Comment

Representation ID: 23227

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy HOU2 – Housing Density, Type and Accessibility

Density

Three density categories have been identified – 40, 45 and 100 dwellings per hectare. As the policy is drafted, these categories are one of three considerations that go into determining what density and type of dwellings are appropriate for different sites across the Black Country. The other two factors are the range of type and size of accommodation, and high-quality design and amenity.

In practice, the implications of the other two categories are that, in the most cases, this is going to result in the density reducing below the target in the categories. There are always exceptions to the rule, but the average densities will be lower than the targets in the categories.

The nature of the housing market in the Black Country is that there is limited demand for apartments. We would expect these to be delivered in the ‘very high’-density areas, where this product becomes more attractive. In the ‘high’ and ‘moderate’ density areas the pressure from the development industry will be to deliver housing. This is what the demand is for and apartments on housing sites are just not attractive when there will be houses near by that can be purchased for the same/less money.

Our comments on the impact of design are set out above under policy CSP4 and demonstrate that high-quality design will need to be rethought if the target densities are to be met. Our fundamental concern is that historically, seeking to achieve better design has pushed densities down, which conflicts with the desire to increase densities. It will need to be demonstrated that these are not competing objectives.

There are other competing policy objectives when it comes to increasing densities. These are the requirement for NDDS and M4(2) and M4(3) under Policy HOU3. In our submissions earlier this year we highlighted that we work with, and have spoken to, most of the major developers who operate across the Black Country. In doing so all of these developers confirmed that they did not currently deliver house types to meet these standards in the Black Country. This includes affordable housing developers, with Homes England accepting 85% NDDS for grant applications. Introducing these standards will increase house sizes and this is not compatible with higher densities.

In terms of M4(2), this tends to have the biggest influence on 3 / 4 bedroom units, because it requires a wet room down stairs, which cannot be delivered within the existing footprint when all other factors are considered. This will further increase the footprint of the dwellings going forwards.

None of the above is to say that the target figures in the density categories should be reduced. After all, the Framework requires us to make the most of previously developed sites and there is no harm in driving for higher densities.

However, when it comes to establishing what a realistic capacity of the sites is within the existing urban area, we do not consider it is appropriate to use these target densities. The average density will be lower than this. By applying these target figures, this will inflate the capacity figures and under-represent the need for sites to be release elsewhere and fundamentally not lead to the enough homes and jobs being built/delivered for local people