Comment

Representation ID: 935

Received: 21/11/2024

Respondent: Dennis R Whittaker

I live in Brierley Hill where the extensive Chapel Street Estate consists of nine High Rise blocks of Flats and twelve Medium Rise blocks of Flats and Maisonettes. So, we already have more than our fair share of such Housing. Since the Brierley Hill Area Action Plan (2011) we have been classed as a Strategic Centre and, under Policy DLP11, are at risk of having more high density blocks of 100% Flats inflicted upon us. As this would be of low suitability for Families, a community imbalance would result. This would be neither wise nor good planning.

Support

Representation ID: 1019

Received: 27/11/2024

Respondent: Glen Dimplex Group

Agent: Glen Dimplex Group

Policy DLP11 - Housing Density, Type and Accessibility Policy DLP11 details the need for housing developments to deliver a range of types and sizes to meet sub-regional and local needs, as well as ensuring that new development has access to sustainable transport and achieves high- quality design. It imposes minimum density levels on developments with more than 10 dwellings providing they meet the Dudley Borough Housing Accessibility Standards (Table 8.2).

In principle, Glen Dimplex 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 current evidence base supporting this policy, and any relevant revisions" and refers then to Table 8.3. In our previous representations we noted that it was not clear whether the Local Planning Authority would be undertaking a HMA specific to the Dudley area. It is welcomed that this has now been completed and incorporated into the policy.

Table 8.3 sets out the mix identified in the Dudley Housing Market Assessment (September 2024) (HMA) and is generic for across the Borough as a whole rather than on more localised markets. However we consider that for this policy to be positively prepared in accordance with Paragraph 16 and 35 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 Dudley HMA 2024 (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."

Providing a broader source of market information will enable housing developments to be brought forward in accordance to the market dynamics at the time of submitting a planning application, should the HMA be considered out of date.

Furthermore, this will enable this policy to be considered 'effective' as such wording will allow the housing requirement to be deliverable in an ever changing market, providing Applicants with the flexibility to bring forward additional sites as required. Additionally, in terms of being positively prepared, this will enable the LPA to meet the Borough's OAN by encouraging development appropriate to the location.

Object

Representation ID: 1081

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

What is clear is that for 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. Focusing on delivering apartment led development will also curtail the delivery of affordable housing as RPs are less inclined to take on units in mixed tenure blocks.

Whilst it is noted that a range of densities are proposed in different parts of the Borough the Dudley Housing Market Assessment 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 in town or strategic centres, where a significant proportion of new development is proposed to be focused, 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 and accessible homes along with sufficient car parking on site. A combination of these and other policy considerations can, and will, impact on the density of development that can potentially come forward on sites. If all these are to met on sites the amount of land required to do so will need to increase.

Barberry object to Policy DLP11 on the basis that it is not effective and will not result in the majority of housing needs, which are predominantly for 3 and 4 bedroom properties, being met. Meeting the actual housing needs of those in the Borough in need of a home appears to have been sacrificed for higher density flatted development where the actual need is for family housing. Barberry do not consider that sufficient land has been identified to meet these density targets whilst also at the same delivering a number of other policy objectives and aspirations such as POS, car parking and accessible homes.

Support

Representation ID: 1142

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

The Policy is prescriptive in that the density and type of housing to be provided should reflect local needs and the accessibility of the site. Great emphasis is placed upon high density 100 dph development in accessible locations, with other standards seeking to push development densities to high levels.
Concerns are set out here about this approach on the basis that firstly the approach doesn’t align with needs set out in the Housing Market Assessment. Within the HMA Update and reflected in Table 8.3, nearly 50% of needs are for properties with 3 or 4 bedrooms, more typical of family housing. The extent to which this can be accommodated at high densities within the urban area is unrealistic, indeed a number of the sites allocated in the Plan would be unrealistic for this major housing need.
Secondly the densities set out in policy have not been market tested. The extent to which they are both realistic to be taken up in the market and in demand has not been set out in the evidence. Whilst such an approach conveniently increased the theoretical urban capacity, there is nothing in evidence to suggest these high density forms of urban living will be realistically deliverable within Dudley, when they are still challenging in many other more buoyant market locations such as Birmingham City Centre for example.

