Comment

Representation ID: 44983

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

DESIGN QUALITY
Part 2 of the policy identifies a number of matters that development proposals must address.
However, these matters are very high level such as addressing " the townscapes and landscapes
of the Black Country". As with Policy CSP4, Part 2 of the policy would benefit from further
clarification either within the policy text itself or the justification text and it may be worthwhile
for a design guide to be prepared as part Of the BCp which reflects local character and design
preferences and would provide more specific guidance to developers on design requirements.
e policy requirements should be set out in sufficient detail to determine a planning
application Without relying on, Other criteria or guidelines set out in a separate SPD.
It is essential that this is prepared as part of the BCP so that any cost implications can be
properly viability tested in conjunction With Other policy requirements.
Part 3
part 3 States that new residential development Will be required to meet water efficiency
standards of 110 litres per person per day. If the BCA wish to adopt the optional standard for
water efficiency of 110 litres per person per day then they need to justify doing so by applying
the criteria set out in the practice Guidance". The Water Cycle Study (2020) identifies the
Severn Trent Water and South Staffordshire Water supply regions as areas of only moderate
water stress. A clear local need has not been demonstrated.
Taylor Wimpey thereforæ considers that Part 3 of the Policy should be deleted.
Part 4
Taylor Wimpey objects to Part 4 of Policy ENV9 which requires all new msidential development
to meet the Nationally Described Space Standards LNDSSI.
Taylor Wimpey notes that the Government's decision to make these standards optional suggests
that they do not expect all properties to be built in accordance with them. If the standards are to
be applied, the Practice Guidance'S sets out a clear set of criteria local planning authorities
should address in order to justify them, these being:
need — evidence should be provided on the size and type of dwellings currently being built in
the area, to ensure the impacts Of adopting space standards can be properly assessed.
viability — the impact Of adopting the space standard should be considered as part Of a plan's
viability assessment with account taken of the impact of potentially larger dwellings on land
supply. Local planning authorities will also need to consider impacts on affordability where
a space standard is to be adopted.
timing — there may need to be a reasonable transitional period following adoption Of a new
policy on space standards to enable developers to factor the cost of space standards into
future land acquisitions.
With regard these criteria, we firstly note that no need evidence is provided to justify the policy
requirement. The justification text to the policy suggests that the standard is generally met in
most new build housing across the Black Country but no further information on this matter is
provided and it does not appear to have been covered in the evidence base, so there is nothing to
Planning Practice Guidance ID : 56-014-20150327 and ID : 5&015-201S0327
s Planning Practice ID: 56-020-20150327
r tify this. With regard to viability, the BCP Viability Study states that the NDSS has been
applied within the appraisals as the minimum standard. However, it is not clear whether the
impact upon affordability has been considered.
•fie BCA's policy approach should recognise that customers have different budgets and
aspirations. An inflexible policy approach to NDSS for all new dwellings Will impact on
affordability and effect customer choice. Well-designed dwellings below NDSS can provide a
good, functional home.
For the above reasons, Taylor Wimpey considers that Part 4 of the policy should be deleted.
If the Council is able to provide sufficient evidence to justify the policy, Taylor Wimpey
considers that a transitional period should be applied. It is not clear whether a large proportion
of new dwellings currently meet the standard, and the cost of such provision may not therefore
be factored into current and past land acquisitions. A reasonable transitional period following
adoption of a new policy would help enable developers to factor the cost of space standards into
future land acquisitions.