Sandwell Local Plan - Reg 19 Publication

Ends on 11 November 2024 (26 days remaining)

7. Sandwell's Housing

Introduction

7.1 The policies in this chapter will help to create a network of cohesive, healthy and prosperous communities across Sandwell. This is a fundamental element of the Plan's Vision and objectives and will help deliver its strategic priorities. The policies will also ensure the provision of a balanced range of housing in terms of type, tenure, wheelchair accessibility and affordability, and specialist provision for Gypsies, Travellers and Travelling Showpeople and for those who wish to undertake self-build or custom build. New housing is expected to be of a high build quality and will need to be well-designed, including meeting national space and water efficiency standards and delivering high levels of energy efficiency and adaptation to climate change. In addition, maximising sustainable transport access to key residential services and focusing high-density housing in areas of greatest accessibility is at the heart of the Spatial Strategy, helping to deliver Strategic Objectives 6, 7 and 15.

7.2 Providing a balanced network of well-designed and education facilities is a further key part of this approach. Creating fit-for-purpose and modern learning environments that enable pupils to concentrate on their studies in welcoming and safe environments will in turn support ongoing and future economic prosperity.

Sustainable Housing Growth

7.3 A key role of the SLP is to set out realistic targets for the delivery of sustainable housing growth over the plan period up to 2041.

Grove Lane/ Cranford Street/ London Street (1) Chances Glass Works (2) Evans Halshaw car showroom (3) Army Reserve, Carters Green (4) Cultural Quarter, West Bromwich (5) Lion Farm, Oldbury (6) West Bromwich Central (7) West Bromwich Central (8) George Street Living (9) Queens Square Living (10) Policy SHO1 - Delivering Sustainable Housing Growth 

  1. Sufficient land will be provided to deliver at least 10,434 net new homes over the period 2024 - 2041.
  2. The key sources of housing land supply are summarised in Table 5, which also provides an indicative number of homes to be delivered in the following timeframes: 2024 - 2029, 2029 - 2034, 2034 - 2039 and 2039 - 2041. Housing allocations are set out in Appendix B.

Table 7 - Housing Land Supply – sources

Source of Supply

Type of Supply

2024-2029

2029 - 2034

2034 - 2039

2039 - 2041

Total

Current Supply

Site under construction

883

6

0

0

889

Sites with Planning Permissions or Prior Approval

787

97

0

0

884

Sites with Other Commitments (as set out in 2024 SHLAA)

24

17

0

0

41

Allocated

Occupied Employment Land

224

916

770

333

2243

Other Non-Occupied Employment Land

158

1349

797

0

2304

Sites with Planning Permission

1142

288

95

95

1620

Sites Under Construction

76

0

0

0

76

Total Identified Sites

3293

2673

1662

428

8057

Total Windfall Allowance

Small sites (<10 homes / 0.25ha)

0

875

875

350

2100

Additional floorspace in centres

West Bromwich

0

5

0

0

5

Town Centres

0

72

0

0

72

District and Local Centres

0

95

0

0

95

Total additional floorspace in centres

0

172

0

0

172

Additional supply in Wednesbury Master Plan 

0

105

0

0

105

Total Supply

3293

3825

2537

778

10434

Gypsy and Traveller pitches

10

0

0

0

10

 Discounted by 5%   Discounted by 10%   Discounted by 15%

  1. Most of the requirement will be met through sites with existing planning permission and sites allocated for housing by this Plan. Additional housing supply will also be secured on windfall sites throughout the urban area.
  2. The development of sites for housing should demonstrate a comprehensive approach, making best use of available land and infrastructure and not prejudicing neighbouring uses. Incremental development of an allocated site will only be allowed where it would not prejudice the achievement of high-quality design across the wider site. Masterplans and other planning documents[159] will be produced, where appropriate, to provide detailed guidance on the development of allocations.
  3. Ancillary uses appropriate for residential areas, such as health facilities, community facilities and local shops, may be acceptable where there is a gap in service provision and where they can be integrated successfully into the residential environment. Other uses will not be acceptable on these sites.

Justification

7.4 The council has identified sufficient land to provide 10,434 additional homes by 2041. 97% of the supply is on brownfield land and 3% is on undeveloped sites. The Sandwell Policies Map illustrates the distribution of housing sites across the borough. A balanced range of sites has been provided, in terms of size, location and market attractiveness, which will help to maximise housing delivery over the Plan period. Across the borough, 10% of identified supply in the Plan and in the most recent Brownfield Register is on sites no larger than 1ha, which is in accordance with the requirement set out in the NPPF at paragraph 070.

7.5 The details of proposed housing allocations are provided in Appendix B and sites are shown on the Policies Map. Housing capacity has been identified in accordance with the Spatial Strategy and is based on the following information:

  1. Strategic Housing Land Availability Assessments (SHLAAs) and the Black Country Employment Area Review (BEAR);
  2. an estimate of the likely scale of housing renewal up to 2041;
  3. an estimate of likely windfall development on small sites up to 2041;
  4. an assessment of the capacity of West Bromwich strategic centre above existing supply, drawing on the West Bromwich Master Plan and Interim Planning Statement;
  5. an estimate of the likely capacity of vacant floorspace in town, district and local centres;
  6. application of a density uplift to existing allocations likely to gain permission after 2025, in line with Policy SHO3;
  7. an estimate of the additional 'aspirational' growth that will be delivered in the regeneration areas and on sites identified in masterplans and other supplementary guidance;
  8. a comprehensive land review and site assessment process.

7.6 The housing supply from allocations on occupied employment land has been discounted by 15% to take account of the multiple delivery constraints that typically affect such sites and that are likely to reduce delivery on a minority of sites. Delivery constraints include poor ground conditions and the need for large-scale master-planning, land assembly, business relocations and residential service access improvements.

7.7 The supply from other commitments in the current supply and allocated in the urban area has also been discounted by 10% to allow for non-implementation, as some of these sites are also affected by delivery constraints such as poor ground conditions.

7.8 The supply from sites with planning permission but not yet under construction has been discounted by 5% in accordance with historic lapse rates. These discounts are balanced rates that take account of the likely availability of external funding to address constraints, as set out in the Viability and Delivery Study.

7.9 Together, these discounts provide sufficient flexibility in the housing land supply to meet any unforeseen circumstances.

