Policy HOU2 – Housing Density, Type and Accessibility

Comment

Representation ID: 10589

Received: 19/08/2021

Respondent: Mr Ian Satterthwaite

Affordable council housing for English Working class families was where The Borough of Stourbridge council was a pioneer, however in more recent times the council housing stock has been sold and lost for this demographic, which should be addressed by a slum clearance in Lye (again) and the development of affordable housing for working families and a return to traditional high street shopping

Object

Representation ID: 10645

Received: 29/08/2021

Respondent: Miss Karen Westwood

The proposed 115 houses for Bryce Road field is mass over development. No consideration is evident for the loss of privacy for existing residents, the increased level of traffic approaching the new development or consideration for the loss of current recreational green space used by many surrounding residents. Loss of wildlife habitat will be devastating. There’s also concern about the affect on property values due to the drastic changes proposed for the area of green space.

Comment

Representation ID: 10657

Received: 01/09/2021

Respondent: Mr David Brookes

Can you make sure that disabled and aged accommodation is mixed in with normal housing and not in gettos as as happened in past .also it's needs to be by local shops .doctors.chemist bus routes .etc.
And that said housing contains the right needs ..IE I was moved into a new bungalow with wheelchair access doors switch's etc .to find fitted with a bath . kitchen cabinets 6ft from floor selves 8 ft then find out nothing can be altered for a least 12 months due to being new building under builder's warranty.

Comment

Representation ID: 10866

Received: 16/09/2021

Respondent: Mr Paul Rogers

Whilst the policy appears balanced and reasonable, I object to inclusion of sites DUH-206, DUH-207, DUH-208, and DUH-209 on the grounds that this combined site does not readily fulfil the accessibility criteria and encroaches unnecessarily on green belt land.

Comment

Representation ID: 11016

Received: 20/09/2021

Respondent: Mr Richard Carter

This country as a whole needs to review its expectations with regarding the types of housing that is build. Greater focus should be made on the use of 4 story (plus basement) apartment building that make greater and better use of available land. Irrespective of the number of homes that the government has allocated, there should not be any need to re-assign green belt or recreational land to housing, or employment, use. Before this happens, there is a needs to ensure that ALL empty, underutilised, semi-derelict and derelict properties are utilised and/or replace first.

Comment

Representation ID: 11099

Received: 14/09/2021

Respondent: Miss Anne Nicholls

With new homes, there must be a mixed of different types of housing including affordable housing.

Comment

Representation ID: 11186

Received: 25/09/2021

Respondent: Mr. Dennis R Whittaker

In table in paragraph 6.20, whilst all the rows add up to about 100%, all columns add up to amounts significantly more than 100% - namely 112.6%, 124.0%, 134.1% & 129.4% respectively. Therefore, the figures are unreliable.

Object

Representation ID: 11192

Received: 26/09/2021

Respondent: Mr Morgan Brookes

Develop sites and leave green belt. Build family homes and convert social housing to multi occupancy .

Comment

Representation ID: 11297

Received: 29/09/2021

Respondent: Mr Melvyn Wilson

Dwellings at 35dph is over capacity for the type of are concerned.

Comment

Representation ID: 11307

Received: 29/09/2021

Respondent: Mrs Emily Fitz-Harris

Future building needs to take into consideration, privacy and overlooking, access to sunlight and daylight; artificial lighting; vibration; dust and fumes; smell; noise; crime and safety;

Future building needs to really take this into consideration, while I agree there is a need for new housing and the supporting infrastructure it is so important that it does not as stated cause a detrimental impact on the living conditions for future OR CURRENT occupiers of new residential properties, in terms of: privacy and overlooking, access to sunlight and daylight; artificial lighting; vibration; dust and fumes; smell; noise; crime and safety;

Comment

Representation ID: 11348

Received: 30/09/2021

Respondent: Ms Julia Hawes

How can the planned housing proposal in Pelsall/Shelfield be described as low to medium density when you are planning to cram hundreds of houses into the areas in question?

Comment

Representation ID: 11373

Received: 30/09/2021

Respondent: Mrs Jacqueline Elson-Whittaker

Consider better way of energy for homes - sustainable - installation of solar panels as standard and electrical charge points for cars.

Comment

Representation ID: 11725

Received: 08/10/2021

Respondent: Mr Greg Ball

COVID and lockdown exposed the pressures on parks and open space in high density areas. Small flats and houses were ill-suited to round the clock occupation and home working. There must be a balance between the objective of minimising car use and avoiding peripheral housing and avoiding town cramming. Too many recent high density developments have been poorly designed.

