Black Country Core Strategy Issue and Option Report

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Black Country Core Strategy Issue and Option Report

Question 30 - Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites

Representation ID: 414

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites.

Full text:

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorities do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards. Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forward. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions, including transportation solutions, with applicants.

Object

Black Country Core Strategy Issue and Option Report

Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mec

Representation ID: 415

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Full text:

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding. It is for this reason that we endorse a higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).

Object

Black Country Core Strategy Issue and Option Report

Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health

Representation ID: 416

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Full text:

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Object

Black Country Core Strategy Issue and Option Report

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

Representation ID: 417

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Full text:

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Object

Black Country Core Strategy Issue and Option Report

Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

Representation ID: 418

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significantly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

Full text:

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significantly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the BCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employment sites.

In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajectory for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability, ground conditions, failure to release employment sites, we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the BCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.

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Black Country Core Strategy Issue and Option Report

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for exam

Representation ID: 419

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield.

Full text:

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield. It will be necessary to have regard to site constraints, parking requirements, offset distances, green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is important not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the density will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfield sites, particularly if these are expected to accommodate significant areas of green infrastructure.

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances. High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Support

Black Country Core Strategy Issue and Option Report

Question 37a - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why

Representation ID: 420

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Full text:

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Object

Black Country Core Strategy Issue and Option Report

Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and

Representation ID: 421

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should be considered.

Full text:

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should be considered.

Object

Black Country Core Strategy Issue and Option Report

Question 39 - Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more depe

Representation ID: 422

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

Full text:

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

Object

Black Country Core Strategy Issue and Option Report

Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.

Representation ID: 423

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation Summary:

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

Full text:

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

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