Comment

Representation ID: 23317

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We have a number of concerns with this policy, particularly where it introduces dual regulatory control. For example, Part 1e) of the Policy refers to needing to achieve Secured by Design principles as set out in Part Q of the Building Regulations. Similarly, part 3) of the policy refers to water efficiency standards that are set out in Part G2 of the Building Regulations. As both matters are addressed in other legislation there is no need for them to be included in this policy.

The policy also states that all new forms of residential development will be required to meet Nationally Described Space Standards (“NDSS”) except where it can be clearly demonstrated that the implementation of NDSS would cause harm to the significance of a heritage asset. The PPG is quite clear that the Councils need to gather evidence first to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plan. There is not sufficient evidence to require all new properties to meet NDDS.

The BCHMA suggest that there is a requirement of 17,866 accessible and adaptable homes in the Black Country and a requirement for 1,674 wheelchair user dwellings. Combined this equates to approximately 25.7% of the total housing requirement (76,076), and 40% of the requirement that is expected to be met within the Black Country administrative area (47,837). That being the case, unless typically less than 40% of the houses on new development sites are built to NDSS standards there is no basis for this policy.

Notwithstanding this, if NDSS were to be applied this would have a number of significant implications for the Councils. The use of NDSS means larger houses have to be built in order to comply with the standards. This will mean the density of development and the capacity of sites will decrease. This will decrease the number of houses that can be delivered in the suggested allocations in the Plan.

Part 5 of the policy refers to ‘greening’ of the Black Country. This term is not precise. Whilst it generally refers to undertaking or incorporating sustainability measures in order to try and reduce the environmental impact of development it is not clear how can this be measured or assessed.