Object

Representation ID: 20981

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Policy HOU2 – Housing Density, Type and Accessibility
Density
Three density categories have been identified – 40, 45 and 100 dwellings per hectare. As the policy is drafted, these categories are one of three considerations that go into determining what density and type of dwellings are appropriate for different sites across the Black Country. The other two factors are the range of type and size of accommodation, and high-quality design and amenity.
In practice, the implications of the other two categories are that, in the most cases, this is going to result in the density reducing below the target in the categories. There are always exceptions to the rule, but the average densities will be lower than the targets in the categories.
The nature of the housing market in the Black Country is that there is limited demand for apartments. We would expect these to be delivered in the ‘very high’-density areas, where this product becomes more attractive. In the ‘high’ and ‘moderate’ density areas the pressure from the development industry will be to deliver housing. This is what the demand is for and apartments on housing sites are just not attractive when there will be houses near by that can be purchased for the same/less money.
Our comments on the impact of design are set out above under policy CSP4 and demonstrate that high-quality design will need to be rethought if the target densities are to be met. Our fundamental concern is that historically, seeking to achieve better design has pushed densities down, which conflicts with the desire to increase densities. It will need to be demonstrated that these are not competing objectives.
There are other competing policy objectives when it comes to increasing densities. These are the requirement for NDDS and M4(2) and M4(3) under Policy HOU3. In our submissions earlier this year we highlighted that we work with, and have spoken to, most of the major developers who operate across the Black Country. In doing so all of these developers confirmed that they did not currently deliver house types to meet these standards in the Black Country. This includes affordable housing developers, with Homes England accepting 85% NDDS for grant applications. Introducing these standards will increase house sizes and this is not compatible with higher densities.
In terms of M4(2), this tends to have the biggest influence on 3 / 4 bedroom units, because it requires a wet room down stairs, which cannot be delivered within the existing footprint when all other factors are considered. This will further increase the footprint of the dwellings going forwards.
None of the above is to say that the target figures in the density categories should be reduced. After all, the Framework requires us to make the most of previously developed sites and there is no harm in driving for higher densities.
However, when it comes to establishing what a realistic capacity of the sites is within the existing urban area, we do not consider it is appropriate to use these target densities. The average density will be lower than this. By applying these target figures, this will inflate the capacity figures and under-represent the need for sites to be release elsewhere and fundamentally not lead to the enough homes and jobs being built/delivered for local people.
Housing mix
The policy also requires that a range of house types and sizes should be provided in new development. We don’t disagree with this objective and agree that delivering the right type and size of houses in the right locations is clearly the right approach to meeting housing needs of the Black Country. However, we object to the policy as written on the basis that it is not the correct way of achieving these objectives as it is an incredibly blunt object for developers to comply with when it comes to delivering the houses that are needed.
Whilst the policy seeks to differentiate between the need for market and affordable housing, another key determinate of where housing is to be delivered is geographical location. Developments in the strategic centres or regeneration corridors are likely to be better served by public transport and existing shops, services and facilities which would lend themselves to higher density developments that could include apartments. An apartment scheme, however, is unlikely to be able to deliver the full mix of dwellings sought in the policy. Whilst NGAs are better placed to deliver a higher proportion of 3- and 4-bedroom dwellings to assist in meeting the target of delivering at least 50% of the dwellings with 3 or more bedrooms. The policy, as worded, does not consider these different market areas and seeks to apply a one size fits all approach to delivering housing in both. This is not a sound approach.

As detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. The emerging plan seeks to adopt a space standard policy which will increase dwelling sizes impacting upon density. It is not unusual, in our experience, for brownfield sites within the Black Country to have constraints that adversely affect density, such as mineshafts or due to their relationship to surrounding uses. In addition, Table 5.10 of the BCHMA, advises that 54% of the housing requirement should be delivered as three or more bedroom properties, with over 25% of the properties required as four bed plus. Larger dwellings take up more space. This will drive down the density that can be achieved. It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will be reduced accordingly.