Object

Representation ID: 11789

Received: 09/10/2021

Respondent: Sam Collenette

I object to building on the greenbelt under any circumstances. 171 houses should be factored in by increasing the density on brownfield sites. Redrawing the boundaries is not a sustainable or justifiable option. I object to the complexity of this consultation. I expect my comments to be taken as an objection to the whole plan not just this chapter. You have not made it as easy as it should be for concerns to be raised and objections submitted.

Object

Representation ID: 12790

Received: 06/10/2021

Respondent: Rhiannon and Tony Fearn

Number of people: 2

I ask that the number of affordable houses that are needed is calculated and allocated to the redevelopment of brownfield sites. Rather than the constant and irreversible destruction of our green belt.

Comment

Representation ID: 13014

Received: 09/10/2021

Respondent: Mr Phillip Tapper

[Brownfield in Darlaston and Pleck] would be more suitable for affordable new housing which is what the town needs.
Commercial pressure would cause [other, green belt] proposed sites to be developed as mid-range executive houses for growing families and extended family units.

Comment

Representation ID: 13574

Received: 07/10/2021

Respondent: Mrs Barbara Pritchard

New builds should be of smaller, less expensive units not 4 and 5 bedroom houses

Support

Representation ID: 13839

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Draft Policy HOU2 includes a proposed density for the districts. Living Space welcome the Councils’ and the proposed densities, as this will ensure the best use of land. Living Space also agree that density should be based on the need to achieve high-quality design and consider the characteristics of the wider area, but this should be done in a way that still ensures the best use of land.

Comment

Representation ID: 18047

Received: 11/10/2021

Respondent: Brierley Hill Community Forum

Brierley Hill has demonstrated that high density housing (for example, adjacent to the Merry Hill Centre) can be highly successful. However, there is a concern that the over concentration of social housing for rent in particular areas can amplify social problems for towns, whilst contributing little to the economic viability of town centres. There is a view that all social housing is being concentrated in areas which already have high levels of such homes, whilst the proposals do little or nothing to address shortages in the west of the borough.

Comment

Representation ID: 18427

Received: 07/10/2021

Respondent: Richard Brooks

Policy HOU2 - Covenants must be put on new developments to prevent excessive paving of front gardens to protect the street scene and our health and biodiversity, as well as reducing flooding.

Comment

Representation ID: 19388

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.6 - Recommends that the policy also explains where the evidence comes from for determining the range of houses and sizes.

Comment

Representation ID: 19389

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.7 - Table 5 and in relation to accessibility "In order to provide suitable flexibility in the market and in particular to reflect the location of specific sites, the supporting text and policy should both make clear that these figures are a guideline and will be informed by other evidence dependent on site location and specifics applying at the time that planning applications are determined."