7.10 Allowances for structural change, as detailed in the Urban Capacity Review (2024), are made up of two sources - potential sites and surplus floorspace within West Bromwich Strategic Centre (drawing on the West Bromwich Master Plan and Interim Planning Statement) and for Tiers Two and Three centres (as defined in Policies SCE4 and SCE5). The structural change allowances are over and above the small windfall site allowance. The latter represents a continuation of historic rates, whereas the former represents a structural change in the factors giving rise to new housing sites which is predicted will generate additional supply over the Plan period. These include changes to shopping patterns, permitted development rights and work patterns arising from COVID impacts.

7.11 The Plan period has been divided into four phases, covering every five years from 2024. Housing targets for each phase are provided in Table 5. These are based on the housing trajectory set out in Appendix I, with further detail provided in the SHLAA. The trajectory demonstrates a steady supply of housing completions over the Plan period, justifying consistent housing targets throughout the Plan period. As set out in the NPPF (paragraph 76), the Council is seeking to confirm through the SLP the existence of a five - year housing land supply from the year of adoption (2025). For this purpose, the buffer applied to housing supply (as set out in the housing trajectory) will be 20%, in line with the most recent Housing Delivery Test results (2023).

Windfall Development

7.12 A robust small windfall site allowance has been included in the supply, which reflects historic completion rates for sites of less than ten homes. Windfall sites are subject to policy, sustainability, and detailed site considerations.

Policy SHO2 – Windfall developments

  1. Proposals for residential development on sites not specifically allocated for residential use (windfall developments) will be permitted where the site is previously developed land and in accordance with other local plan policies.
  2. Proposals for residential development on unallocated greenfield land will be resisted. Such sites will only be considered where:
    1. the site is not protected open space;
      or
    2. the site is Council-owned land that is deemed surplus to requirements;
      or
    3. the development of the site will bring an under-used piece of land back into beneficial use and will not harm the environmental or ecological value of the site and the wider area, in accordance with other relevant policies in the SLP, or cause harm to the significance of heritage assets, including their setting.

Justification

7.13 In addition to the sites allocated for residential development within the Plan, it is recognised that other sites will become available for development during the Plan period as it is impossible to identify all potential redevelopment proposals that may arise within an urban area such as Sandwell. These sites are likely to include surplus public land, small non-conforming employment uses and some residential intensification sites where appropriate. However, greenfield proposals will only be considered if they meet the criteria above.

Housing Density, Type and Accessibility

7.14 It is important that the new homes delivered over the plan period:

  • are provided in places with good sustainable transport access to key residential services;
  • can provide a mix of types and densities that are appropriate to their location; and
  • can help to meet local needs.

Policy SHO3 - Housing Density, Type and Accessibility

  1. The density and type of new housing provided on any housing site should be informed by:
    1. the need for a range of types and sizes of accommodation to meet identified local needs;
    2. the level of accessibility by sustainable transport to residential services, including any improvements to be secured through development, as set out in Table 6; and
    3. the need to achieve high-quality design, to mitigate and adapt to climate change. and minimise amenity impacts, considering the characteristics and mix of uses in the area where the proposal is located.
  2. The council will aim to provide an overall mix of house types over the plan period, tailored to best meet local needs and will support development that creates mixed, sustainable and inclusive communities. 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.
  3. All developments of ten homes or more should achieve the minimum net density, on the net developable area, set out below, except where this would prejudice historic character and local distinctiveness as defined in Policy SHE2:
    1. 100 dwellings per hectare where Table 6 accessibility standards for very high-density housing are met and the site is:
      1. located within a Strategic or Town Centre detailed at Table 10;
      2. identified for very high-density housing within a masterplan and / or design brief agreed with the council; or
      3. considered suitable for very high-density housing in accordance with guidance in the council's Design Code.
    2. 45 dwellings per hectare where Table 6 accessibility standards for high density housing are met;
    3. 40 dwellings per hectare where Table 6 accessibility standards for moderate density housing are met.
  4. Table 6 provides details of the appropriate density and, where appropriate, house type mix, to be sought on each housing allocation site, in accordance with the requirements set out in this Policy. Further details of design requirements for housing developments will be set out in Sandwell's Design Codes.

Table 8 - Minimum Housing Densities and Accessibility

Density (homes per hectare net)

Very High: 100 +

High: 45 +

Moderate: 40 +

Indicative proportion of flats

100%

>15%

0 – 15%

Indicative amount of housing suited to families

low

medium

high

Accessibility (by either walking or public transport, unless stated)

Employment - Strategic Centre or other employment area

20 mins

20 mins

30 mins

Health – Primary Care e.g., GP Surgery or Health Centre

10 mins

10 mins

15 mins

Fresh Food - Centre or food store

n/a

10 mins

15 mins

Education - Primary School (walking distance only)

n/a

15 mins

10 mins

Education - Secondary School

n/a

25 mins

20 mins

  1. Any development that fails to make efficient use of land, by providing a disproportionate number of large, 4+ bedroom homes when compared with evidenced local housing need, will be refused in accordance with the requirements of this policy.
  2. Development proposals should be consistent with other Local Plan policies.

 Justification

7.15 Achieving an appropriate density and mix of house types is crucial both to the success of each new housing development and the overall sustainability of the Spatial Strategy. It is important that every major development of ten homes or more contributes to providing the mix and density that best aligns with current local needs. Achieving this will also help to protect and improve residents' physical, social and mental health, as outlined in the Health and Wellbeing section.

7.16 The accessibility of housing developments to a range of residential services by walking, cycling or public transport is key to achieving sustainable communities. As higher density developments will accommodate more people, they should generally be delivered in those areas with good access to services, to encourage use of sustainable transport modes. The highest densities of 100 homes per hectare or more should be in areas with the best access to public transport and services, but also where a high proportion of flats will provide design solutions that best reflect historic character and local distinctiveness. Therefore, such densities will only be acceptable within West Bromwich Strategic Centre, the Town Centres or other appropriate locations identified by Policy SHO3 where accessibility standards are met.

7.17 Conversely, lower density developments, accommodating more families, should enjoy high levels of accessibility to schools. Not all developments with good sustainable access to services will be suited to the highest densities – in some cases a lower density will be more appropriate, for example in areas of historic character, to reflect the density of adjacent uses or to meet the need for a mix of housing types.

