Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 103

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

Clause a) of policy DLP 17.
This does not seem logical, surely any conversion of family housing to a House of multiple occupation leads to a loss of family housing and surely there's a shortage of family housing across the borough so on this basis no conversions to HMOs should be permitted?
Clause d) on car parking, this is too vague in terms of the level of car parking required and we should be looking for a clear statement of the ratio of car parking spaces compared with the number of occupants in each property.
Paragraph 8.51 is confusing. On the one hand it says that planning permission is not normally required for an HMO but then it refers to the Article 4 direction, so which is it, is planning permission required or not?
Paragraph 8.56 again the implication of this paragraph is that conversion to HMO from a family home will never be permitted because clearly any such conversion reduces the number of family homes.
If the council is saying that it will not allow conversion of family homes to HMO's then it needs to make this a bit clearer but certainly this seems to be the implication in this section.

Object

Representation ID: 106

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

pages 115-8
This section is about affordable housing.
The key issue here is that the document uses the expression “where financially viable” which basically gives developers the ability to wriggle out of their affordable housing requirements obligations by claiming that the scheme is not financially viable.
All private sector developers are adept at producing financial viability assessments which demonstrate that affordable housing is not financially viable.
On page 118 the document does talk about the necessity for developers to produce financial viability assessments and the possibility that this may be externally scrutinised but again this is identified as a possibility not a certainty.
Our view would be that the council should either be stating that any site which falls within the threshold needs to provide affordable housing irrespective of financial viability, or the council should be stating that all schemes which claim that that it's not possible to provide affordable housing for financially viability reasons should be subject to independent scrutiny l) at the developer's expense.
Otherwise the council is just making a rod for its own back because it will be engaged in perpetual arguments between developers who are experts at manipulating financial viability whereas planning officers are not.

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.