Comment

Representation ID: 21204

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy HOU2 – Housing Density, Type and Accessibility

Policy HOU2 recognises that the density and type of housing to be provided on any housing site will be informed by (i) sub-regional and local needs, (ii) access to sustainable transport methods and (iii) the need to achieve high quality design. Insofar as (i) is concerned, our Client considers it will be important to maintain flexibility to allow for changing local market circumstances. In this regard, it will also be important to ensure that housing mix prescriptions are determined in line with up-to-date evidence.

Paragraph 125 of the National Planning Policy Framework states:
“Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site.”

This policy also states that plans should contain minimum density standards for city and town centres and other locations that are well served by public transport, and that the use of minimum density standards should also be considered for other parts of the plan area and that it may be appropriate to identify a ‘range’ of densities that reflects the accessibility and potential of different areas.

The Black Country is a highly constrained District, in terms of Green Belt boundaries and other constraints, and Taylor Wimpey therefore appreciates that available land will need to be used in the most efficient way to ensure that the BCAs are able to meet their future housing requirements. Taylor Wimpey, therefore, as a matter of principle, support the range of minimum net densities set out in Policy HOU2 of between 40 dph and 100 dph.

Notwithstanding this, high densities will not be appropriate in all proposed housing locations, for example in previously developed land within the Green Belt, or sites which are within close proximity to national designated sites i.e. SSSIs etc. Densities should therefore be considered on a site-by-site basis, taking into account local circumstances.

Part 5 of the policy also states that further details of design requirements for housing developments may be set out in Supplementary Planning Documents. If such a document is to be produced, it is essential that it is prepared in parallel with the BCP so that any cost implications can be properly viability tested in conjunction with other policy requirements to ensure that it will not have any detrimental impact upon scheme delivery.