Draft Black Country Plan

Support

Representation ID: 13831

Received: 11/10/2021

Respondent: Living Space Housing Ltd

The site falls within the proposed allocation at Fallings Park (Ref. WOH264). Living Space wholly support the allocation of this site as a suitable, available, and deliverable scheme within the proposed timescales. The site is allocated for circa 95 dwellings at 40 dwellings per hectare based on the gross site area. Living Space support the higher proposed density as it is an urban edge location and is capable of delivering a denser scheme. Furthermore, as the site is currently designated as Green Belt, the higher proposed density allows better use of land and provides a justification for releasing it from the Green Belt.

Comment

Representation ID: 13834

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space are happy to work with the Council to develop a masterplan for the entirety of Fallings Park. Living Space understand the Councils’ desire to bring the site forward as one coherent scheme. However, conversely, the Councils should also ensure that requirement to develop a masterplan does not compromise the delivery of the allocation.

Support

Representation ID: 13835

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space support the inclusion of the housing figure as a minimum with the wording of “at least 47,837 net homes”. As per the National Planning Policy Framework (NPPF), strategic policy-making authorities should establish a housing requirement figure for their whole area. This figure is required to ensure that the identified housing need (and any need arising from Neighbourhood Area) can be met over the plan period1. The Black Country is part of the Greater Birmingham & Black Country Housing Market Area (GB&BCHMA) and it is commonly accepted that there is severe unmet need in both Birmingham and the Black Country. Table 2 within the draft Plan details that the minimum requirement of 47,837 dwellings is the requirement for Black Country alone, with an additional 28,239 dwellings arising through the Duty to Cooperate. Therefore, the Black Country Authorities should be seeking to maximise their housing numbers over the Plan period to ensure that the complete need of 76,076 is met.

Living Space agree that the spatial strategy should focus around delivering the majority of development in the existing urban area, as this will maximise the opportunity for sustainable development.

Comment

Representation ID: 13836

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space understand why the Councils have taken the approach of focusing new development around the Strategic Centres and Core Regeneration Areas. The existing centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton are the most sustainable locations within the Black Country and new development can help these communities to continue to grow in a sustainable way. However, it is important to recognise the benefits that new development can bring and the Councils should ensure that there is a good distribution of growth throughout the districts. This will help ensure that all communities have the opportunity to grow and develop in a sustainable way. The Councils should also be cautious with their proposal to locate the majority of new development within the existing built-up area. The majority of this will be required on brownfield sites and will be dependent on the viability of said site. The development of brownfield sites is often as the expense of providing any on-site affordable dwellings.
1 Paragraph 66 of the National Planning Policy Framework (NPPF) (2021)

Support

Representation ID: 13837

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space encourage the inclusion of Policy CSP3 as a support to Policy CSP2 and in it’s own right. The Policy recognises the importance of the Urban Edge areas for accommodating growth. These areas are as sustainable and suitable for development, and will create a variety of new homes for the District. Furthermore, releasing greenfield sites from the Green Belt for housing development ensures that there is suitable complementary development to the proposed regeneration of brownfield sites. Greenfield sites often do not have the same viability complications as brownfield sites, meaning they can provide more benefits such as a higher affordable housing provision and higher Section 106 contributions for the Local Community.

Comment

Representation ID: 13838

Received: 11/10/2021

Respondent: Living Space Housing Ltd

It is important that the new Green Belt boundary is drawn in a way that honours the 5 Green Belt purposes, as defined by the NPPF.

Living Space support the inclusion of point a. As the promoter for proposed allocation WOH264, a current Green Belt site, Living Space will engage with the Council in discussions regarding the compensatory improvements to seek clarification on this. At this time, it is not clear what this entails.

Whilst Living Space recognise the intension behind compensatory improvements, the Councils should ensure that the viability of this is tested and that it does not compromise the deliverability of the proposed allocations.

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.

Support

Representation ID: 13840

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Under draft Policy HOU 3, the Councils set out the minimum proportion of affordable housing as follows:
• 10% on all sites in lower value zones and brownfield sites in medium value zones;
• 20% on greenfield sites in medium value zones; and
• 30% on all sites in higher value zones.

The proposed approach towards the provision of affordable is supported, as put forward in the Black Country Viability and Delivery Study.

Object

Representation ID: 13841

Received: 11/10/2021

Respondent: Living Space Housing Ltd

However, the Councils will be aware of the national affordability crisis that exists within the housing sector and measures should be incorporate to provide better policy support for schemes proposing 100% affordable units. The Plan is currently silent in Policy terms on schemes which propose 100% affordable units.

Object

Representation ID: 13842

Received: 11/10/2021

Respondent: Living Space Housing Ltd

The draft Policy proposes the following on Wheelchair Accessibility as a minimum:
a. On all brownfield sites, and on greenfield sites in lower value zones: 20% of homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.
b. On greenfield sites in medium or higher value zones: 15% of homes to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings16 and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.

Living Space would remind the Councils of the need to adequately evidence policy proposals, and no such evidence has been presented to justify the proposed requirement for M4(2) and M4(3) units. The supporting Black Country Strategic Housing Market Assessment (2021) does not evidence a local need for M4(2) and M4(3) standard units. Therefore, requesting such a high proportion of dwellings as a Policy minimum is unsound. If the Councils wish to include a policy on these standard, the policy should be more flexible and based on evidenced local need.