Object

Representation ID: 20981

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Policy HOU2 – Housing Density, Type and Accessibility
Density
Three density categories have been identified – 40, 45 and 100 dwellings per hectare. As the policy is drafted, these categories are one of three considerations that go into determining what density and type of dwellings are appropriate for different sites across the Black Country. The other two factors are the range of type and size of accommodation, and high-quality design and amenity.
In practice, the implications of the other two categories are that, in the most cases, this is going to result in the density reducing below the target in the categories. There are always exceptions to the rule, but the average densities will be lower than the targets in the categories.
The nature of the housing market in the Black Country is that there is limited demand for apartments. We would expect these to be delivered in the ‘very high’-density areas, where this product becomes more attractive. In the ‘high’ and ‘moderate’ density areas the pressure from the development industry will be to deliver housing. This is what the demand is for and apartments on housing sites are just not attractive when there will be houses near by that can be purchased for the same/less money.
Our comments on the impact of design are set out above under policy CSP4 and demonstrate that high-quality design will need to be rethought if the target densities are to be met. Our fundamental concern is that historically, seeking to achieve better design has pushed densities down, which conflicts with the desire to increase densities. It will need to be demonstrated that these are not competing objectives.
There are other competing policy objectives when it comes to increasing densities. These are the requirement for NDDS and M4(2) and M4(3) under Policy HOU3. In our submissions earlier this year we highlighted that we work with, and have spoken to, most of the major developers who operate across the Black Country. In doing so all of these developers confirmed that they did not currently deliver house types to meet these standards in the Black Country. This includes affordable housing developers, with Homes England accepting 85% NDDS for grant applications. Introducing these standards will increase house sizes and this is not compatible with higher densities.
In terms of M4(2), this tends to have the biggest influence on 3 / 4 bedroom units, because it requires a wet room down stairs, which cannot be delivered within the existing footprint when all other factors are considered. This will further increase the footprint of the dwellings going forwards.
None of the above is to say that the target figures in the density categories should be reduced. After all, the Framework requires us to make the most of previously developed sites and there is no harm in driving for higher densities.
However, when it comes to establishing what a realistic capacity of the sites is within the existing urban area, we do not consider it is appropriate to use these target densities. The average density will be lower than this. By applying these target figures, this will inflate the capacity figures and under-represent the need for sites to be release elsewhere and fundamentally not lead to the enough homes and jobs being built/delivered for local people.
Housing mix
The policy also requires that a range of house types and sizes should be provided in new development. We don’t disagree with this objective and agree that delivering the right type and size of houses in the right locations is clearly the right approach to meeting housing needs of the Black Country. However, we object to the policy as written on the basis that it is not the correct way of achieving these objectives as it is an incredibly blunt object for developers to comply with when it comes to delivering the houses that are needed.
Whilst the policy seeks to differentiate between the need for market and affordable housing, another key determinate of where housing is to be delivered is geographical location. Developments in the strategic centres or regeneration corridors are likely to be better served by public transport and existing shops, services and facilities which would lend themselves to higher density developments that could include apartments. An apartment scheme, however, is unlikely to be able to deliver the full mix of dwellings sought in the policy. Whilst NGAs are better placed to deliver a higher proportion of 3- and 4-bedroom dwellings to assist in meeting the target of delivering at least 50% of the dwellings with 3 or more bedrooms. The policy, as worded, does not consider these different market areas and seeks to apply a one size fits all approach to delivering housing in both. This is not a sound approach.

As detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. The emerging plan seeks to adopt a space standard policy which will increase dwelling sizes impacting upon density. It is not unusual, in our experience, for brownfield sites within the Black Country to have constraints that adversely affect density, such as mineshafts or due to their relationship to surrounding uses. In addition, 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 plus. Larger dwellings take up more space. This will drive down the density that can be achieved. It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will be reduced accordingly.

Comment

Representation ID: 21204

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy HOU2 – Housing Density, Type and Accessibility

Policy HOU2 recognises that the density and type of housing to be provided on any housing site will be informed by (i) sub-regional and local needs, (ii) access to sustainable transport methods and (iii) the need to achieve high quality design. Insofar as (i) is concerned, our Client considers it will be important to maintain flexibility to allow for changing local market circumstances. In this regard, it will also be important to ensure that housing mix prescriptions are determined in line with up-to-date evidence.

Paragraph 125 of the National Planning Policy Framework states:
“Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site.”

This policy also states that plans should contain minimum density standards for city and town centres and other locations that are well served by public transport, and that the use of minimum density standards should also be considered for other parts of the plan area and that it may be appropriate to identify a ‘range’ of densities that reflects the accessibility and potential of different areas.

The Black Country is a highly constrained District, in terms of Green Belt boundaries and other constraints, and Taylor Wimpey therefore appreciates that available land will need to be used in the most efficient way to ensure that the BCAs are able to meet their future housing requirements. Taylor Wimpey, therefore, as a matter of principle, support the range of minimum net densities set out in Policy HOU2 of between 40 dph and 100 dph.

Notwithstanding this, high densities will not be appropriate in all proposed housing locations, for example in previously developed land within the Green Belt, or sites which are within close proximity to national designated sites i.e. SSSIs etc. Densities should therefore be considered on a site-by-site basis, taking into account local circumstances.

Part 5 of the policy also states that further details of design requirements for housing developments may be set out in Supplementary Planning Documents. If such a document is to be produced, it is essential that it is prepared in parallel with the BCP so that any cost implications can be properly viability tested in conjunction with other policy requirements to ensure that it will not have any detrimental impact upon scheme delivery.

Comment

Representation ID: 21262

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy HOU2 – Housing Density, Type and Accessibility
The policy sets out criteria that housing mix for development sites will be based on which includes being in line with the most recently available information. Paragraph 124 of the NPPF sets out the importance of planning policies to make efficient use of land taking into account: the identified need for different types of housing, local market conditions and viability, the availability and capacity of infrastructure, the desirability of maintaining an area’s character and setting and the importance of securing well-designed and attractive places [Savills emphasis].

