Black Country Core Strategy Issue and Option Report

We agree that Policy HOU1 of the adopted Core Strategy needs to be comprehensively reviewed. We agree that the proportion of housing built on previously developed land will need to be significantly changed. As referred to above the bias towards greenfield/Green Belt sites should be increased significantly.

We do not favour the prioritisation of brownfield land over greenfield land. This is not a Framework compliant approach. Given the considerable amount of housing required across the plan area it is 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, given their geographical detachment in the large parts of the Growth Network and will provide a different type of development sites.

In terms of a discount rate it is now evident that the Growth Network has not delivered houses as expected. It is, therefore, our clear view that there should be an increase in the discount rate that should result in the overall housing requirement being increased relatively significantly.

We make no comment at this stage about proposals for high density allocations within the strategic centres other than to say that market research should be carried out to ensure there is both demand and an appetite from the housebuilding industry to provide this type of product.

It is difficult to establish definitive density requirement at the present time. This is a site specific issue that will vary based on a range of factors. Individual sites will be affected by different site constraints such as topography, size of sites, on site constraints and access arrangements. In addition, general requirements will affect density levels such as parking requirements, offset distances, green infrastructure requirements and drainage requirements. All these factors can significantly limit the net developable area of a site. It is important not to overestimate densities which could be achieved in identifying sites to be released for development as this would result in the housing requirement not being met.

We would suggest the policy should be targeted to provide densities at 30 to 40 dph net depending upon site specific requirements. This is a density range that is attractive to housebuilders and can be accommodated having regard to normal infrastructure requirements and site constraints.

It is our view that the threshold should remain at 15 dwellings or more. Reducing the threshold below 15 dwellings is likely to make sites less viable.

Green Belt sites may have more exacting requirements in terms of green infrastructure and density than brownfield sites. This could well affect density. We therefore suggest that density standards of 35 dph net developable should be applied to Green Belt sites.

No. The SHMA does not fully assess affordable housing requirements as referred to above. As such, it cannot actually dictate an overall mix. In addition, housebuilders will provide housing to meet their assessment of localised market needs. This will change throughout the plan period. A static policy that does not flex during the course of the existing plan period would be inappropriate. We would also suggest that housebuilders have a better understanding of market requirements than the Local Authority.

We believe it would be prudent to keep the affordable homes target as originally set. Increasing it could create viability problems prevent the delivery of housing.

We believe that the site size threshold should be retained at 15 dwellings. This will assist in the delivery of smaller sites by smaller housebuilders.

Yes, we agree the figure should be retained at 25% subject to viability.

more likely to require new below ground infrastructure be provided such as drains, power supply etc. than brownfield land. Other physical and sociable infrastructure contributions will also be required such as education, transport etc. Therefore, greenfield sites are not necessarily more able to contribute to affordable housing than brownfield sites. We therefore believe the flat rate of 25% affordable housing provision across the plan area.

Policy DEL2 does need to be recast given that it is now evident that the supply of poor quality employment land that is available for housing has decreased. A revised version of Policy DEL2 is required that allows for existing active employment sites to expand whilst allowing the selective regeneration of the employment sites that are unlikely to deliver.