Yes

ID sylw: 106367

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC welcomes the Council’s approach in considering a balanced combination of Green Belt
land and brownfield land to accommodate its housing needs.
The Council will be preparing a Stage 2 Green Belt review and acknowledges that if there are “clear sustainability benefits to utilising one or more Green Belt locations, then this will form the basis of an argument that “exceptional circumstances” exist to justify releasing that land from the Green Belt.” It is positive to read that the Councils intend on assessing the Green Belt to identify whether there is
potential available “Grey Belt” land, which relates to areas of Green Belt which are previously developed or otherwise making a limited contribution to the five purposes of Green Belt. Furthermore, the SWLP intends to review villages that are currently included in the Green Belt and decide if any of them should be taken out as well as assessing if the built-up parts of these villages. This is welcomed by the WMHAPC as it will help to enable to Council to allocate appropriate sites for development and to
maximise the delivery of housing throughout the plan period.

Yes

ID sylw: 106368

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC supports the approach outlined in draft Policy Direction 8, as it aims to optimise land use effectively. Accordingly, the WMHAPC welcomes further guidance through a design code to ensure
that densification maximises affordable housing delivery while maintaining high quality homes that respect the local vernacular.
Future policies on density should allow for flexibility and nuance, considering the relationship between density, dwelling size (including implications of optional space and accessible/adaptable home standards), housing mix, and developable land. Future policies should be viability tested to take these factors into account.
Additionally, future policies should consider that when determining applications, the impact on delivering
a diverse range of housing typologies to meet the needs of different groups should be carefully evaluated, with scope for site specific considerations and case by case assessments where appropriate.

Other

ID sylw: 106369

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

Draft Policy Direction 9 explains that the Councils will make full use of suitable urban brownfield land before development is considered in other locations. While broadly supportive of this approach, we reiterate our comments made at Issues and Options consultation that the SW councils should be cautious to a brownfield led approach to development as it may hinder the delivery of affordable housing within the area. It is widely recognised that the development of brownfield land often has cost
implications that negatively impact the viability of delivering affordable homes at such sites.

Other

ID sylw: 106370

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

Draft Policy Direction 10 currently states that proposed developments should follow the latest housing needs assessment which is currently the HEDNA (2022). While this provides a good baseline, the WMHPAC advises that the SW councils take a flexible and evidence-based approach. It would be beneficial if the SWLP incorporates wording into its policy that sets out various circumstances where it may not be appropriate to follow the housing mix set out in the latest needs assessment, including
viability constraints, physical constraints associated with smaller sites, locational issues etc. This may allow the opportunity for the delivery of more affordable housing in the authority area and would help to ensure the right kind of residential development is being delivered on a case-by-case basis.

No

ID sylw: 106371

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

This draft policy A proposes the blanket application of Nationally Described Space Standards (NDSS) for all new residential developments. There are concerns that the blanket application of the NDSS across all residential development, including affordable tenures, will undermine the viability of many development schemes. This will potentially result in fewer affordable homes being delivered as optional technical standards have implications for build costs and sales values, with implications in turn for development viability.
We highlight that the Planning Practice Guidance (PPG) requires local authorities to justify the need for
NDSS through considering need, viability and timing.
In light of the above, it is not clear that the Council has provided evidence demonstrating the need for
NDSS across all new developments in SW. If the Council continues to seek the NDSS requirement, then it must do so in line with the PPG to ensure the policy is justified and found sound at examination.
It is also relevant that Homes England only requires affordable homes to meet 85% of the NDSS to receive funding. For affordable housing in particular, there may be instances where achieving NDSS is impractical and unnecessary, as it may result in for example, higher rental and heating costs.
On sites that deliver 100% affordable housing, NDSS presents issues in that it increases the risk of financial impairment.
With regards to accessible living standards, it is proposed that all new housing, including conversions and subdivisions, must meet accessibility and adaptability standards (M4(2)) and on developments of 10 or more homes, at least 10% of market homes and 25% of affordable homes must be wheelchair friendly (M4(3)). Whilst the WMHAPC accepts that there is a growing need for accessible and adaptable homes, there is however concern that the 10% requirement for M4(3) dwellings could have considerable implications on viability and overall affordable housing delivery in SW. Some sites and/or schemes do not lend themselves to the statutory provision of M4(3) units. In light of this, the WMHAPC requests that the Council exercises an element of discretion when considering proposals.

