Draft Black Country Plan

Support

Representation ID: 23309

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

The general approach in Policy CSP4 is welcomed. Paragraph 127 of the Framework states that “Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.” We consider that the proposed policy is appropriate and provides sufficient clarity as to what will be expected and what would be acceptable.

Reference is made within the policy to achieving high levels of sustainability and use of sustainable modern technologies. The approach taken in the policy is welcomed in that it does not try and conflate the dual roles of the planning process with Building Regulations, as we consider that Building Regulations are a far more efficient and effective way of securing sustainable building design and energy reduction than the planning system is.

Comment

Representation ID: 23310

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. Indeed, it is imperative if the housing requirement is to be met. However, even with Green Belt land release it is necessary for a significant proportion of the housing requirement to be direct to neighbouring authority areas.

Comment

Representation ID: 23311

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Policy HOU2 – Housing Density, Type and Accessibility

The policy states that the density and type of housing should be informed by a range of factors. These include the need for and type of new housing required, the level of accessibility of a site to public transport and services and the need to achieve well design development that has regard to the surrounding character of the area. We agree that these considerations are key in determining what the density of new development should be. The policy then goes on to state that all new major development should achieve the minimum net densities set out in Table 5, which range from 40 dph to 100+ dph. Whilst the 100+ dph range is intended to be delivered within strategic centres or close to transport hubs, achieving 40 dph on other sites will present certain challenges, particularly in the context of other policy requirements in the Plan.

A large proportion of the development sites within the Black Country are urban brownfield sites. These can often have constraints that can reduce their net developable area, such as mineshafts or underground infrastructure such as cables and pipes. These sites are often relatively small and are not regular in shape. This makes achieving an efficient layout problematic. This has the consequence of reducing the net developable area and net density.

Policy HOU2 requires that a range of house types and sizes are provided in new developments. The Table on page 100 of the draft Plan confirms that there is a greater demand for 3, 4 and 4+ bed properties than 1 and 2 bed properties. 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 and four bed plus. Larger dwellings take up more space and consequently reduce density.

The emerging Plan also proposes the introduction of National Described Space Standards through Policy ENV9 – Design Quality. This will result in minimum property sizes applying and consequently the average footprint of properties increasing. Again, this will result in densities decreasing.

Policy ENV8 – Open Space, Sport and Recreation, advises that each local authority will set out specific proposals for open space, sport and recreation provision for new developments in their Part 2 Local Plans. As these standards have not been published it is not possible to confirm what impact they will have on the capacity of sites. However, introducing policies that require on site open space and sport facilities will reduce the amount of land available for development that will in turn reduces the number of dwellings a site can accommodate.

The Environment Bill will introduce a required for new developments to achieve 10% biodiversity net gain. This could require additional land for offsetting on development sites. This will reduce the number of units that can be accommodated on sites and their gross density.

Drawing these factors together, we are concerned that the density levels proposed by the Policy are unrealistic. The capacity of the proposed allocations has been overestimated.

Comment

Representation ID: 23312

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

The supporting text to the policy at paragraph 6.32 acknowledges that building homes that meet the M4(2) standard are more expensive to build than standard housing and that ones that meet the M4(3) standard involve a significantly increased cost. In building houses to these standards the additional cost is not offset by an increased sales value. It is an additional development cost that has the potential to impact on the viability of development. As such, securing adaptable/accessible homes may well have to be offset against other policy requirements such as delivery of affordable homes, provision of open space or payment of other contributions for example.

In relation to self build homes paragraph 6.29 confirms that there are only 153 individuals on the Self Build Register. This is the equivalent to 0.31% of the 47,837 dwellings proposed to be delivered in the Black Country. In light of the numbers of people that are interested in self build we do not see that there is any justification for 5% of larger sites over 100 dwellings to be required to provide self build plots. Indeed, this would result in a significant over supply of such plots that may not be deliverable due to a lack of demand. The self build plot requirements should be removed from the Policy.

Comment

Representation ID: 23313

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Part 2 and 3 of the policy duplicates the provisions of the emerging Environment Bill. Once the Bill is adopted it will require 10% biodiversity net gain. Dual regulatory control is inappropriate. As such parts 2 and 3 of the policy should be removed.

Measures to achieve biodiversity net gain on site could reduce coverage and consequently the number of units. This matter needs to be carefully considered in light of the draft Plans density aspirations.

Comment

Representation ID: 23314

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Part 5 of the policy states that “Tree Preservation Orders will be used to protect individual(s) or groups of trees that contribute to the visual amenity and / or the character of an area and that are under threat of damage or removal”. Guidance on the use of TPO’s is set out in the National Planning Practice Guidance. It should not be repeated in Local Planning policies.

Support

Representation ID: 23315

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

In principle we support the requirement to make provision for open space and recreation land within new housing developments. The policy advises that open space standards will be set in Part 2 Local Plan produced by each LPA. We therefore cannot comment on this matter any further at this time.

Comment

Representation ID: 23317

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We have a number of concerns with this policy, particularly where it introduces dual regulatory control. For example, Part 1e) of the Policy refers to needing to achieve Secured by Design principles as set out in Part Q of the Building Regulations. Similarly, part 3) of the policy refers to water efficiency standards that are set out in Part G2 of the Building Regulations. As both matters are addressed in other legislation there is no need for them to be included in this policy.

The policy also states that all new forms of residential development will be required to meet Nationally Described Space Standards (“NDSS”) except where it can be clearly demonstrated that the implementation of NDSS would cause harm to the significance of a heritage asset. The PPG is quite clear that the Councils need to gather evidence first to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plan. There is not sufficient evidence to require all new properties to meet NDDS.

The BCHMA suggest that there is a requirement of 17,866 accessible and adaptable homes in the Black Country and a requirement for 1,674 wheelchair user dwellings. Combined this equates to approximately 25.7% of the total housing requirement (76,076), and 40% of the requirement that is expected to be met within the Black Country administrative area (47,837). That being the case, unless typically less than 40% of the houses on new development sites are built to NDSS standards there is no basis for this policy.

Notwithstanding this, if NDSS were to be applied this would have a number of significant implications for the Councils. The use of NDSS means larger houses have to be built in order to comply with the standards. This will mean the density of development and the capacity of sites will decrease. This will decrease the number of houses that can be delivered in the suggested allocations in the Plan.

Part 5 of the policy refers to ‘greening’ of the Black Country. This term is not precise. Whilst it generally refers to undertaking or incorporating sustainability measures in order to try and reduce the environmental impact of development it is not clear how can this be measured or assessed.

Comment

Representation ID: 23318

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We have no objection to the general thrust of the policy and agree that the need to reduce climate change is paramount. However, there is duplication with this policy and other policies that are in draft Plan. As such, this policy is superfluous and should be removed.

Object

Representation ID: 23319

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We object to the requirement that all developments of 10 or more houses or more than 1,000 square metres should include opportunities for decentralised energy provision. Whilst in theory the use of decentralised energy has a number of sustainability benefits, the reality is that incorporating it in new development is very difficult and expensive on small schemes making it unviable. Similarly, the end user i.e. home owners, commonly have next to no experience of using shared heating systems and this can often be a detractor. As such, there is no desire to develop the technology as ultimately there is no demand from the purchasers.