Comment

Representation ID: 43822

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

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7. Policy HOU2 - Housing Density, Type and Accessibility
7.1 Paragraph 60 of the Framework states:

homes, it is important that a sufficient amount and variety of land can come
forward where it is needed, that the needs of groups with specific housing
requirements are addressed and that land with permission is developed without
(our emphasis)
7.2 Paragraph 62 of the Framework explains that within this context:

the size, type and tenure of housing needed for different groups in the
community should be assessed and reflected in planning policies (including,
but not limited to, those who require affordable housing, families with children,
older people, students, people with disabilities, , service families, travellers,
people who rent their homes and people wishing to commission or build their
(our emphasis)
7.3 Paragraph 2a- What is the relationship between the current housing stock and
current and future needs?

Strategic policy-making authorities will need to look at the current stock of
houses of different sizes and assess whether these match current and future
needs.
7.4 Policy HOU2 does not provide any specific mix relating to need. It simply requires the density and
type of housing to be informed by s and sizes of accommodation
to meet identified sub- . The policy then sets out minimum density
requirements, the lowest of which is 40 dwellings per hectare (dph), which would still be relatively
high density for a housing development.

7.5 The plan fails to properly address the need for different types of housing, in particular family
housing. This goes to the heart of the strategy of predominately relying upon brownfield sites in
the urban area. We refer to the analysis undertaken by Turley in their review of housing need and
supply in the Black Country (see Appendix EP1, paragraphs 2.10 2.13 & 4.24 4.27).

7.6 Furthermore, we question whether the need for different types and sizes of housing identified in
Section 5 of the BCHMA is robust. The methodology for adducing the required housing mix is not
specified in the BCHMA, but it appears to be based upon demographic modelling assumptions
(i.e., the bedroom standard referred to on page 60, footnote 36 for the BCHMA, or similar) rather

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than any analysis of current and future market demand. For example, a family of four may in
demographic terms require a three-bedroom house. However, that family may aspire to live in,
or need for other reasons, a four or five-bedroom house. For example, spare bedrooms may be
required for a home office or guest accommodation. Such issues have become particularly
relevant post-COVID with the shift towards increased home working.

7.7 We therefore consider that the overall strategy needs to be re-assessed to ensure that the need
for specific types of housing, in particular family housing, are met.