Object

Draft Black Country Plan

Representation ID: 21334

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Representation Summary:

POLICY CSP3 – TOWNS AND NEIGHBOURHOOD AREAS AND THE GREEN BELT: OBJECT
WDH’s response to Policy CSP1 sets out their concerns in relation to the BCP’s overall development strategy, and as such those comments are referred to in response to Policy CSP3. Those comments set out that, given the scale of the BCAs’ own housing needs and the housing context in the wider HMA, the BCP should seek to meet a higher proportion of the BCAs’ housing needs before exporting its unmet need to neighbouring authorities. That response to Policy CSP1 highlights that this approach to maximising development within the jurisdiction of the BCAs is entirely justified, and that the SA should be revisited to ascertain the maximum level of housing that could be accommodated before significant adverse impacts arise.

In that context, WDH recognise the important role that Towns and Neighbourhood Areas and the Green Belt adjacent to such settlements can play in meeting the BCAs’ considerable housing needs. Indeed, the supporting text for the policy outlines that these areas relate to the built-up area “where most of its residents live” and that “a key spatial priority of the Plan is to support the delivery of a constant supply of new housing development”, a significant amount of which will be accommodated in these locations.

That is an entirely appropriate and justified approach in principle, and WDH are of the view that the BCP should maximise growth in those areas where there are suitable sites in sustainable locations so as to meet the BCAs’ housing needs more fully. That approach would ensure that housing needs would be met close to where they arise, which would be testament to positive planning and would be an inherently sustainable approach to development.

As set out in WDH’s response to Policy CSP1, it is important that the BCAs develop a clear spatial to guide that identification of further development sites. Doing so would ensure that the BCP allocates those sites that are located in the most sustainable locations so as to limit the adverse impacts of that additional development, and would also provide further clarity to direct future growth should sites fail to deliver or the BCAs’ housing needs increase further.

The merits of Pedmore as an inherently sustainable location for growth are set out in WDH’s response to Policy CSP2 given its location adjacent to the main built form of Stourbridge, the range of services and facilities available both within Pedmore and nearby settlements, and the excellent connectivity that the settlement shares with surrounding settlements and higher-order settlements. The clear suitability of Pedmore as a location for growth should be reflected in the spatial strategy that must be developed to sit within Policy CSP1. The merits of Bromwich Lane, Pedmore are outlined in WDH’s response to Policies CSP1 and HOU1.

WDH also recognises the policy objectives of Policy CSP3, and notes the key role that the development of Bromwich Lane, Pedmore could play in realising those. Notably, the site’s development would deliver green corridors and key open spaces that would contribute towards an integrated and continuous green infrastructure network, and would also benefit from strong links to nearby Core Regeneration Areas and Strategic Centres to ensure the site’s integration with the existing built form. Upon the delivery of a sensitive development scheme with appropriate mitigation, the site would also ‘round-off’ the existing urban form and provide a defensible Green Belt that creates a clear threshold between the redefined settlement edge and the Countryside to the south and west, which would provide easy access to the countryside for residents whilst also safeguarding and enhancing its heritage, recreational, agricultural and conservation values. The development of Bromwich Lane, Pedmore would therefore be testament to sustainable development, as demonstrated in WDH’s response to Policy HOU1.