Part Two: Centres and Site Allocations (Regulation 19)

Comment

Representation ID: 1178

Received: 29/11/2024

Respondent: Brierley Hill Community Forum

Page 8 point B
Night time economy is all very well, but the Plan needs to recognise the negative impact this can have on people who live adjacent to such uses given the growth of people living in flats above shops in our towns.
We do not feel that there is a need for more pubs in Brierley Hill, and some of the extended licencing hours for the existing pubs already cause issues for people who live in the High Street town centre.

Comment

Representation ID: 1179

Received: 29/11/2024

Respondent: Brierley Hill Community Forum

Connectivity across the Strategic Centre
There is little in the plan about achieving connectivity across the strategic centre of Brierley Hill. In fact this is only referred to once.
“Delivering an integrated and accessible town centre” was a key objective of the Council’s 2011 Brierley Hill Area Action Plan – why is this not a key objective of the current draft Plan?
See pages 8-11 of the AAP which set out this as the first challenge for the AAP.
AAP 2011 page 9-
“New connections need to be made between the High Street, Waterfront and Merry Hill, and their surrounding areas, and sustainable transport options need to be enhanced to improve access to everyone”.
Given that Brierley Hill is now the strategic centre of the borough, we would expect a lot more emphasis to be placed on the need to join up its separate elements.
This should once again be a core objective of the new Local Plan.
At the moment Brierley Hill High Street, Merry Hill and the Waterfront all have very different identities and are effectively separated from one another by topography and physical barriers.
If one of the intentions of the plan is to promote Brierley Hill as a strategic centre, a key objective of the plan should be to propose ways in which these three distinct areas can be more effectively integrated. This could include physical connections such as bridges across the canal, better connectivity between the Waterfront and Merry Hill across Level St.
The potential residential development of sites between Merry Hill and Brierley Hill clearly offers the opportunity to create linkages and join up these areas. It is really important that when these sites are developed the opportunity is taken in their design to achieve a relationship with both Brierley Hill and Merry Hill.
We feel that this is a major failing of the Plan, and we do not understand why this objective which was set out so strongly in the 2011 AAP, has now been abandoned.

Comment

Representation ID: 1180

Received: 29/11/2024

Respondent: Brierley Hill Community Forum

We are pleased to see that the Council has revised downwards its housing target for Brierley Hill to a more realistic level.
However we do not consider that the high density of development proposed for most of these sites meet the housing need in the area nor is it deliverable in terms of market demand.
Housing Need

Disappointingly, the Plan does not include information on housing need for the plan period for the Brierley Hill area. We find this extraordinary, as this information is held by the Council’s Housing Strategy Team.

The Council’s Housing Strategy Team has produced a breakdown of the figures from the SHMA disaggregated into five sub-areas in the Borough as follows: (see attachment)

The housing need data collated by the Council at the Brierley Hill sub-area is as follows (see attachment)

So if we convert the housing need figures above by size into percentages, we get the following figures for new housing required in Brierley Hill sub area -

1 bed - 27%
2 bed - 25%
3 bed -24%
4 bed -23%

Conclusion from this data - There is as great a need for family housing in Brierley Hill sub area as there is for flats.


Existing Housing mix

These percentages being based on the "sub-area" which includes places such as Wordsley, Kingswinford North, Wall Heath and Kingswinford South (which have far fewer flats than Brierley Hill does), mask the fact that in Brierley Hill ward there is already a disproportionate oversupply of 1 and 2 bedroom properties; meaning that if the need was assessed for the ward on its own, the percentages would lean even more heavily towards a need for more 3 and 4 bedroom properties.

The data below provided by the Council shows Brierley Hill properties by number of bedrooms compared with Boroughwide by number of bedrooms.

