Comment

Representation ID: 21262

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy HOU2 – Housing Density, Type and Accessibility
The policy sets out criteria that housing mix for development sites will be based on which includes being in line with the most recently available information. Paragraph 124 of the NPPF sets out the importance of planning policies to make efficient use of land taking into account: the identified need for different types of housing, local market conditions and viability, the availability and capacity of infrastructure, the desirability of maintaining an area’s character and setting and the importance of securing well-designed and attractive places [Savills emphasis].

The housing mix set out under paragraph 6.20 of the plan sets out the housing needs identified in the BCA Housing Market Assessment (2021). Market demand changes so this ‘latest’ evidence may not be representative of need when planning applications are submitted in the future. As developers and national housebuilders have vested interests in building products that are deliverable and meet market needs, the BCA should not have a fixed size and type guidance, as this could affect development viability, lead to inflexibility and result in obstructing development. We consider that the Housing Market Assessment figures should be used as guidance only and housing mix should be determined on a site by site basis based on market evidence at the time of application submission.

Although we support the Council’s ambition to make the most efficient use of land (NPPF paragraph 125), we do not support the proposed approach to calculating density requirements within this policy. Policy HOU2 has based its proposed density requirements on Table 5, which assesses accessibility through the proximity of the site to local centres, health facilities, shops and education. The Planning Practice Guidance (‘PPG’) sets out a range of considerations which should be taken into account when considering densities for a site or area which includes accessibility to services, as the BCA have assessed but also characterisation studies (urban form and historic character), environmental and infrastructure capacity and market/site viability which the plan has not considered (Reference ID: 66-004-20190722). Additionally, the PPG also states that it is “important to consider how housing needs, local character and appropriate building forms relate to the density measures being used” (Reference ID: 66-005-20190722). We consider that it is important that density is considered on a site by site basis, particularly for proposed allocations which are adjacent to lower density housing such as Site WSA2.

Paragraph 6.18 states that investment will be sought to improve any facilities where there is an identified gap in service provision. We understand that Walsall Council has not received input from health or Education to date to confirm their requirements. Health and education requirements for each site should be confirmed and addressed accordingly within the plan.