Support

Representation ID: 22127

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy HOU2 (Housing Density, Type and Accessibility)
In principle, Brockmoor Properties Limited generally support Policy HOU2 (Housing Density, Type and Accessibility), however the draft policy as currently worded could be clearer and more effective for future residential development proposals.

The draft policy promotes flexibility over the plan period for housing types to be assessed on a site-by-site basis which is important in the dynamic housing market and specific locational requirements. Part 3 of this draft policy however, states that the range of house types and sizes should be 'in line with the most recently available information' and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"Developments of ten homes or more should provide a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as:

The Black Country HMA 2021 (or any subsequent revision): or
Detailed Local Housing Market Assessments (where applicable); or
Current and future demographic profiles: or
Locality and ability of the site to accommodate a mix of housing: or
Market signals and local housing market trends."

Additionally, paragraph 6.20 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "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", This is not however referred to in the policy wording itself nor does the HMA provide evidence that all four authorities will be undertaking further HMA assessments. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text need to be clear about which evidence is to be used to inform housing mix and the wording suggested above would assist in removing ambiguity in the policy. Paragraph 6.20 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.