Comment

Representation ID: 22561

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy HOU2 – Housing Density, Type and Accessibility

We are broadly supportive of Policy HOU2 with regards to housing types and densities being informed by their location, access to amenities as well as public transport access and choice. We welcome the increase in minimum net density for developments in a Strategic Centre or Town Centre of Very High – 100+ dwellings per hectare (dph) which is a significant increase of 65+ from Table 8 of the adopted BCCS. This clearly takes into account the conclusions made by the Urban Capacity Review 2021 which set out that the centres have an important role to play in accommodating future residential growth, particularly in creating more capacity and enhancing the rates of delivery. Given the importance of the Strategic Centres, Walsall should be systematically and proactively planning for it now via updated Town Centre AAP work which could show clearly how 100+ dph will be achieved across sites in the town centre (given some will be higher and some lower density).

We also note that part 4 of this policy caveats the minimum density requirements “…except where
this would prejudice the historic character and local distinctiveness as defined by Policy ENV5.” .
paragraph 6.16 states “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.”. whilst this may be the case in some circumstances, it is certainly not the case for all sites. The policy does not take any account of footprints of existing sites or typography, which will dictate the level of density which can be provided, as well as heights.

Like much of the Black Country, Walsall Town Centre is not ‘flat’; there are significant changes in typography within relatively short distances. Our Site is elevated above the rest of the Town Centre, as is the Grade II* Listed Church. The existing building on site as a result of the elevation and the change in levels on the site itself, means that the re-use of the existing footprint and building ‘up’ in the only efficient option for development. As a result of this any development on the Site will have significantly higher densities than the current 100+ in the DBCP. Density calculations do not take into account typography and as a result can be a misleading quantitative marker for development if this is the only marker used.

We believe that the current wording of part 4 of the policy does not give sufficient flexibility for development on sites where they are physically constrained by typography/gradient of the land. Such inflexibility goes against the NPPF paragraph 16 (b) of plans to be “be prepared positively, in a way that is aspirational but deliverable”. The policy wording should be amended to remove the word “except” and replaced with wording which is more flexible and allows the LPAs to have the ability to take into account physical constraints which are specific to sites (something which the review of the AAP could do). Wording could be as follows: “…(4) All developments of ten homes or more should achieve the minimum net density set out below. Where this would impact the historic character, or townscape and local distinctiveness as a result of physical layout or constraints, proposals should demonstrate the level of impact on these, as defined in Policy ENV5”.

The suggested working would still connect the need to meet minimum density requirements, and the requirements for proposals to take into account the matters listed in Policy ENV5 and have formed part of the design rationale, with robust evidence to allow LPAs to apply the policy flexibly.