Yes

ID sylw: 106372

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC agrees that tackling issues such as climate change mitigation and adaptation should be prioritised, although rigid climate change and sustainable construction policies that have the potential considerably frustrate the delivery of affordable housing should be avoided.
Draft net zero and carbon policies among others should be carefully considered against Building Regulations and the Future Homes Standard which is being introduced from 2025 to avoid duplication and any potential inconsistencies. With the introduction of Building Regulations Part O, parts of draft Policy Direction 22 overlap with statutory requirements and are therefore unnecessary. Furthermore, Draft Policy H references a water efficiency standard of 110 litres per person per day, in line with Part G2 of the current Building Regulations. While the WMHAPC supports the inclusion of a provision to comply with the most up-to-date building regulations, the policy should be revised to avoid specifying
exact measures. Water efficiency standards are already addressed and enforced through Building
Regulations and repeating these standards in planning policy risks becoming outdated if regulations
change. To maintain flexibility and relevance, the policy should focus on compliance with current regulations without duplicating specific technical requirements.

Other

ID sylw: 106373

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC welcomes guidance for new developments with regards to design as it is a useful tool for understanding the expectations of the Council when putting forward planning applications. The WMHAPC asks the Council to be wary of ways in which overly restrictive design codes or demanding policies could impact development viability and therefore restrict the provision of affordable housing in SW.
The WMHAPC would also like to take the opportunity to raise that it is not just appearance but also the maintenance and management of design features and spaces should be considered when designing residential schemes which include an affordable housing element.
Furthermore, the WMHAPC advocates for a well integrated and varied distribution of affordable housing
within housing schemes should allow for social integration within the overall design, although the WMHAPC reminds the Council to consider the practical implications for housing associations when it comes to the management of their housing stock.
.Encouraging pepper potting across a scheme makes
management more difficult as the properties are more spread out. The WMHAPC would not encourage affordable housing to be grouped together in one area, instead recommending that affordable housing is clustered across a site, with policy expressing a maximum group size or range; approximately 10 dwellings forming each cluster on larger sites (circa 100+ dwellings) is often favoured.

Other

ID sylw: 106374

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

Draft Policy Direction 38 requires all new development proposals (unless exempt) must achieve a minimum of 10% BNG on-site or as a last resort, purchase statutory biodiversity credits from the government.
The WMHAPC would welcome the production of a BNG supplementary planning document and/or a further implementation note/guidance following the adoption of the Local Plan for developers to understand the costs of the mandatory BNG requirement such the purchase of credits from the council or alternative third parties. As the non-negotiable aspect of BNG requirements, the cost may impact on the viability of the sites and its ability to deliver against other policy requirements such as affordable housing, developers would need all information to be able to make an informed decision on possible options.

Other

ID sylw: 106375

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

It is currently unclear what a policy on Environmental Net Gain (ENG) would entail. If the Council wishes to pursue this as a policy in the next stage of consultation, justification for ENG is required alongside consideration of how such a policy may impact viability of developments and thus hinder the delivery of affordable housing in SW.

Yes

ID sylw: 106376

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC agrees that integrating existing and new Green and Blue Infrastructure (GBI) is important in order to support sustainable residential growth.
We also support the approach that a site’s BNG contribution will also count towards the overall Greening
Factor of a site. The WMHAPC recommend that the Councils provide further guidance on how GBI will be implemented and measured.
The WMHAPC advises that this draft policy is viability tested to ensure that it does not hinder the delivery of affordable housing in SW.