The housing mix set out under paragraph 6.20 of the plan sets out the housing needs identified in the BCA Housing Market Assessment (2021). Market demand changes so this ‘latest’ evidence may not be representative of need when planning applications are submitted in the future. As developers and national housebuilders have vested interests in building products that are deliverable and meet market needs, the BCA should not have a fixed size and type guidance, as this could affect development viability, lead to inflexibility and result in obstructing development. We consider that the Housing Market Assessment figures should be used as guidance only and housing mix should be determined on a site by site basis based on market evidence at the time of application submission.

Although we support the Council’s ambition to make the most efficient use of land (NPPF paragraph 125), we do not support the proposed approach to calculating density requirements within this policy. Policy HOU2 has based its proposed density requirements on Table 5, which assesses accessibility through the proximity of the site to local centres, health facilities, shops and education. The Planning Practice Guidance (‘PPG’) sets out a range of considerations which should be taken into account when considering densities for a site or area which includes accessibility to services, as the BCA have assessed but also characterisation studies (urban form and historic character), environmental and infrastructure capacity and market/site viability which the plan has not considered (Reference ID: 66-004-20190722). Additionally, the PPG also states that it is “important to consider how housing needs, local character and appropriate building forms relate to the density measures being used” (Reference ID: 66-005-20190722). We consider that it is important that density is considered on a site by site basis, particularly for proposed allocations which are adjacent to lower density housing such as Site WSA2.

Paragraph 6.18 states that investment will be sought to improve any facilities where there is an identified gap in service provision. We understand that Walsall Council has not received input from health or Education to date to confirm their requirements. Health and education requirements for each site should be confirmed and addressed accordingly within the plan.

Comment

Representation ID: 21291

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy HOU2 – Housing Density, Type and Accessibility

Draft Policy HOU2 seeks to locate new homes in places with good sustainable transport access to key residential services and provide a mix of housing types and densities which are appropriate to their location and to help meet local needs.

The principle of optimising the density of development in locations that are well served by public transport is supported and considered to be consistent with national policy (NPPF, paragraphs 125 and 141). However, it is considered that the wording of the policy should be amended so that section (4) of the policy only applies on Sites not allocated for housing within Chapter 13. Chapter 13 identifies the site allocations for each of the BCA areas and provides details of what it considers to be an appropriate density for each site. This is based on an assessment of each of the sites undertaken in the ‘Sites Assessed for Housing’ report, that includes a range of considerations including local context and individual site constraints. As such, this is considered to be a more robust density standard which aligns with paragraph 124 of the NPPF and the NPPG on achieving appropriate densities (see ‘Effective use of land’ Paragraph 004 Reference ID: 66-004-20190722). For example, in the case of this Site, part 4c) of Policy HOU2 would apply, which would set a minimum net density of 40 dwellings per hectare for the Site. However, the draft site allocation in Chapter 13 estimates an appropriate capacity of 35dph, given that the Sites Assessed for Housing report had identified a very low character density of 17dph in the local area.

Comment

Representation ID: 21346

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY HOU2 – HOUSING DENSITY, TYPE AND ACCESSIBILITY
WDH supports the BCAs’ recognition that residential net densities will be informed by the range, types and sizes of dwellings, accessibility to sustainable transport, and the need to achieve high-quality design and minimise amenity. In that regard, WDH recognises the indicative densities set out within the supporting text to the policy. That said, WDH would welcome a reference to final residential densities being informed by ‘development viability and site and settlement-specific considerations.’

Similarly, WDH welcomes the recognition in Policy HOU2 that final housing mixes will be informed by the most recently available evidence, and also recognises the inclusion of an indicative mix within the supporting text which itself is informed by the most recent Strategic Housing Market Assessment (SHMA). However, WDH would appreciate additional flexibility being built into that policy given that the housing needs will inevitably vary greatly between the urban centres of Wolverhampton, Walsall, Brierley Hill and West Bromwich and more suburban areas. Therefore, the policy should be redrafted to read that final housing mixes should be “in line with most recently available information in relation to localised housing needs, and taking into account site and settlement-specific considerations, as well as viability.”

Comment

Representation ID: 21619

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy HOU2: ‘Housing Density, Type and Accessibility’
Draft Policy HOU2 states that: ‘all developments of ten homes or more should achieve the minimum net densities’.
For non-strategic centre or town centre sites, minimum densities of 40 to 45 dwellings per hectare are sought by draft Policy HOU2.
First, it is not clear whether the densities apply to the gross area or the net developable area.
In our experience, there can be significant differences between the gross land area and the net developable area achievable. Hence, draft Policy HOU2 should be updated to ensure that these densities apply to the net land areas in the policy (to ensure that the densities targeted are achievable).
In addition, the ability to achieve the 45 dwelling per hectare minimum density in particular will depend upon a range of site-specific factors, such as the ability to deliver a higher amount of apartments typically in the order of approximately 20% of the overall residential
development mix. Clearly, this requirement will need to be balanced with a range of other policy density and mix requirements, as well as both market demand and need, as well as site specific constraints, throughout the BCAs.
Therefore, draft Policy HOU2 should be updated to ensure that these proposed densities should be expressed as a ‘target’ rather than ‘minimum’ density requirements.