7.18 Table 6 provides access standards for differing house type mixes / densities, in relation to four priority residential services: employment, health, fresh food and education. Proxies have been selected for each service. Employment is represented by West Bromwich Strategic Centre and retained employment areas. The proxy used for fresh food is a centre, or an existing food store outside a centre, that currently provides a range and choice of fresh food. The access standards have been developed based on survey evidence regarding the distance people are prepared to travel to each service by foot and public transport and are designed to help create well-connected and walkable neighbourhoods. Although open space does not form one of the priority residential services for the purposes of establishing the appropriate density and type of housing, Policy SHW4, taken together with local standards and policies, will ensure that a sufficient quantity and quality of different types of open space is available close to where people live.

7.19 Housing developments of ten homes or more will be expected to meet the accessibility standards set out in Table 6, which vary according to density and likely house type mix. The priority is for the service needs of future communities to be served by the existing network of centres, to ensure their future vitality and viability, and to secure future regeneration. Any on-site service provision potential required to meet accessibility standards is identified in the housing allocations. Where there is an identified gap in service provision against one or more of these standards, investment will be sought to improve either service provision or access to existing services sufficient to ensure standards are met.

7.20 New service provision, including for centre uses, should be located and justified in accordance with Policies SCE3 and SCE4.

7.21 Current accessibility to residential services by sustainable transport modes across Sandwell has been modelled. This modelling shows the high levels of accessibility achieved by the Spatial Strategy. However, there are some gaps in provision that will need to be addressed through service or access improvements. The model will be updated on a regular basis to reflect changes in service provision and public transport services. Local circumstances, such as planned changes to service provision, will be considered when assessing accessibility on a site-by-site basis.

7.22 The Sandwell Housing Market Assessment (HMA) 2024 demonstrates that new households generated by 2041 will need the following mix of home tenures and types:

Table 9 - New housing types and tenures in Sandwell

Size of home

Market Housing[160]

First Homes[161]

Shared Ownership

Social / affordable rented

Total

1 bedroom

18%

15%

25%

26%

19%

2 bedrooms

28%

23%

32%

20%

26%

3 bedrooms

27%

25%

27%

20%

26%

4+ bedroom

27%

37%

16%

34%

29%

It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person.

7.23 Land supply is limited, and this has an impact on the number of homes that can be delivered, therefore it is essential that any new development makes the most efficient use of the land. On sites where homes are proposed to be delivered, the Council will be looking for housing sizes that improve the choice in an area; the Council will also expect smaller family housing to be included in the overall mix of housing. Furthermore, new developments need to provide a range of typologies / mix of homes to complement the existing / surrounding housing context; a consistent run of overly large units on a site can be at odds with neighbouring sites in terms of street or plot context. Therefore, developments that fail to make the most efficient use of land by proposing developments of 4+ bedroom homes when compared with evidenced local housing need, will be refused in accordance with the requirements of this policy and Policy SHO1.

Affordable Housing

7.24 To meet local needs, a sufficient proportion of new homes provided over the plan period should be affordable.

Grove Lane/ Cranford Street/ London Street (1) Great Barr with Yew Tree Ward (2) Oldbury Ward (3) Langley Ward (4) Policy SHO4 - Affordable Housing

  1. Developments of ten homes or more should, where financially viable, provide a range of tenures that will meet the accommodation needs of both existing and future residents, in line with the most recently available information.
  2. All developments of ten homes or more should provide a proportion of affordable housing on site where this is financially viable. Only in exceptional circumstances would a commuted sum be acceptable instead of on-site provision. Smaller sites, which could reasonably be expected to form part of a major development in the future, will also need to take this policy into account. The minimum proportion of affordable housing that should be provided[162] is:
    1. On all sites in lower value zones and brownfield sites in medium value zones – 10% affordable housing;
    2. On greenfield sites in medium value zones – 15% affordable housing;
    3. On all sites in higher value zones – 25% affordable housing.
  3. 25% of the affordable homes required by this policy will be First Homes tenure, as defined in national guidance.
  4. Beyond the tenure requirements set out in Parts 2 and 3 of this policy, the tenure and type of affordable homes sought will be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations.
  5. Where providing the applicable percentage of affordable homes (as set out in Part 2) cannot be achieved, the maximum proportion of affordable housing will be required that does not undermine the development's viability (Policy SID1).
  6. The affordable housing created will remain affordable in perpetuity.

Justification

7.25 Rising house prices and low average incomes over a long period have made market housing increasingly unaffordable for many Sandwell households. The Sandwell HMA (2024) identifies a requirement for 17.5% of new homes to be made available for affordable or social rent, 7.8% to be shared ownership and 8.3% to be First Homes. To meet this level of need over the Plan period, 33.6% of new housing would have to be affordable. Sandwell aspires to provide this level of affordable housing, through a range of schemes delivering up to 100% affordable housing funded through grant and other financial sources and supported by developer contributions where viable.

7.26 The Viability and Delivery study demonstrates that viability varies greatly according to local housing values and whether the site is greenfield or brownfield. Therefore, a sliding scale of affordable housing requirements, ranging from 10% to 25%, has been set out in Policy SHO4, which reflects this variation. The affordable housing value zones are shown in Figure 5. This approach should ensure that viability appraisals are not required at planning application stage for many sites. However, viability issues can vary significantly from site to site and are often caused by poor ground conditions, the extent of which cannot be accurately assessed until planning application stage. Therefore, to maximise delivery of affordable housing over the Plan period, it is important that affordable housing is sought on all eligible sites, that viability is assessed on a site-by-site basis where required, and that a flexible approach is employed wherever possible to allow for changing market conditions.

7.27 The current affordable housing value zones are based on the current ward boundaries. Should the ward boundaries change then the value zones will be realigned to the new boundaries and viability within the affected ward(s) will be reassessed.

Figure 5 - Sandwell Affordable Housing Value Zones

Lower Value Affordable Housing Value Zones: Wednesbury North, Tipton Green, Great Bridge, Greets Green and Lyng, St. Pauls, Langley, Smethwick, Soho and Victoria, Abbey. Medium Value Affordable Housing Value Zones: Princes End, Wednesbury South, Friar Park, Hateley Heath, West Bromwich Central, Oldbury, Cradley Heath and Old Hill. Higher Value Affordable Housing Value Zones: Great Barr with Yew Tree, Charlemont with Grove Vale, Newton, Tividale, Rowley, Blackheath, Bristnall, Old Warley.