Brierley Hill Ward
1 bedroom - 17.6%
2 bedroom - 34.4%
3 bedroom - 42%
4 bedroom - 6%

Summary
1 and 2 bedroom - 52%
3 and 4 bedroom (family homes) - 48%


Dudley Borough
1 bedroom - 9.5%
2 bedroom - 24.3%
3 bedroom - 51.4%
4 bedroom - 14.8%

Summary
1 and 2 bedroom - 33.8%
3 and 4 bedroom (family homes) - 66.2%

Conclusion from this data - there is already a higher proportion of flats in the Brierley Hill Ward than the borough average, and a corresponding lower ratio of 3 and 4 bedroom houses.

The Dudley Local Plan proposals for housing within Brierley Hill Strategic Centre

(see table in attachment)
This table excludes the Priority sites at Waterfront Way and Level Street/Daniels Land. If we look at the density of new homes proposed on the table of sites above per hectare, a number of them are 90-100 homes per hectare, that is the level of development you would expect in a 100% flat development.

See Policy DLP11 of Part 1 of the revised Local Plan which quotes -
very high density - 100+ homes per hectare
high density - 45+
moderate - 40+

Looking at the table of sites above, the total number of homes expected across all of these sites adds up to 948.

However 4 of those sites are at/over/near the very high density level of 100+ homes per hectare, totalling 671 flats minimum
- 71% of all new homes across these sites.

All of the other sites fall in the high density category, meaning small numbers of houses, probably none at all on some of these sites.

Conclusion from this data - the draft Local Plan proposes that a minimum of 71% of new homes across these sites be high density, ie, flats.

Overall Conclusion

The data above demonstrates that –

• The demand for family housing in Brierley Hill is as great as the demand for high density/flats;
• There is already a disproportionately high level of flats in Brierley Hill compared with the rest of the Borough;
• However the Local Plan proposes that a minimum of 71% of new homes across the sites listed above will be flats/high density development.

It is very clear therefore that this part of the Plan is unsound as it proposes a mix of housing for sites at Brierley Hill which will not meet the local housing need.

Instead of the houses that are needed, more flats will be built, despite the fact that there are already more flats in Brierley Hill than in any other part of the Borough.

The Plan should be revised to emphasise the need for more family housing and less flats.
Deliverability of High Density Development

Our view is that the proposal to build a large number of flats in Brierley Hill not be deliverable in market terms.

Some of the sites in Brierley Hill do lend themselves to flatted development, but this ignores the dynamics of the housing development market.
In theory building flats is good for the developer because it means they can get more properties on less land.

But this only works in areas where there is a strong demand for flats and where they will achieve good sales prices, like Birmingham City centre, not like Brierley Hill where the housing market is comparatively weak and house prices low compared with the borough average. The reality is that most people want to live in houses not in flats so flats tend to be slow sellers.

The other problem with building flats is that because of all the ancillary space associated with flats like corridors lifts service areas etc which the developer has to provide but which doesn't create any income, they are not much cheaper to build than houses.

But the real problem is cash flow.

A developer building out two and three bedroom houses builds those houses a few at a time and sells them as he works through the site, creating a constant cash flow which goes towards paying off his costs of labour, materials, borrowing etc.

The problem with building flats is that he has to build the whole block before he can either sell or let a single one, so in cash flow terms flatted schemes are really hard to make viable especially now that interest rates have gone up and look likely to stay where they are.

By proposing flats on those sites the Council are effectively making it less likely that anyone will build them out because the risks and costs associated with building flats are so much higher than building traditional housing.

So there are two problems with the Council’s proposals to build high numbers of flats in Brierley Hill.
The first one is that flats are not what most people in the local area either want or need.
The second one is that development of large numbers of flats in this location will not be attractive to developers, and this undermines the deliverability of new homes in the area.

Comment

Representation ID: 1181

Received: 29/11/2024

Respondent: Brierley Hill Community Forum

Housing at the Merry Hill Centre

We would like to see included as an aim in the plan the development of high quality housing within the Merry Hill shopping centre or car parks.
We believe that the centre will never achieve full occupancy again as a result of the changes to retail patterns and both part of the centre and the extensive car parks could be repurposed with a high quality residential offer.
We recognise that the current owners of the site are not considering this option, but longer term, and certainly during the Plan period, we think it is an appropriate aspiration which should be included in the Plan.