Object

Draft Black Country Plan

Representation ID: 23229

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Representation Summary:

Housing mix

The policy also requires that a range of house types and sizes should be provided in new development. We do not disagree with this objective and agree that delivering the right type and size of houses in the right locations is clearly the right approach to meeting housing needs of the Black Country. However, we object to the policy as written on the basis that it is not the correct way of achieving these objectives as it is an incredibly blunt object for developers to comply with when it comes to delivering the houses that are needed.

Whilst the policy seeks to differentiate between the need for market and affordable housing, another key determinate of where housing is to be delivered is geographical location. Developments in the strategic centres or regeneration corridors are likely to be better served by public transport and existing shops, services and facilities which would lend themselves to higher density developments that could include apartments. An apartment scheme, however, is unlikely to be able to deliver the full mix of dwellings sought in the policy. Whilst NGAs are better placed to deliver a higher proportion of 3- and 4-bedroom dwellings to assist in meeting the target of delivering at least 54% of the dwellings with 3 or more bedrooms. The policy, as worded, does not consider these different market areas and seeks to apply a one size fits all approach to delivering housing in both. This is not a sound approach.