7.28 Provision of affordable housing is through on-site provision; commuted sums in lieu of on-site provision will only be accepted in exceptional circumstances where all other avenues have been explored and found to be unsuitable. Commuted sums will be calculated using the following method:

  1. The amount payable per dwelling will be a sum equal to the difference between the appropriate RP purchase price and the market valuation of an equivalent dwelling in the locality (with a distinction between rented units and shared ownership units).
  2. Typically, a RSL would pay 50% of the market value for a social rented unit, 55% for an affordable rented unit and 70% for a shared ownership property.
  3. Example:
    Market Valuation = £150, 000
    For a social rented unit this would be:
    • purchase price (social rented unit) at 50% of market value = £75,000
    • commuted sum = £150,000 - £75,000 = £75,000

    For an affordable rented unit this would be:
    • purchase price (affordable rented units) at 55% of market value
    • commuted sum = £150,000 - £82,500 = £67,500

    For a shared ownership unit this would be:
    • purchase price (shared ownership) at 70% of market value = £105,000
    • commuted sum = £150,000 – £105,000 = £45,000

7.29 Any costs associated with negotiating a commuted sum, including the cost of site/property valuations, will be met by the developer directly.

7.30 The timing of the payment of commuted sum will be in accordance with a payment schedule agreed with the Council.

7.31 The tenure of affordable housing to be funded by developers through planning obligations is constrained by national planning policy, as set out above. At least 25% of any affordable homes funded should be First Homes tenure – a specific kind of discounted market sale housing to be sold at 30% below current market value, to eligible persons only, at every future sale[163]. National guidance allows for evidenced local variations in First Homes requirements, however there is no evidence that such variations are required in Sandwell. In addition, the NPPF (paragraph 66) requires at least 10% of all homes on major developments (of ten homes or more) to be affordable home ownership tenure. Annex 2 of the NPPF provides a definition of affordable home ownership[164].

7.32 Beyond national requirements, the tenure and type of affordable housing required over the Plan period will vary according to local housing need and market conditions. In general, a mix of tenures will be sought on all sites of ten homes or more, to help create mixed communities across the borough. However, there may be circumstances where this goal is better achieved through the provision of 100% affordable housing development to boost affordable housing provision, or through delivery of 100% market housing development with off-site provision of the affordable housing requirement.

Delivering Accessible and Self-build and Custom Housing

7.33 To meet local needs, a sufficient proportion of new homes provided over the plan period should be accessible, and enough plots should be provided to meet local demand for self-build and custom build housing.

Policy SHO5 - Delivering Accessible and Self / Custom Build Housing

National Accessibility Standards

  1. All new homes will be required to meet M4(2) (Category 2: Accessible and adaptable dwellings) requirement in Building Regulations[165].

Self-Build, Custom Build and Community-led / Co-operative Housing Schemes

  1. On developments of 100 homes or more, where there is currently a demand for self-build and custom build plots (defined as the number of entries added to the self-build and custom build register in the most recent base period for the local authority where the site is located), at least 5% of plots should be made available for self-build or custom build, or sufficient to match demand if lower.
  2. All plots set aside for self-build or custom build housing (secured via a legal agreement or planning condition) must include:
    1. legal access onto a public highway;
    2. water, foul drainage, broadband connection, and electricity supply available at the plot boundary;
    3. sufficient space to build without compromising neighbouring properties and their amenity and the amenity of future occupiers; and
    4. an agreed design code or plot passport for the plots.
  3. If a plot remains unsold after six months, after a thorough and proportionate marketing exercise that includes making details available to people on the custom and self-build register, the requirement to make the plot available for self-build or custom build will fall away.
  4. Where appropriate, Sandwell Council will support the delivery of community-led / co-operative housing[166] proposals, particularly where they can help provide social / affordable housing options that meet the specific requirements of local residents.

Justification

Accessible and adaptable homes

7.34 Sandwell Council will work with partners to meet identified needs to accommodate older people, people with disabilities and those with other special needs. The Sandwell HMA (2024) concludes that an additional 6,510 accessible and adaptable homes will be required by Sandwell households in 2041 due to disability or old age.

7.35 There is a need for these types of home across all tenures. This implies that a significant uplift will be required to the number of homes that meet these standards currently. Although some improvements to existing homes funded through Disabled Facilities Grants may contribute towards this uplift, the provision of new homes meeting the standards would reduce the need for adaptations to be retrofitted and make the housing stock more responsive to the evolving needs of the local population.

7.36 People's housing needs change as they get older, and homes designed in a way that makes them more easily accessible and adaptable allow people to stay in their own homes for longer. With public health and social care strategies placing more emphasis on supporting people in their own homes rather than moving to residential care, it is important that more adaptable and accessible homes are provided. Studies have shown that older properties are generally less accessible, and harder to adapt.

7.37 In line with new Building Regulations all new homes must meet the M4(2) (Category 2: Accessible and adaptable dwellings) requirement. Accessible and adaptable homes that meet the M4(2) Building Regulations are designed and built to a standard that meets the needs of occupants with differing needs, including some older or disabled people, and are only slightly more expensive to build than standard housing. They must also allow adaptation to meet the changing needs of occupants over time. Homes built to this standard are more flexible and readily adaptable as people's needs change, for example if they have children and require easy access for pushchairs, if they have a temporary or permanent disability or health issue, or as they gradually age and their mobility decreases.

7.38 The standards will be applied through planning conditions or section 106 agreements, which will require an agreed number of units to be constructed to the specified Building Regulations requirements.

7.39 Policy SHO5 allows for an element of flexibility in recognition of the practicalities of delivering these standards, given the challenges that may arise around the topography of some sites, where access within the gradients specified in the Building Regulations Approved Document may not be achievable. Where step-free access to dwellings cannot feasibly be achieved due to site specific factors, the optional standard will not be required for the homes affected. Where multi-storey flats or apartments are being developed without lift provision, homes on the first floor or above will not be required to meet the M4(2) standards. Ground floor flats in multi-storey developments will still be required to meet the optional standard. Where lifts are provided the standards will be applied in accordance with the Policy.

Self and Custom Build Housing and community-led / co-operative schemes

7.40 National guidance requires local authorities to permit sufficient serviced plots of land to meet the demand for self-build and custom housebuilding in their area, defined as the number of entries to the authority's self-build and custom housebuilding register in the most recent base period (12 months running from 31 October to 30 October). The current[167] demand for the base period of 31 October 2023 to 30 October 2024 is 11.

