, and also experiences unauthorised encampments on a regular basis. In accordance with national guidance, the BCP aims to provide sufficient, appropriately designed and integrated sites to accommodate the needs of these communities over the plan period.
 

(2) Table 6 - Black Country Indicative Gypsy, Traveller and Travelling Showpeople Accommodation Targets^[18]

Source: Black Country GTAA 2017
 

(1) Justification

6.41 A Gypsy and Traveller Accommodation Assessment (GTAA) for the BCA was completed in 2017, in accordance with national guidance, and identified the likely future local need for gypsy and traveller and travelling show people accommodation as set out in Table 6. Following completion of a new GTAA during 2021 (which has been delayed due to Covid-19 restrictions), the Publication Plan will use updated information to set targets for the first five and ten years of the Plan period, from adoption in 2024. There have historically been low overall levels of identified need for pitches and plots, reflecting the good record of the Black Country authorities in permitting and delivering pitch and plot sites within the urban area. Therefore, following removal of sites WAGT26 and WAGT27 from the green belt in Walsall, it is anticipated that allocations and permissions will provide sufficient supply to meet targets up to 2029, and small windfalls within the urban area are expected to make up the remainder of targets up to 2034.

6.42 Permanent gypsy and traveller pitches, and travelling show people plots, have fixed infrastructure with all the normal residential amenities, and are used as a base to travel from. They are intended to allow gypsies and travellers to obtain good access to education, health, and other services.

6.43 The GTAA (2017) identified that gypsies and travellers prefer small, family-sized sites with approximately 10-15 pitches, but will accept larger sites if carefully planned and designed in consultation with the gypsy community. Local authorities may assist gypsies and travellers living on their own land without planning permission to obtain retrospective planning permission where this is deemed appropriate.

6.44 Travelling show people have different accommodation requirements to those of gypsies and travellers, and form part of a different community. They require large plots capable of accommodating lorries and equipment, which are more suited to mixed use areas.

6.45 Chapter 13 provides details of sites allocated in the BCP for gypsy and traveller pitches. These sites, together with existing permissions and small windfalls, should provide sufficient pitches and plots to meet the targets set out in Table 6. However, planning permission may also be granted for alternative sites which meet the criteria set out in Policy HOU4, where appropriate.

6.46 The GTAA 2017 identified a need for a transit site or sites to be provided in the Black Country to meet the needs of travellers and help prevent the occurrence of unauthorised encampments. Transit sites have since been provided in Dudley and Sandwell, a transit site has planning permission in Wolverhampton and a potential location for a transit site has been identified in Walsall. Therefore, it is anticipated that any need for transit provision identified in the GTAA 2021 will be capable of being met.
 

(2) Evidence

• Black Country and South Staffordshire Gypsy and Traveller Accommodation Assessment (2017)
   

Delivery

• Allocations in Local Plan Documents and bids for Government funding where required.
• Planning applications determined through the Development Management process
   

Issues and Options Consultation Responses

6.47 Respondents supported the use of pitch and plot targets taken from the GTAA. The National Federation of Gypsy Liaison Groups requested the inclusion of a transit pitch target. However, need for transit pitches has now been exceeded by available and permitted sites across the Black Country.
 

Education Facilities

6.48 A variety of services are required to meet the needs of new residents, including education facilities. It is important that these facilities can be easily accessed by sustainable forms of transport and meet the variety of needs for different age groups and educational needs.
 

 

Justification

6.49 Rising demand for school places in recent years, due to a combination of high birth rates, inward migration, retention levels and housing growth, has resulted in the expansion of a significant number of existing schools and an increased need for new schools across the Black Country. This investment has largely been funded by Local Education Authorities, as housing sites within the Black Country urban area do not demonstrate sufficient viability to provide for their own educational needs.

6.50 Housing growth over the Plan period is likely to generate the need for further investment in education provision for all age groups, including nursery and further and higher education. National guidance sets out the presumption that housing developments will fund the provision of education facilities sufficient to meet their own needs, including the provision of land for the construction of new buildings where necessary. However, the Viability and Delivery Study indicates that depending on the extent of other planning obligations required, this may not be viable on some sites, particularly those located in lower value zones, as shown on Figure 5. Where it can be proved that it is not viable for a housing development to fund all its own education facility needs, the developer should work with the Local Education Authority or BCA concerned to investigate available options and ensure that these needs can and will be met.

6.51 Improvements to existing educational settings should be explored to help address low educational attainment, which is a key priority for the Black Country. It is important that any investment in educational settings is focussed to support centres, address accessibility gaps, generate maximum service improvements and secure community benefits. Increasing community use of school sports facilities would make a major contribution towards meeting open space, sport and recreation standards and improving health through increased sports participation. One or more Supplementary Planning Documents will be produced to provide guidance on the approach towards developer contributions for education facilities across the Black Country.

6.52 The preferred location for major education facilities, which generate a large number of trips, is the network of identified centres. However, there may be cases where a development is isolated from a centre or provision within a centre may not be possible. In such cases the priority, when selecting a location, should be addressing accessibility gaps in accordance with access standards set out in Policy HOU2, to maximise sustainable access to the facility.

6.53 Higher and further education institutions and research facilities, particularly the University of Wolverhampton, play a major role in the Black Country economy and have a key role in helping deliver economic and social transformation. Attracting and retaining graduates within the Black Country is also key to securing a knowledge-based economy. The higher and further education sector is a major driver of economic, social, and cultural regeneration and ongoing investment in the existing network of this sector is supported. Initiatives that strengthen linkages between the sector and the wider economy will also be supported.
 

