Comment

Representation ID: 220

Received: 05/01/2024

Respondent: Dennis R Whittaker

Quote:- "2. Developments of ten homes or more should provide a range of house types and sizes
that will meet the accommodation needs of both existing and future residents, in line with the most recently available information."
Quote:- "3. All developments of ten homes or more should achieve the minimum net density set out below, except where this would prejudice historic character and local distinctiveness as defined in Policy DLP55:
(3.a.) 100 dwellings per hectare where Table 8.2 accessibility standards for very high-density housing are met and the site is located within a Strategic Centre or Town Centre"
Table 8.2 shows that 100 DPH is Very High Density, 100% Flats and not really suitable for Families
- and we need at least a moderate proportion of Families living within Town Centres in order to provide firm foundations on which strong, stable, sustainable, Communities with a sense of belonging, can be built
Policy DLP1 paragraph 1.a sets an objective of creating "sustainable mixed communities"
Developments of about 100% Flats are likely to appeal to people buying or renting their first Home
as a prelude to moving to a house somewhere where they can settle and put down "roots". Creating a transient population would be the opposite of a "sustainable mixed community". Therefore, I object to such high density developments.

Comment

Representation ID: 293

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Current Housing Market Assessment identifies an annual affordable housing need of 867 dpa (which equates to over 20% of the LHN) and also highlights (at Figure 8.1) that the highest overall requirement is for 3-bedroom houses, followed by 4-bed houses, then 2-bed and 1-bed houses. However, the spatial strategy relies heavily on supply from within strategic centres, and Policies DLP11 and DLP12 expect such locations to deliver 100% flats with a ‘low’ indicative amount of housing suited to families, and just 10% affordable housing. That further demonstrates that an uplift above the LHN is required, and that greenfield sites (including Green Belt land) should be allocated to realise the required level of affordable housing delivery and an appropriate mix of houses of all sizes across the Borough. There is, therefore, very clear justification for DMBC to set a housing requirement that exceeds the SM derived LHN.

Comment

Representation ID: 314

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 11 Housing Density, Type and Accessibility
The policy specifies the density and type of new housing that should be provided, with new housing development to be informed by the need for a different type and range of size of accommodation, levels of accessibility and the need to achieve high quality design. The policy then goes on to state that developments of 10 or more homes should provide a range of house types and sizes and that developments of 10 or more homes should achieve the density target set out within the policy. These range from 100 dwellings per hectare on sites that are within strategic centres or town centres, down to 45 dwellings per hectare where a site is accessible for a high density housing site or 40 dwellings per hectare for a moderate density housing development. In seeking to achieve the density targets set out above we note the evidence contained in the Black Country Housing Market Assessment (March 2021). This sets out the size of housing required within each tenure within Dudley for owner-occupied, rented, shared ownership or social rented / affordable rented properties. What is clear is that for nearly all 4 of these tenures nearly 50% of the properties are required to be 3 or 4 bedroom properties. It is, therefore, highly debatable whether sites of 10 or more dwellings would be able to deliver the full range of dwellings required and the density specified within the policy. Three or four bedroom dwellings tend to be houses as opposed to apartments and would therefore deliver a much lower density development than a wholly flatted scheme.
Similarly, if high density development is to be achieved then this is likely to be comprised of 1 and 2 bedroom apartments and would not therefore deliver the full range of housing that the policy seeks.
Whilst it is noted that a range of densities are proposed in different parts of the Borough the Black Country Housing Market Report is clear that there is a significant demand across all tenures for 3 and 4 bedroom properties. If this need is to be met then sites and town centres or in the strategic centres, where new development is proposed to be focused, these area and sites are unlikely to deliver the larger properties that are required. This reinforces Barberry’s view that the range of different sites are required in order to help meet the housing needs of the Borough going forward.
A further consideration in seeking to achieve the density assumption set out in the policy also relate to meeting other aspirations and policy objectives in the Plan. This could include provision of open space, achieving high quality design and incorporation of National Described Space Standards. A combination of these and other policy considerations can and will impact on the density of development that can potentially come forward on sites.

Comment

Representation ID: 327

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

2.12. The remarks we have on this policy are limited in that we have concerns over the densities being set for town centres (100 dph) resulting in a large numbers of flats. Given the prevailing housing market in Dudley, Halesowen and Brierley Hill town centres, we do not consider there will be much support from Registered Providers for these types of homes as affordable housing, which have historically been difficult to manage and expensive for tenants and shared ownership customers because of higher management charges covering communal areas and facilities. We would urge the council to engage with Registered Providers over this policy as whilst such densities may work in neighbouring Birmingham, we would be concerned over the viability and implementation of such a policy without grant funding being in place.