7.41 Therefore, where there is identified demand in the borough when an application is submitted, developers of larger sites (sites of 100 homes or more) will be expected to make available a small proportion of the development as serviced self-build and custom build plots, as defined in national guidance and legislation and that meet the criteria set out in Policy SHO5 parts 5a-d. Appropriate marketing of these plots, for example through specialist plot-finding services, residential property websites and local estate agents, will be required for a period of at least six months. These plots will not form part of the affordable housing requirement for the development. Detailed guidance for the plots, for example on design, will be provided where appropriate.

7.42 Self-build projects should conform to all relevant policies in the SLP, including SCC1 on climate change adaptation and mitigation.

7.43 Community-led housing schemes include co-operative housing and co-housing. A housing co-operative traditionally means that members of the co-operative own the house(s) and all members have an equal say in the management of it, regardless of their financial share in the property. Co-housing communities are intentional communities[168], created and run by their residents. Each household has a self-contained, private home as well as shared community space. Residents can choose to come together to manage their community, share activities, or regularly eat together, for example. They can be established through the re-use of empty homes, or through new builds.

Protecting Family Housing

7.44 There is sufficient demand in Sandwell for family accommodation that the Council believes it is appropriate to include a policy requiring the retention of family houses except where identified circumstances apply.

Policy SHO6 - Protecting Family Housing (Use Class C3)

  1. To address the shortage of homes that are suitable and attractive to families throughout the borough, and to encourage the provision of sustainable, inclusive and mixed communities, there will be a presumption against the loss of dwelling houses (Use Class C3) for family occupation through either sub-division, conversion to Use Class C4[169], conversion to other non-residential uses or demolition and redevelopment, unless:
    1. the property / properties is / are located within a site allocation and the corresponding development principles indicate that an alternative use or mix of housing will be more appropriate;
    2. the proposed development fulfils other regeneration aspirations of the Council;
    3. evidence of local housing need and demand indicates that an alternative mix of housing is appropriate;
    4. alternative provision will help meet other housing priorities of the Council, such as provision for elderly persons (including bungalows); or
    5. an applicant can demonstrate that the property / properties will no longer be suitable for family occupation, in which case, replacement with a new Class C3 dwelling house(s), suitable for family occupation will be the preferred approach, unless one of the criteria set out above can be satisfied.

Justification

7.45 The Sandwell Housing Market Assessment (2024) demonstrates a need for homes with one bedroom (19%), two bedrooms (26%), three bedrooms (26%) and four bedrooms (29%). Sandwell's waiting list register also demonstrates that more people are waiting for one- and two- (42% and 32%) bedroom homes, with three- bedroom homes seeing the third highest level of demand (17.5%).

7.46 Sandwell is limited in its capacity to identify areas of land for housing to meet the borough's needs, and many family homes have been lost through conversion into separate flats and Houses in Multiple Occupation. Therefore, existing family homes should be retained unless there are circumstances identified where it may not be appropriate to do so.

7.47 Such circumstances may arise where the property or properties form part of a site allocation within this Plan, and the accompanying development principles for that site state that an alternative use for the property has been identified; or where an alternative type of housing is more appropriate.

7.48 Another example would be where an alternative form of development would fulfil regeneration aspirations identified by the Council, or where alternative provision would help to meet other housing priorities of the Council, as set out in the Housing Strategy.

7.49 Where applicants feel that a property or properties are no longer suitable for family occupation, a robust justification will be required for their conversion or replacement. Factors that will be taken into consideration will include:

  1. location of the property;
  2. compatibility of neighbouring uses;
  3. provision of private outdoor amenity space;
  4. car parking;
  5. outlook; and
  6. adaptability of internal layout.

Housing in Multiple Occupation

7.50 Over the last few years, the issue of the number and location of Houses in Multiple Occupation[170] (HMOs) in Sandwell has risen in importance. A combination of changes to permitted development rights and the need to provide affordable accommodation for people on low incomes has led to an increase in the number of HMOs and in the numbers of related planning applications being determined by Sandwell's Planning Committee.

7.51 HMOs provide an additional and valuable source of lower-cost accommodation for sections of the community who cannot afford to purchase their own property or who do not qualify for other forms of social housing. They also provide for the needs of students and people commuting from elsewhere in the country to work in Sandwell.

7.52 There is a perception however that HMOs lead to increases in anti-social behaviour, increased activity, parking problems, noise nuisance and more transient occupiers leading to a weakening of community coherence.

Policy SHO7 - Houses in Multiple Occupation 

  1. Proposals for the creation of a House in Multiple Occupation (HMO), including the conversion of buildings or sub-division of dwellings, will only be permitted if this would not result in over 10% of the number of residential properties  within a 100-metre radius of the application site, measured from the centre point of the property (referred to in this policy as the “relevant area”) operating as HMOs and if the proposals would meet the additional criteria set out in this policy. 
  2. The methodology for establishing the quantum of HMOs in a relevant area is set out in the table below:

Table 10 - Methodology for calculating concentration of HMOs within a relevant area.

Methodology / Evidence:
The Council will calculate the number of HMOs in the relevant area for each individual planning application by using the following approach: 
  1. Identifying the current distribution of residential properties in the relevant area - 

    For the purposes of assessing applications for HMO development, dwelling houses and HMOs that are located within blocks of flats or subdivided properties are counted as one property. Residential institutions, care homes, hostels and purpose-built student accommodation and other specialist housing types are also counted as one property per block. This will ensure that calculations of HMO concentration are not skewed. 
     