Comment

Representation ID: 1175

Received: 29/11/2024

Respondent: Brierley Hill Community Forum

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.

Object

Representation ID: 1289

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The Council’s approach to density responds positively to the requirements of the Framework to make effective use of land. However, the minimum densities set out in criteria 3 of DLP11 is a concern, when taking into consideration other requirements for developments including mandatory Biodiversity Net Gain, SUDS, proposed requirements for tree planting, public open space and other infrastructure needs.

It is considered that if the Council has based the capacity of site allocations on achieving or exceeding these minimum densities, the proposed capacity of housing allocations should be taken with caution, noting that it may not be feasible or appropriate to seek to deliver these densities. Further to concerns regarding the number of dwellings proposed through this emerging Plan in any case, the council should ensure that a robust and realistic approach to housing numbers has been taken in this regard. This should also be a consideration in respect of other priorities for the emerging Plan, recognising the need to balance expectations in terms of design and green infrastructure, whilst also seeking to secure appropriate levels of housing density to seek to meet local housing needs and respond positively to national policy requiring effective use of land. It is considered that the Plan as currently drafted has not given enough consideration to the inter-related nature of these issues, and there is a conflict in policy that should be addressed before the Plan proceeds to examination.

Object

Representation ID: 1321

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP11 on Housing Density, Type, and Accessibility is considered unsound by the Home Builders Federation (HBF) due to a lack of justification, effectiveness, and alignment with national policy.

Density Standards: HBF questions the proposed residential densities in criteria three, suggesting that density should be considered on a site-by-site basis to ensure schemes are viable and deliverable. They call for flexibility in the policy to account for site-specific circumstances.

Viability and Deliverability: HBF raises concerns about the realism and deliverability of high-density developments in Dudley, particularly regarding brownfield sites and the demand for high-density city-center living post-COVID-19. They warn against relying too heavily on overly ambitious intensification of dwellings, stressing that the policy must allow for a variety of housing types and tenures to meet diverse housing needs in the area.

Object

Representation ID: 1359

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DLP11 The use of a threshold of 10 dwellings is a distorting factor, encouraging developers to bring forward sites of 9 houses, so as not to have to comply with the density and other policies. Further detail on adverse effect of high thresholds is provided in the objection to DLP12

Object

Representation ID: 1375

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The Council’s approach to density responds positively to the requirements of the Framework to make effective use of land. However, the minimum densities set out in criteria 3 of DLP11 is a concern, when taking into consideration other requirements for developments including mandatory Biodiversity Net Gain, SUDS, proposed requirements for tree planting, public open space and other infrastructure needs.

It is considered that if the Council has based the capacity of site allocations on achieving or exceeding these minimum densities, the proposed capacity of housing allocations should be taken with caution, noting that it may not be feasible or appropriate to seek to deliver these densities. Further to concerns regarding the number of dwellings proposed through this emerging Plan in any case, the council should ensure that a robust and realistic approach to housing numbers has been taken in this regard. This should also be a consideration in respect of other priorities for the emerging Plan, recognising the need to balance expectations in terms of design and green infrastructure, whilst also seeking to secure appropriate levels of housing density to seek to meet local housing needs and respond positively to national policy requiring effective use of land. It is considered that the Plan as currently drafted has not given enough consideration to the inter-related nature of these issues, and there is a conflict in policy that should be addressed before the Plan proceeds to examination.

Object

Representation ID: 1612

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL objects to Policy DLP11, which sets density and housing type requirements for new developments. The policy mandates that developments of 10 or more homes should meet specific density targets, ranging from 100 dwellings per hectare (dph) in strategic or town centers to 40-45 dph for moderate-density areas. However, the Dudley Housing Market Assessment (2024) indicates a significant demand for 3- and 4-bedroom homes, which are typically houses rather than apartments. This makes it difficult to achieve the required density targets while meeting the housing needs for larger family homes.

High-density developments would likely consist of smaller apartments, which do not align with the demand for larger homes. WL argues that focusing on density targets could result in a mismatch between the housing type needed and what will be delivered, particularly in town or strategic centres. Additionally, achieving high-density housing while meeting other policy objectives, like open space, design quality, and accessibility, further limits the ability to meet the housing needs for families. WL believes the policy is ineffective and that it prioritizes density over meeting the actual housing needs of the Borough.