Comment

Representation ID: 23293

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Furthermore, as detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. This is on the basis that:

• The emerging plan seeks to adopt a NDSS policy which will increase minimum 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 their capacity and density, such as mineshafts or due to their relationship to surrounding uses.
• Achieving biodiversity net gain could reduce net developable areas.
• On site POS provision could reduce net developable areas.

It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. Site densities should be based on agreed masterplans for the strategic sites as the process is refined, rather than a blanket approach. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will need to be reduced accordingly.