  2. Calculating the number of HMOs in the relevant area - 

    Current HMO numbers will be identified from the following sources: 
    •    Properties licensed as a HMO 
    •    Properties with C4 or Sui Generis HMO planning consent or issued with a Certificate of Lawful Development 
    •    Council tax records – student exemptions for council tax excluding purpose-built student accommodation and private flats
     
  3. Calculating the concentration of HMOs in the relevant area -

    The concentration of HMOs surrounding the application site is calculated as a percentage of the total estimated number of existing HMO units against the total number of residential properties. It is accepted that although the HMO sources listed above provide the most robust approach to identifying the numbers and locations of HMOs in an area, it will not identify all HMOs.
  1. Once the current level of HMO provision has been established in a relevant area, the following criteria will be applied to a new proposal:
    1. the development would not: 
      1. result in the loss of C3 family-sized dwellings in areas where there is a proven demand for such accommodation (Policy SHO7);
      2. result in a C3 family dwelling house being sandwiched[172] between two HMOs or other non-family residential uses[173];
      3. lead to a continuous frontage of three or more HMOs or non-family residential uses. 
    2. the development is unlikely to be detrimental to the amenities of the occupiers of adjoining or neighbouring properties by way of noise, overlooking, general disturbance, or impact on visual amenity;
    3. the development would not have a significant adverse impact on the character or appearance of the area, or of the historic or natural environment;
    4. the development would not give rise to unacceptable adverse cumulative impacts on amenity, character, appearance, security, crime, anti-social behaviour or the fear of crime[174];
    5. in areas at risk of a 1 in 100-year plus flood event, finished ground floor levels are at least 60cm above the 1 in 100-year plus flood level; 
    6. provisions for off- and on-street car and cycle parking are sufficient and appropriately incorporated, and would not have an adverse impact on the surrounding area by way of increased on-street parking, impaired highway safety or impeding proper access to the area; 
    7. the site is in an area that has good access by walking and public transport to residential services, as set out in Policy SHO3; and
    8. the development provides a satisfactory standard of living accommodation, and the internal layout is shown to be suitable for the number of units proposed in terms of daylight, outlook and the juxtaposition of living rooms and bedrooms. 
  2. The construction or conversion of the building / dwelling intended to form the HMO should be undertaken to provide adequate personal living space and residential facilities[175], including:
    1. bedrooms of at least 7.5m2 (single) and 11.5m2 (double); 
    2. communal living space comprising lounge, kitchen and dining space either as distinct rooms or in an open plan format; 
    3. washing facilities; 
    4. adequate provision for the storage and disposal of refuse and recycling; and
    5. outdoor amenity space for sitting out, play and drying clothes and external storage space, including cycle storage[176].

Justification

7.53 Houses in Multiple Occupation (HMOs) are defined as homes accommodating three or more unrelated households who typically share kitchens, lounges, and bathrooms.

7.54 HMOs are an increasingly popular part of the housing market in parts of the Black Country. As rooms can be rented individually, they provide additional affordable accommodation options, used primarily by students, young people, and those on lower incomes.

7.55 Whilst the area's stock of HMOs contributes to meeting housing needs, increased numbers of properties in multiple occupancy have the potential to create harmful impacts. Concentrations of HMOs within neighbourhoods can lead to imbalanced and unsustainable communities and harm the social mix and fabric of the area by increasing the proportion of short-term households. They can damage the residential amenity and character of surrounding areas, as the level of activity associated with a HMO is significantly greater than a typical family house, thus increasing the potential for noise and disturbance.

7.56 Harmful impacts associated with high numbers of HMOs can include:

  1. reduced social cohesion resulting from demographic imbalance and unsustainable communities;
  2. reduced housing choice resulting from housing type / tenure imbalance (e.g., a shift from permanent family housing to more transient accommodation and a growth in the private sector at the expense of owner-occupation);
  3. reduced community engagement from residents resulting from an increase in the transient population of an area;
  4. noise and disturbance resulting from intensification of the residential use and / or the lifestyle of occupants;
  5. detriment to the visual amenity and character of the area resulting from poor or accumulative external alterations to properties and / or poor waste management;
  6. reduced community facilities resulting from a shift in the character of shops and businesses;
  7. increased anti-social behaviour and fear of crime resulting from the lifestyles of some HMO occupants, the transient nature of the accommodation and inadequately designed / maintained properties;
  8. highway safety concerns resulting from congested on-street parking.

7.57 Whilst this type of accommodation can address certain housing needs, HMOs tend to be grouped together in parts of the urban area, becoming the dominant type of housing, which can lead to social and environmental problems for local communities. Alongside this, an over-concentration of HMO properties can lead to a loss of family-sized units. This in turn can lead to a consequential increase in the overall number of units unsuited to family occupation. This can pose a serious issue for maintaining a mixed sustainable housing offer across the Black Country.

7.58 The Sandwell HMA (2024) signalled that the greatest demand in the future will be for homes of three bedrooms or more. It is important, therefore, that an approach is taken to the creation of HMOs and the sub-division of existing properties that only allows those proposals that do not impact upon the overall supply of family-sized homes to be supported. In applying this policy, 'family-sized dwellings' means houses with three or more bedrooms.

7.59 In determining the concentration of HMOs surrounding the application site, it will be calculated as a percentage of the total number of residential properties. HMOs should not form over 10% of the number of residential properties within a 100-metre radius. Any application that would result in a higher figure, e.g., 10.04%, would be refused.

7.60 Planning permission will not be granted where the introduction of a new HMO would result in an existing C3 dwelling being 'sandwiched' between adjoining HMOs or non-family residential uses on both sides. In the context of the policy, this is defined as:

  1. Up to three single residential properties in a street located between two individual HMO properties;
  2. Individual HMO properties in any two of the following locations: adjacent, opposite or to the rear of a single residential property;
  3. A residential flat in a building where most of the other flats are proposed for use as HMOs;
  4. A residential flat within a building located between two other sub-divided buildings with at least one HMO flat in each of the other building;
  5. A residential flat located between HMOs above and below or between HMO flats on either side.

7.61 This would not apply where the properties are separated by an intersecting road or where properties have a back-to-back relationship in different streets. Planning permission would also not be granted where it would result in a continuous frontage of three or more HMOs or non-family residential uses.

7.62 In situations where properties are not traditional houses situated along a street frontage, the policy can be applied flexibly depending on the individual circumstances of the proposal.

Exceptional circumstances

7.63 In some areas, the concentration of HMOs will already be at such a high level that the introduction of an additional HMO use would be difficult to refuse. In these circumstances, the retention of a property as a family dwelling is very likely to have no noticeable or meaningful effect on the balance and mix of households in an area already characterised by a high density of extant HMOs. On this basis, therefore, the conversion of a remaining building to an HMO could not harm the character of the surrounding area any further.

Education Facilities

7.64 A variety of services are required to meet the needs of new residents, including education facilities. It is important that these facilities can be easily accessed by sustainable forms of transport and meet the variety of needs for different age groups and educational needs.