Comment

Representation ID: 381

Received: 21/12/2023

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Policy DLP 11 Housing Density, Type and Accessibility
The policy specifies the density and type of new housing that should be provided, with new housing development to be informed by the need for a different type and range of size of accommodation, levels of accessibility and the need to achieve high quality design. The policy then goes on to state that developments of 10 or more homes should provide a range of house types and sizes and that developments of 10 or more homes should achieve the density target set out within the policy. These range from 100 dwellings per hectare on sites that are within strategic centres or town centres, down to 45 dwellings per hectare where a site is accessible for a high density housing site or 40 dwellings per hectare for a moderate density housing development. In seeking to achieve the density targets set out above we note the evidence contained in the Black Country Housing Market Assessment (March 2021). This sets out the size of housing required within each tenure within Dudley for owner-occupied, rented, shared ownership or social rented / affordable rented properties. What is clear is that for nearly all 4 of these tenures nearly 50% of the properties are required to be 3 or 4 bedroom properties. It is, therefore, highly debatable whether sites of 10 or more dwellings would be able to deliver the full range of dwellings required and the density specified within the policy. Three or four bedroom dwellings tend to be houses as opposed to apartments and would therefore deliver a much lower density development than a wholly flatted scheme.
Similarly, if high density development is to be achieved then this is likely to be comprised of 1 and 2 bedroom apartments and would not therefore deliver the full range of housing that the policy seeks.
Whilst it is noted that a range of densities are proposed in different parts of the Borough the Black Country Housing Market Report is clear that there is a significant demand across all tenures for 3 and 4 bedroom properties. If this need is to be met then sites and town centres or in the strategic centres, where new development is proposed to be focused, these area and sites are unlikely to deliver the larger properties that are required. This reinforces WL’s view that the range of different sites are required in order to help meet the housing needs of the Borough going forward.
A further consideration in seeking to achieve the density assumption set out in the policy also relate to meeting other aspirations and policy objectives in the Plan. This could include provision of open space, achieving high quality design and incorporation of National Described Space Standards. A combination of these and other policy considerations can and will impact on the density of development that can potentially come forward on sites.

Comment

Representation ID: 389

Received: 22/12/2023

Respondent: Cllr Wayne Little

Evidence shows that Brierley Hill has a disproportionately high number of one and two bedroom flats when compared to other areas of the Dudley borough. This starkly contrasts with the immediately surrounding areas such as Kingswinford, Wordsley and Stourbridge.

We strongly believe that the housing need in Brierley Hill is for more family homes (typically three and four bedrooms) not more flats (typically one/two bedroom).

The document proposes to build almost a thousand more flats within the Brierley Hill area over the next 20 years.
We see that this type of housing results in a higher level of transient population, who tend to only reside in the area for a shorter period of time.

Whereas a more settled community, with families laying down roots and investing their children's future in the area, builds a stronger, healthier and more economically resilient community.

We would therefore like to see the plan include an increase in the number of houses with three and four bedrooms, which will allow growing families to remain in the area of Brierley Hill, continuing to positively contribute to the economic and social outcomes of the area.

We feel this needs to be considered as a priority when planning the future allocation of housing, so this imbalance can be improved.

Comment

Representation ID: 400

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF would also question how realistic the densities proposed in criteria three are noting that the setting of residential density standards should be undertaken in accordance with the NPPF (para 125). HBF suggest that density needs to be considered on a site by site basis to ensure schemes are viable, deliverable and appropriate for the site, and policy needs to include some flexibility if needed to enable it to respond to site specific circumstances. HBF would question of the density proposed are realistic deliverable and viable as the deliverability of high-density residential development in Dudley will be dependent upon the viability of brownfield sites and the demand for high density city centre living post Covid-19. It is important that delivery of the housing requirement does not rely overly ambitious intensification of dwellings, and policy enables for the range of housing types and tenures to
be provided to meet the range of need and demand in Dudley.

Comment

Representation ID: 448

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 11 Housing Density, Type and Accessibility
Policy DLP 11 specifies the density and type of new housing that should be provided, the type, levels of accessibility and the need to achieve high quality design. The policy requires developments of 10 or more homes to provide a range of house types and sizes and achieve the density target set out within the policy. These range from 100 dwellings per hectare on sites that are within strategic centres or town centres, to 45 dwellings per hectare where a site is accessible and 40 dwellings per hectare for a moderate density housing development. In seeking to achieve the density targets set out above we note the evidence contained in the Black Country Housing Market Assessment (March 2021). This sets out the size of housing required within each tenure within Dudley for owner-occupied, rented, shared ownership or social rented / affordable rented properties. Whilst we support maximising densities in general terms the approach to dwellings mix should not be applied in all instances. For example, Revelan have submitted a planning application proposing the development of 94 dwellings on land to the north of Stourbridge town centre. 48 of these dwellings will be affordable. The mix and size of the properties has been established though working with an affordable housing provider. The scheme is tailored to meet an identified need for affordable housing. Scheme specific circumstances such as this should be taken into account in the application of the policy.

Comment

Representation ID: 464

Received: 19/01/2024

Respondent: CPRE Worcestershire

WM CPRE generally support Policy DLP 11 on Densities, and consider the standards set out in Para 3 appropriate. However, we think the Policy should also require developers to show that they have sought to make the most efficient use of land within a sustainable design approach, as some densities may comfortably be higher than these minima.

Object

Representation ID: 484

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

Page 112 – Table 8.2

This table sets out densities of new housing. The percentages of flats allowed on sites in urban areas can be up to 100%.

