Object

Representation ID: 23216

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Density

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.

Conclusion

In conclusion, we are concerned that the identified sources of supply will be incapable of meeting the housing requirement identified by the Plan. In addition, given the housing requirement should be a minimum there is clearly a distinct advantage in erring on the side of caution, and applying robust and realistic lapse rates to the various sources of supply as if additional housing does come forward this will be of no detriment to the Plan. However, a housing delivery shortfall has the potential to be extremely problematic, causing five-year housing land supply issues, failing the Housing Delivery Test and failing to provide much needed market and affordable housing within the Black Country for those that need it.