Policy SHO8 – Education Facilities

  1. New nursery, school and further and higher education facilities should be:
    1. well-designed, to the relevant local / national standards / guidance in place, and should complement and enhance neighbourhood services and amenities;
    2. well-served by public transport infrastructure, walking, and cycling facilities, particularly in centres, and located to minimise the number and length of journeys needed in relation to the home to school travel distances; and
    3. wherever possible, located to address accessibility gaps in terms of the standards set out in Policy SHO3, particularly where a significant amount of new housing is proposed.
  2. New and improved education facilities will be secured through a range of funding measures:
    1. Where a housing development of ten or more homes would increase the need for education facilities to the extent that new or improved facilities would be required to meet this need, planning obligations or Community Infrastructure Levy will be secured sufficient to meet the need in a timely manner, where this is financially viable.
    2. Contributions will be secured retrospectively where forward funding of improvements is necessary to meet immediate needs.
    3. For sites where there is likely to be a requirement for on-site provision of new schools, this is set out in Appendix B.
  3. Where land is provided for a new school as part of a housing development, the financial contribution made by that development towards education facilities will be reduced accordingly.
  4. On sites where the education facility requirement is proven not to be viable, the maximum proportion of funding will be sought that will not undermine the viability of the development, subject to securing other planning obligations necessary for the development to gain planning permission. A financial viability assessment will be required to be submitted, meeting the requirements set out in Policy SID1.
  5. New and redeveloped education facilities should include provision for wider community use of sports and other facilities where this would be in accordance with evidence of need, secured through a suitably worded community use agreement.
  6. The existing network of education facilities will be protected and proposals that seek to enhance this network will be supported. The physical enhancement and expansion of higher and further educational facilities and related business and research will be supported where it helps to realise the educational, training and research potential of Sandwell.
  7. Proposals involving the loss, in part or the whole of an education facility will be permitted only where adequate alternative provision is available to meet the needs of the community served by the facility.

Justification

7.65 Rising demand for school places in recent years (due to a combination of high birth rates, inward migration, retention levels and housing growth) has resulted in the expansion of a significant number of existing schools and an increased need for new schools across the wider Black Country. This investment has largely been funded by Local Education Authorities. Housing sites within the Sandwell area do not demonstrate sufficient viability to provide for their own educational needs.

7.66 Housing growth over the Plan period is likely to generate the need for further investment in education provision for all age groups, including nursery and further and higher education. National guidance sets out the presumption that housing developments will fund the provision of education facilities sufficient to meet their own needs, including the provision of land for the construction of new buildings where necessary. However, the Viability and Delivery Study indicates that depending on the extent of other planning obligations required, this may not be viable on some sites. Where it can be proved that it is not viable for a housing development to fund all its own education facility needs, the developer should work with the Local Education Authority to investigate available options and ensure that these needs can and will be met.

7.67 Improvements to existing educational provision should be explored to help address low educational attainment. It is important that any investment in educational services is focussed to support centres, address accessibility gaps, generate maximum service improvements and secure community benefits. Increasing community use of school sports facilities would make a major contribution towards meeting open space, sport and recreation standards and improving health through increased sports participation.

7.68 The preferred location for major education facilities, which generate many trips, is within the network of identified centres. However, there may be cases where a development is isolated from a centre, or provision within a centre may not be possible. In such cases, the priority when selecting a location should be to address accessibility gaps in accordance with access standards set out in Policy SHO3, to maximise sustainable access to the facility.

7.69 Locally based Academy Trusts and higher and further education institutions play a major role in the Sandwell economy and also have a key role in helping deliver economic and social transformation. Attracting and retaining graduates within Sandwell is also key to securing the maintenance and growth of a knowledge-based economy. The Higher and Further Education sector is a major driver of economic, social, and cultural regeneration and ongoing investment in the existing network of this sector is supported. Initiatives that strengthen linkages between the sector and the wider economy will also be supported.

Accommodation for Gypsies and Travellers and Travelling Showpeople

7.70 Sandwell has a small, settled community of Gypsies and Travellers, and Travelling Showpeople, and has also experienced unauthorised encampments in the past. In accordance with national guidance, the SLP aims to provide sufficient, appropriately designed and integrated sites to accommodate the needs of these communities over the plan period.

Policy SHO9 – Accommodation for Gypsies, Travellers and Travelling Showpeople

Safeguarding Existing Supply

  1. Existing Gypsy and Traveller and Travelling Showpeople sites (shown on the Policies Map – SG2) will be protected unless it can be demonstrated that they are no longer required or suitable alternative provision can be made.

Meeting Future Need

  1. New Gypsy and Traveller permanent pitches will be provided to meet identified needs up to 2031 as set out in Table 9, in accordance with the Black Country Gypsy and Traveller Accommodation Assessment (GTAA) 2022.
  2. Accommodation needs for Gypsies and Travellers and Travelling Showpeople over the Plan period will be met through sites with outstanding planning permission, allocated sites and other sites granted planning permission during the Plan period in accordance with the criteria set out below. The council will pursue funding and / or management arrangements for new sites, where necessary.
  3. Proposals for permanent Gypsy and Traveller pitches and Travelling Showpeople plots will be assessed against the following criteria:
    1. the site should be suitable as a place to live, particularly regarding health and safety, and the development should be designed to provide adequate levels of privacy and amenity for both occupants and neighbouring uses;
    2. the site should meet moderate standards of access to residential services as set out in Policy SHO3, Table 6;
    3. the site should be located and designed to facilitate integration with neighbouring communities;
    4. the site should be suitable to allow for the planned number of pitches, an amenity block, a play area, access roads, parking and an area set aside for work purposes where appropriate, including, in the case of Travelling Showpeople, sufficient level space for outdoor storage and maintenance of equipment;
    5. the site should be served or be capable of being served by adequate on-site services for water supply, power, drainage, sewage and waste disposal (storage and collection);
    6. a minimum 10% biodiversity net gain is demonstrated in accordance with Policy SNE2; and
    7. the site should not be at risk of flooding and proposals must not increase flood risk for others, in accordance with Policy SCC5.
  4. The location, design and facilities provided on new sites will be determined in consultation with local Gypsies and Travellers and Travelling Showpeople and will also consider / reflect any available national guidance.
  5. Proposals should be well designed and laid out in accordance with Secured by Design principles and as set out in Policy SDM1. It is recommended that pre-application advice is sought from the West Midlands Police Design Out Crime Officers.

