Draft Black Country Plan

Comment

Representation ID: 23220

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

For the reasons stated in our comments to CSP1, we would question whether the area outside of the Strategic Centres and Regeneration Corridors is capable of delivering 27,068 dwellings.

We welcome the identification of Neighbourhood Growth Areas (NGA) and the acknowledgement that Green Belt land needs to be released if the development needs identified are to be met.

Comment

Representation ID: 23221

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP4 – Achieving Well-designed Places

We generally welcome the thrust of Policy CSP4 and agree that achieving well designed places that make a positive contribution to the local character of an area is a desirable policy objective. Furthermore, the thrust of national planning policy seeks to emphasise the role that good design can and should play in new development as evidenced by the recent updates to the Framework and the inclusion of specific new design policies in Chapter 12.

However, we need to be realistic about what this means for the amount of development that can be delivered on sites. We raised this in the workshop meetings held at the beginning of this year and the response was that good design can be achieved at higher densities. Whilst in principle this is true, the higher density schemes I have worked on the black country have been a result of the unique history or design response required for that site. In the most part, where the existing Design Guidance documents holds more weight, the guidance and standards invoked do not allow for high density housing schemes in favour of a more traditional layout. There is nothing wrong with this approach from a design/amenity perspective; however, if higher densities are going to be met than have previously been achieved, then what constitutes good design will need to be rethought. A clear commitment to this will be needed, because otherwise the practical reality is not going to meet the policy aspiration, and the development needs will not be met.

The amount of development that can be achieved on the site is also impacted by the net developable area. The sixth criteria in this policy relates to the delivery of a network of public open space within housing sites. We support the provision of public open space within residential developments, but it is not clear how this aspiration relates to the assumption that that net developable area on brownfield sites will be 80% of the site. When you consider the potential for single sided roads and the other inefficiencies that come with brownfield sites, this not going to leave any meaningful space for the provision of public open space.

Comment

Representation ID: 23222

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy ENV3 – Biodiversity net gain

This is a new requirement and will see the amount of land needed to achieve this increase. This will be true on brownfield and greenfield sites, with brownfields sites often being quite interesting from an ecological perspective for all manner of reasons. This also questions whether the 80% net area assumption is sound.

Support

Representation ID: 23225

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy GB1 – The Black Country Green Belt

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. These sites will not only assist in meeting the development needs, but they deliver more affordable housing, green infrastructure, executive housing, assist in achieving the objective of 25% 4 bedroom dwellings, and will improve the infrastructure (e.g. school and doctor places).

One thing we note here is the desire to create permanent boundaries to the NDAs. Presumably with the intent that they will endure beyond the plan period as required by the National Planning Policy Framework. However, this does pose an important question. Is the draft plan saying that the Black Country has maximised its Green Belt capacity for not only this plan, but also the next? So that any additional development needs that cannot be accommodated in the urban area will have to be exported.

Comment

Representation ID: 23227

Received: 11/10/2021

Respondent: Heyfield Development

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

Object

Representation ID: 23229

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Housing mix

The policy also requires that a range of house types and sizes should be provided in new development. We do not 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 54% 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.

Support

Representation ID: 23230

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

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

This policy sets different targets for delivering M4(3) homes, with lower value areas not required to provide any. Higher value areas can accommodate these and this is another benefit of releasing Green Belt sites.