Evidence

• Black Country Viability and Delivery Study (2021)
• Black Country Infrastructure Delivery Plan (2021)
   

Delivery

• Local Education Authority school expansion and improvement programmes
• National DfE Free School Programmes
• Delivery of new schools on strategic allocations and identification of sites for new education facilities in other Local Plan documents
• Use of planning obligations or other funding mechanisms to address the impact of development on the need for education facilities
• Identification of sites to support implementation of university and college estate strategies
   

Issues and Options Consultation Responses

6.54 Respondents supported the extension of the approach set out in Policy HOU5 to cover health and other community facilities. Policy HW2 takes forward this approach for health facilities.
 

Houses in Multiple Occupation

6.55 In recent years, as house prices have risen in comparison with local wages, the demand for houses in multiple occupation (where facilities are shared by separate households) has increased across the Black Country and now requires a policy approach.
 

 

Justification

6.56 Houses in Multiple Occupation (HMO) are defined as homes accommodating three or more unrelated households who typically share kitchens, lounges, and bathrooms. Proposals for the conversion of an existing home to a HMO designed to accommodate three to six people do not normally require planning permission. However, where a relevant Article 4 Direction is in place, as is currently the case for the City of Wolverhampton, planning permission is required for such developments.

6.57 HMOs are an increasingly popular part of the housing market within many parts of the Black Country. As rooms can be rented individually, they provide additional affordable accommodation options, used primarily by students, young people, and those on lower incomes.

6.58 Whilst the area's stock of HMOs is contributing to meeting housing needs, increased numbers of multiple occupancy properties have the potential to create harmful impacts. Concentrations of HMOs within neighbourhoods can lead to imbalanced and unsustainable communities and harm the social mix and fabric of the area by increasing the proportion of short-term households. They can damage the residential amenity and character of surrounding areas, as the level of activity associated with a HMO is significantly greater than a typical family house, thus increasing the potential for noise and disturbance.

6.59 Harmful impacts associated with high numbers of HMOs can include:

a) reduced social cohesion resulting from demographic imbalance and unsustainable communities;
b) reduced housing choice resulting from housing type / tenure imbalance (e.g. a shift from permanent family housing to more transient accommodation and a growth in the private sector at the expense of owner-occupation);
c) reduced community engagement from residents resulting from an increase in the transient population of an area;
d) noise and disturbance resulting from intensification of the residential use and / or the lifestyle of occupants;
e) detriment to the visual amenity and character of the area resulting from poor or accumulative external alterations to properties and / or poor waste management;
f) reduced community facilities resulting from a shift in the character of shops and businesses;
g) increased anti-social behaviour and fear of crime resulting from the lifestyles of some HMO occupants, the transient nature of the accommodation and inadequately designed / maintained properties;
h) highway safety concerns resulting from congested on-street parking.

6.60 Whilst this type of accommodation can address certain housing needs, HMOs tend to be grouped together in parts of the urban area, becoming the dominant type of housing, which can lead to social and environmental problems for local communities. Alongside this, an over-concentration of HMO properties can lead to a loss of family-sized units. This in turn can lead to a consequential increase in the overall number of units unsuited to family occupation. This can pose a serious issue for maintaining a mixed sustainable housing offer across the Black Country.

6.61 The Black Country SHMA (2021) signalled that the greatest demand in the future will be for homes of three bedrooms or more. It is important, therefore, that an approach is taken to the creation of HMOs and the sub-division of existing properties that only allows those proposals that do not impact upon the overall supply of family-sized homes to be consented. In applying this policy, 'family-sized dwellings' means houses with three or more bedrooms.

6.62 Planning policy needs to balance the growing demand for HMOs with the need to avoid high concentrations which can cause a loss of amenity, increased social or environmental problems, and undermine the health and stability of communities. Ease of access to work and education provision without needing a car also needs to be considered. New HMOs should be located in sustainable locations that allow ease of access to employment and residential services by means of sustainable transport, whilst reducing the need to use the private car. Proposals for new HMOs should look to address detailed local amenity issues, including local parking pressures and impacts on neighbours.
 

Evidence

• Black Country Strategic Housing Market Assessment (2021)
   

Delivery

• Through Local Plan Documents and Supplementary Planning Documents
• Planning applications determined through the Development Management process
   

(1) Issues and Options Consultation Responses

6.63 It was recognised that a concentration of HMOs causes problems in some parts of the Black Country and that guidance could help to avoid these problems in future.
 

Monitoring

^[9] Excluding some sites with planning permission that have been allocated in the BCP to ensure they are not lost to other uses

^[10] Including mixed use allocations that include centre uses and so are not subject to review through the Black Country Plan

^[11] Including 833 homes on identified sites in Walsall Town Centre

^[12] Excluding some sites with planning permission that have been allocated in the BCP to ensure they are not lost to other uses

^[13] Excludes 1,715 homes that it is estimated will be delivered after 2039

^[14] Rounded down

^[15] Or any subsequent national equivalent standard

^[16] Or any subsequent national equivalent standard

^[17] Or any subsequent national equivalent standard

^[18] Pitch targets exclude those living in housing and with a psychological aversion to housed accommodation