Justification

7.71 A Gypsy and Traveller Accommodation Assessment (GTAA) for the Black Country was completed in 2022, in accordance with national guidance, and identified the likely future local need for Gypsy and Traveller and Travelling Showpeople accommodation. It is anticipated that allocations and permissions will provide sufficient supply to meet targets up to 2031, and small windfalls within the urban area are expected to meet remaining need over the Plan period. Appendix B provides details of sites allocated in the SLP for gypsy and traveller pitches. Planning permission will also be granted for additional sites that meet the criteria set out in Policy SHO9, where appropriate.

7.72 Permanent Gypsy and Traveller pitches, and Travelling Showpeople plots, have fixed infrastructure with all the normal residential amenities, and are used as a base to travel from. They are intended to allow Gypsies and Travellers to obtain good access to education, health, and other services. It is important that pitches and plots are well designed in line with Secured by Design principles, and it is recommended that advice is sought from West Midlands Police Design Out Crime Officers.

7.73 The GTAA identified that Gypsies and Travellers prefer small, family-sized sites with approximately 10 - 15 pitches but will accept larger sites if they have been carefully planned and designed in consultation with the Gypsy community. Local authorities may assist Gypsies and Travellers living on their own land without planning permission to obtain retrospective planning permission where this is deemed appropriate.

7.74 Where evidence of demand can be demonstrated, the Council will also explore opportunities to locate transit pitches along traditional travelling routes through Sandwell, reflecting cultural and historic preferences.

Gypsy and Traveller Permanent Pitches

7.75 The SLP aims to meet the needs of existing families that meet the Planning Policy for Travellers Sites 2015 (PPTS) travel for all definition (excluding those living in bricks and mortar accommodation) as identified in the GTAA, by continuing to deliver privately and publicly owned sites and pitches. The total need identified is for eight pitches up to 2031, and an additional six pitches from 2031 to 2041.

7.76 The evidence supports the following approach towards meeting need up to 2031:

  1. safeguard existing Gypsy and Traveller pitches;
  2. allocate existing temporary or unauthorised sites for permanent use (subject to other planning considerations);
  3. intensify and extend existing sites, where appropriate;
  4. carry forward existing pitch allocations from adopted Plans;
  5. allocate new pitches on sites which have emerged since adopted Plans.

Table 11 - Supply of Gypsy and Traveller Permanent Pitches up to 2031

Type of Supply

Number

Existing authorised pitches

16

Regularise temporary / unauthorised sites (b)

0

Intensify and extend existing sites (c)

0

Pitch allocations (d, e)

10

Total New Pitches

10

7.77 Table 9 demonstrates how this approach will deliver sufficient pitches to meet the need up to 2031 plus a buffer of two pitches (20%) - providing a five-year deliverable supply of pitches from adoption of the SLP in 2025, as required by the PPTS. The approach will also provide 71% of the total need for 14 pitches over the Plan period (2024-41).

7.78 It is not possible to identify and allocate further sites to meet the remaining need for four pitches up to 2041, as no deliverable site options were put forward through the Sandwell Local Plan preparation process, which included a "call for site" opportunity and an assessment of Council-owned land. Therefore, this remaining need will be met within the borough through the planning application process, with proposals considered against the criteria set out in Policy SHO9 and any other relevant local plan policies. This is consistent with past trends, where small windfall sites have come forward within the urban area and have been approved where they were in accordance with other planning policies.

Travelling Showpeople Plots

7.79 The GTAA identifies a need for 32 Travelling Showpeople plots over the Plan period. It is not possible to identify and allocate sites to meet this need, as no deliverable site options have been put forward through the Sandwell Local Plan preparation process, which included one "call for sites" opportunity. Therefore, this need will be met within the borough, through the planning application process, with proposals considered against the criteria set out in Policy SHO9 and any other relevant Local Plan policies. This is consistent with past trends, where small windfall sites have come forward within the urban area and have been approved where they were in accordance with other planning policies.

7.80 Travelling Showpeople have different accommodation requirements to those of Gypsies and Travellers, and form part of a different community. They require large plots capable of accommodating lorries and equipment, which will be more suited to mixed use areas.

Housing for people with specific needs

7.81 Sandwell Council will work with partners to meet the identified needs of all sections of the community, including older people, people with disabilities and other people with special needs.

Policy SHO10 - Housing for people with specific needs

  1. Proposals for specific forms of housing including children's homes, care homes, nursing homes, extra care facilities, or any other identified need, will be considered in relation to the following criteria:
    1. compatibility with adjacent uses;
    2. the suitability of the site and building;
    3. the potential for undue noise and general disturbance to surrounding residents;
    4. the character and quality of the resulting environment;
    5. the impact on parking provision and highway safety;
    6. accessibility by a choice of means of transport; and
    7. proximity to facilities.
  2. Supporting information will be required in the form of a planning statement that, as a minimum, must set out the day-to-day activities associated with the use, staffing numbers and visitor numbers. Additional information such as a transport statement or noise statement may be required depending on circumstances.

Justification

7.82 To plan effectively for people with specific needs, the Council will develop a series of strategies to help meet these needs[177], which will be implemented over the Plan period.

7.83 However, it is also considered that accommodation for people with specific needs is best located in areas that are close to local facilities and amenities and accessible by public transport, whilst not having a negative impact on the surrounding area. Therefore, when identifying sites for these facilities, the Council will use the above criteria as well as the accessibility criteria set out in Policy SHO3.


[159] E.g., design codes, development frameworks and supplementary plans

[160] Market housing includes both owner-occupied and private rented.

[161] First Homes figures represent potential demand rather than a requirement. These figures represent the distribution of housing that should be delivered.

[162] Refer to Figure 5 for affordable housing value zones.

[163] Detailed guidance is available at: www.gov.uk/guidance/first-homes

[165] Or any subsequent national equivalent standard

[166] As set out in Annex 2 of the NPPF (December 2023)

[167] As of July 2023

[168] A planned residential community designed to have a high degree of social cohesion and teamwork, with shared responsibilities and resources - https://cohousing.org.uk/faqs/ .

[169] Or subsequent / equivalent iterations

[171] See paragraph 7.57.

[172] See justification for more detailed explanation.

[173] For the purposes of this policy a non-family residential use is defined as a HMO, student accommodation, residential accommodation within C1 and C2 Use and self-contained flats.

[174] It is recommended that pre-application and planning application advice is sought for HMO proposals from the West Midlands Police Design Out Crime Offices

[176] This would normally be calculated to match the same amenity provision for an apartment block (10m2 per person)

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