Comment

Representation ID: 23311

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Policy HOU2 – Housing Density, Type and Accessibility

The policy states that the density and type of housing should be informed by a range of factors. These include the need for and type of new housing required, the level of accessibility of a site to public transport and services and the need to achieve well design development that has regard to the surrounding character of the area. We agree that these considerations are key in determining what the density of new development should be. The policy then goes on to state that all new major development should achieve the minimum net densities set out in Table 5, which range from 40 dph to 100+ dph. Whilst the 100+ dph range is intended to be delivered within strategic centres or close to transport hubs, achieving 40 dph on other sites will present certain challenges, particularly in the context of other policy requirements in the Plan.

A large proportion of the development sites within the Black Country are urban brownfield sites. These can often have constraints that can reduce their net developable area, such as mineshafts or underground infrastructure such as cables and pipes. These sites are often relatively small and are not regular in shape. This makes achieving an efficient layout problematic. This has the consequence of reducing the net developable area and net density.

Policy HOU2 requires that a range of house types and sizes are provided in new developments. The Table on page 100 of the draft Plan confirms that there is a greater demand for 3, 4 and 4+ bed properties than 1 and 2 bed properties. 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 and four bed plus. Larger dwellings take up more space and consequently reduce density.

The emerging Plan also proposes the introduction of National Described Space Standards through Policy ENV9 – Design Quality. This will result in minimum property sizes applying and consequently the average footprint of properties increasing. Again, this will result in densities decreasing.

Policy ENV8 – Open Space, Sport and Recreation, advises that each local authority will set out specific proposals for open space, sport and recreation provision for new developments in their Part 2 Local Plans. As these standards have not been published it is not possible to confirm what impact they will have on the capacity of sites. However, introducing policies that require on site open space and sport facilities will reduce the amount of land available for development that will in turn reduces the number of dwellings a site can accommodate.

The Environment Bill will introduce a required for new developments to achieve 10% biodiversity net gain. This could require additional land for offsetting on development sites. This will reduce the number of units that can be accommodated on sites and their gross density.

Drawing these factors together, we are concerned that the density levels proposed by the Policy are unrealistic. The capacity of the proposed allocations has been overestimated.