We think this is far too open-ended, in theory that means that you could have a development of say 500 flats in one location and we do not think that appropriate anywhere in the Borough.

Some developments might be 100% flats but there should be a numerical ceiling on the number of flats that are permitted as part of a single development even in a town centre.

Comment

Representation ID: 521

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Wording could be clearer and more effective for future residential development proposals.

Part 2 of this policy, states that the range of house types and sizes should be 'in line with the most recently available information" and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"Developments of ten homes or more should provide a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as:
• The Black Country HMA 2021 (or any subsequent revision);
• or Detailed Local Housing Market Assessments (where applicable); or Current and future demographic profiles;
• or Locality and ability of the site to accommodate a mix of housing;
• or Market signals and local housing market trends."

Additionally, paragraph 8.14 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs set out in the HMA", This is not however referred to in the policy wording itself nor does the HMA provide evidence that Dudley MBC will be undertaking a further HMA assessment specific to the authority area. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text needs to be clear about which evidence is to be used to inform housing mix. Paragraph 8.14 and Table 8.3 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.

Support

Representation ID: 620

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: Glen Dimplex Group

Policy DLP11 (Housing Density, Type and Accessibility)

In principle, Brockmoor Properties Limited generally support Policy DLP11 (Housing Density, Type and Accessibility), however the draft policy as currently worded could be clearer and more effective for future residential development proposals.

The draft policy promotes flexibility over the plan period for housing types to be assessed on a site-by-site basis which is important in the dynamic housing market and specific locational requirements. Part 2 of this draft policy however, states that the range of house types and sizes should be 'in line with the most recently available information' and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"Developments of ten homes or more should provide a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as:
The Black Country HMA 2021 (or any subsequent revision);
or Detailed Local Housing Market Assessments (where applicable);
or Current and future demographic profiles;
or Locality and ability of the site to accommodate a mix of housing;
or Market signals and local housing market trends."

Additionally, paragraph 8.14 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs set out in the HMA", This is not however referred to in the policy wording itself nor does the HMA provide evidence that Dudley MBC will be undertaking a further HMA assessment specific to the authority area. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text need to be clear about which evidence is to be used to inform housing mix and the wording suggested above would assist in removing ambiguity in the policy. Paragraph 8.14 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.

Comment

Representation ID: 624

Received: 05/01/2024

Respondent: South Warwickshire Council

The principle of establishing minimum densities for new housing, based on location and proximity to services and public transport, is supported. However, it is suggested that the baseline densities are in some cases inappropriately low, given the existing development pattern. It would be expected that many of Dudley’s historic Victorian terraces would have densities well in excess of 40 dph, which demonstrates that family housing can be successfully accommodated while optimising densities.
It is also anticipated that calculating the appropriate density for an application site could be complicated and subject to challenge from applicants. There is potential ambiguity existing around whether a particular facility should be used to determine accessibility, what mode of transport to use, and what distances could be reasonably covered by that mode of transport. It would be clearer and simpler if the Council included on its policies map zones where different minimum densities would apply. For example using buffer distances from public transport and town centres.

Comment

Representation ID: 644

Received: 22/12/2023

Respondent: TfWM and WMCA

Point 3.b needs to have a minimum stated of 50 dwellings per hectare not 45 (and should be the same for all 4 Black Country plans). This would make it consistent with Birmingham's plan and 50 dph allows more houses to be built in high density areas, supporting turn up and go frequency public transport.
In many other local plans across England, 50 – 60dph is often applied.
The local plan may also want to consider higher minimum housing densities for areas located along or close to high frequency public transport corridors or near to transport hubs.
We further welcome the ambition to maximise sustainable transport access to new developments, but we recommend developing a public transport accessibility criteria for residential developments. Depending on their location to high frequency transport corridors, stations and centres, this may be of value in the local plan. We are aware of Greater Manchester Combined Authority’s Places for Everyone Plan which maximises the number of people living in the most accessible places, helping to increase the proportion of trips made by walking, cycling and public transport, and reducing the demand for car-based travel, and TfWM would be happy to work with Dudley Planners to explore such a criteria if it chooses to do so.
Setting standards to deliver on density appropriate developments at certain locations which reflect the relative accessibility of the site by walking, cycling and public transport and the need to achieve efficient use of land would be welcomed. Also partnership working with TfWM and the WMCA to share and update Dudley’s sustainable transport access modelling is encouraged.

Comment

Representation ID: 682

Received: 25/01/2024

Respondent: NHS Property Services Ltd

Part (3.) of the policy sets out minimum net densities that should be achieved based on the
accessibility standards in Table 8.2, including access to primary care, and paragraph 8.12 seeks
investment to improve identified gaps in service provision against the standards in Table 8.2. As per
our comments on Policy DLP9 Part (4.), healthcare providers should have flexibility in determining
the most appropriate means of meeting the relevant healthcare needs arising from a new
development. We recommend the Council liaise with the ICB and other appropriate stakeholders to
ensure that the implementation of Policy DLP11 aligns with ICB requirements.