Comment

Representation ID: 44940

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HOU3 - Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Part 2
Part 2 of the Policy states that all developments of ten homes or more should provide a proportion of affordable housing, where this is financially viable. It advises that the minimum proportion of affordable housing that should be provided is:
a On all sites in lower value zones and brownfield sites in medium value zones: 10% affordable housing;
b On greenfield sites in medium value zones: 20% affordable housing;
c On all sites in higher value zones: 30% affordable housing.

13.2 The 2021 Strategic Housing Market Assessment [SHMA] notes the following:
“The total annual affordable housing need in the Black Country of 867 per year (as set out in Chapter 6) represents 21.6% of the annual dwelling growth of 4,019 in the housing market area as assessed using the revised Standard Method. It would be reasonable to expect this proportion of new housing as affordable to be delivered on a large housing site in the Black Country, where a figure of 25% would be plausible (subject to viability). The Councils can therefore be confident that the affordable housing need identified in the model will be addressed by the dwelling growth identified by the Standard Method and no adjustment is required to this figure”.

13.3 Whilst TW supports a differentiated approach to the provision of affordable housing to reflect different value zones in principle, we note that the proposed percentages set out in Policy HOU3 are above the recommendations of the BCP Viability Study.

13.4 We would note that any affordable housing policy requirement needs to be tested though the Viability evidence on an ongoing basis as the BCP progresses to ensure that it accounts for any changes to policy requirements which may have a subsequent impact upon site viability.

13.5 It is also noted that the type and tenure of affordable housing sought is ambiguous. The Framework (§16d) states that policies should be clearly written so that a decision maker knows how to react to a development proposal. To be effective, the BCA should provide further clarification of its requirements, which should be justified by supporting evidence.

Part 4
13.6 Part 4 of Policy HOU3 states that all developments of ten homes or more should provide a proportion of wheelchair accessible housing, where this is financially viable. The stated minimum proportion that should be provided on greenfield sites in medium or higher value zones is 15% of homes to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.

13.7 Whilst Taylor Wimpey generally supports the provision of homes that are suitable to meet the needs of older people and disabled people in principle, we object to Part 4 of the policy as we are concerned that the standards proposed are not fully justified and do not accord with the Practice Guidance. The evidence on future need provided in the 2021 SHMA does not support the proportions identified in the policy.

13.8 For M4(3): Wheelchair User Dwellings, the SHMA26 indicates that 1,674 dwellings are required in 2039. It states that 1,456 should be in the general housing stock and 217 in supported accommodation. It indicates that by the end of the plan period, around about 0.3% of the total stock should be available to meet this criteria. However, there is no clear explanation as to how a 15% policy requirement has been derived from this identified need. In addition, it provides no information on the availability of existing stock to meet this need and does not consider the potential for the conversion of existing properties either. The actual likely requirement is therefore likely to be significantly lower than this.

13.9 The evidence does not identify any local circumstances, which demonstrate that the needs of the Black Country differ substantially to those across the West Midlands or England. If the Government had intended that evidence of an ageing population alone justified adoption of optional standards, then such standards would have been incorporated as mandatory in the Building Regulations, which is not currently the case.

13.10 The evidence provided does not therefore justify the 15% requirement identified. In addition, we note that the policy identifies no requirement for the provision of M4(3) dwellings in lower value zones. This does not make any sense as the need for these properties will inevitably be spread through all parts of the BCP area, not just the higher value areas.

13.11 Taylor Wimpey considers that the most effective way to provide sufficient housing to meet M4(3) category requirements in the correct locations would be to increase the proportion of this type of accommodation in specialist housing for older people. This could involve the allocation of specific sites to help meet this need. We recognise that not all wheelchair housing will be provided through such specialist housing and consider that any requirements for M4(3) dwellings on market housing sites could be based on assessments of local need at the time of a planning application.

13.12 For M4(2): Accessible and Adaptable Dwellings, the SHMA identifies that in total 17,866 accessible and adaptable homes are required in 2039 across the Black Country. However, limited evidence has been provided on the size, location, and quality of dwellings needed to address the need identified and it is not therefore clear what requirements are and how they differ across the different authority areas.

13.13 Taylor Wimpey is also concerned that the suitability of existing housing stock has not been properly assessed against the future requirements identified. In this regard, the SHMA notes27 that there is not a detailed profile of the current stock from which to derive a net requirement. In addition, the SHMA28 recognises that the Councils help people to remain in their current home and any adaptions to dwellings provided through this mechanism could reduce the requirement for new homes meeting the M4(2) standard. Improvements to existing homes
funded through Disabled Facilities Grants will inevitably contribute towards this uplift, reducing the need for provision in new housing stock.

13.14 The requirement in Policy HOU3 for all remaining homes to meet the optional Building
Regulations Requirement M4(2) is therefore completely unjustified.

13.15 It is important to note that not all health issues affect housing needs. Many older people already live in the Black Country and are unlikely to move home. No evidence is presented to suggest that households already housed would be prepared to leave their existing homes to move into new dwellings constructed to M4(2) and / or M4(3) standards. Adaption of existing stock will form an important part of the solution.

13.16 For the above reasons, we consider that the percentage provisions for M4(2) housing and M4(3)
housing have not been fully justified and cannot be sought through Part 4 of the policy.

Part 6
13.17 Part 6 of the policy states that on developments of 100 homes or more, where there is currently
a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located, at least 5% of plots should be made available for self-build or custom build, or sufficient to match the current number on the register if lower. Whilst it is accepted that new development should contribute to achieving an appropriate mix of housing, Taylor Wimpey objects to Part 6 for a number of reasons.

13.18 Councils have a legal obligation to grant sufficient planning permissions to meet the demand for self and custom build properties. Taylor Wimpey considers the current policy approach to be ineffective because it would not guarantee that the Council’s obligation to ensure enough self and custom build properties have been provided to meet demand. It cannot be known what
level of provision will be achieved on schemes by market housing developers and when; and
therefore, the Council cannot rely on these sites as their supply for self-build and custom-build housing.

13.19 The evidence provided in the SHMA also indicates that demand is low across the Black Country with only 32 individuals on the self-build register in Walsall and 8 in Dudley. Data from the Self Build Portal also indicates that demand is lower than average. There is therefore no clear justification for the 5% requirement identified.

13.20 Market Housing development and Self or custom build rarely work together. Providing self or custom build on market housing sites is unlikely to work and will severely impact upon a scheme layout. It will also create issues with the apportionment of planning obligations between the housing market area and self -build plots. In addition, it is unlikely that self and custom build serviced plots on residential sites of more than 100 dwellings will appeal to those wishing to build their own home. No justification has been provided for the 10 dwelling threshold identified either.

13.21 In addition, the impact of this policy requirement on scheme viability does not appear to have been considered in the BCP Viability Study.

13.22 Taylor Wimpey therefore considers that this policy requirement should be deleted and the Councils should identify stand alone sites which are specifically allocated to meet the local demand for self and custom build dwellings.

Parts 7 and 8
The option to provide to provide financial viability assessments where affordable housing or wheelchair accessibility requirements can be demonstrated to make the development unviable, is welcomed. However, the BCP authorities should ensure that this situation is avoided where possible by ensuring the requirements of the policy are properly justified and tested through the
viability evidence informing the BCP.