Comment

Representation ID: 21643

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

Draft Policy HOU2 – Housing Density, Type, and Accessibility notes that,


1. The density and type of new housing provided on any housing site should be informed by:
a. The need for a range of types and sizes of accommodation to meet identified sub-regional and local needs;
b. The level of accessibility by sustainable transport to residential services, including any improvements to be secured through development, as set out in Table 5;
c. The need to achieve high-quality design and minimise amenity impacts, considering the characteristics
and mix of uses in the area where the proposal is located.
2. Each authority will aim to provide an overall mix of house types over the plan period, tailored to best meet local and sub-regional needs.
3. Developments of ten homes or more should provide a range of house types and sizes that will meet the
accommodation needs of both existing and future residents, in line with the most recently available information.
4. All developments of ten homes or more should achieve the minimum net density set out below, except where this would prejudice historic character and local distinctiveness as defined in Policy ENV5:
a. 100 dwellings per hectare where Table 5 accessibility standards for very high-density housing are met
and the site is located within a Strategic Centre or Town Centre.
b. 45 dwellings per hectare where Table 5 accessibility standards for high density housing are met;
c. 40 dwellings per hectare where Table 5 accessibility standards for moderate density housing are met.
5. Chapter 13 provides details of the appropriate density and, where appropriate, house type mix, to be sought on each housing allocation site, in accordance with the requirements set out in this Policy. Further details of design requirements for housing developments may be set out in Supplementary Planning Documents.


Table 5 – Black Country Housing Accessibility Standards addresses the issue of density based upon the proximity of the site to local services and facilities via sustainable means such as walking, cycling, or bus. The site at Manor Way performs well against the parameters for 40 dwellings per hectare (dph). I deal with each of the parameters in turn, below:

1. Employment – Strategic Centre or other employment area. The nearest Strategic Centre to the site is Brierley Hill which is accessible by public transport in approximately 25 minutes. On this basis, the site would fall under the 40+ dph density category.
2. Health – Primary Care e.g. GP Surgery or Health Centre. The nearest NHS GP surgery to the site is Stourside Medical Practice, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 45+ dph density category.

3. Fresh Food – Centre or food store. The nearest food store to the site is Aldi at Earls Way, which is accessible by public transport in approximately 13 minutes. On this basis, the site would fall under the 40+ dph density category.
4. Education – Primary School (walking distance only). The nearest primary school to the site is Manor Way Primary Academy. This primary school is within 10 minutes walking distance of the site. On this basis, the site would fall under the 40+ dph density category.
5. Education – Secondary School. The nearest secondary school to the site is Windsor High School and Sixth Form, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 40+ dph density category.

Having assessed the site against the parameters outlined in Table 5 – Black Country Housing Accessibility Standards
in the Draft Black Country Plan, we consider that the site is suitable to deliver a housing density between 40-45 dph.


We respectfully request that the text in Policy HOU1 - Delivering Sustainable Housing Growth is amended to reflect the correct information in respect of the gross site area, the net site area, the number of units that the site is capable of delivering and anticipated delivery timescales.

Comment

Representation ID: 21822

Received: 11/10/2021

Respondent: Dr Osman Dervish

Agent: RCA Regeneration Ltd

2.7. We are broadly supportive of the densities proposed in the emerging plan, however we consider they are aspirational when it comes to the central areas of the main Black Country settlements, with the exception of perhaps Wolverhampton, because of viability (specifically build costs v likely sales values). Apartments continue to be difficult to sell in much of the Black Country and it is hard to imagine how (post-covid) high density apartment schemes will, in reality, come forward on any great scale. We would urge the BC authorities to reconsider their expectations on this moving forwards.
2.8. We would seek some flexibility in the application of accessibility standards - particularly as a result of the move towards more sustainable personal travel modes, such as electric cars.
2.9. We would also seek flexibility in the application of housing mix standards, where evidence from the availability of second hand stock within the immediate area demonstrates an oversupply of a particular size of dwelling.