Object

Representation ID: 21479

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy DSA4 – Corbett Meadow Local Green Space

3.1. Charles Church Homes and The Dudley Group NHS Foundation Trust strongly objects to the proposed Local Green Space (LGS) designation of Land at Corbett Hospital, considering that it is not justified or appropriate. It does not reflect the nature of the site and conflicts with the requirements for the Black Country Plan to contribute to delivering sustainable development and meeting housing needs.

3.2. The Framework identifies at Paragraph 101 that ‘Designating land as Local Green Space should be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services’. Furthermore, in Paragraph 102 it goes on to identify that the designation of Local Green Space should only be used where the green space fulfils certain criteria. It is considered that the designation of Land at Corbett Hospital is not consistent with the requirement for the emerging Plan to contribute towards achieving sustainable development, and in particular deliver sufficient housing to meet objectively assessed needs.

3.3. The promotion of the site for LGS appears to be focused on the history of the site, as identified in the assessment provided in Appendix A-6 of the Draft Black Country Plan Site Assessment Report. This asserts that the site has significant local history, having originally been purposed with the intention of the land to be used for medical purposes for the people of Stourbridge and the surrounding areas. However, no reference is made in the assessment to the subsequent transfer of the land to the NHS when it was formed in 1948, and the NHS having formally identified the land as surplus to requirements. As a result, it has been included in the register of NHS Surplus Land as available for disposal, with the anticipated disposal expected during 2021/22. The site was added to the register of public sector land in 2017 and was offered exclusively to all other public sector users before being offered on the open market for housing.

3.4. The Government has encouraged the disposal of surplus NHS land to realise capital receipts that could provide a key capital funding stream for the NHS. A review of NHS Property and Estates was undertaken by Sir Robert Naylor in 2018, which identified land that could be released to deliver 26,000 homes that could fund £2bn of capital transformation. The latest NHS Property Disposal Guide (2021) confirms that there is now a policy that requires that at least 50% of the net proceeds of property disposals are to be reinvested in the local health economy, ensuring that local developments are prioritised for the receipt from disposal of sites such as the Land at Corbett Hospital. As the land at Corbett Hospital is owned freehold by The Dudley Group NHS Foundation Trust, 100% of the net proceeds of the sale will be spent within the Dudley health economy.

3.5. DHSC’s ‘Homes for NHS Staff’ policy requires that housing built on land formerly owned by the NHS should be offered initially to employees of the NHS. The development of homes on Land at Corbett Hospital could therefore support the housing and employment objectives of the Core Regeneration Areas policy. By restricting the potential development prospects of the site through the proposed LGS designation, it is considered that the Black Country Authorities are preventing the realisation of critical investment to the NHS both locally and nationally.

3.6. It is considered that a sensitively designed proposal of a suitable scale could deliver some residential development within the site, whilst retaining and enhancing many of the natural features of the site. Furthermore, parts of the site would provide public open space, facilitating public access to the site that is currently not available as no public access is deliverable at present. As a result, it is considered that the proposed development would actually deliver improvements in respect of public access, that would not be the case if the site were to be designated as Local Green Space. The initial landscape analysis that identifies the potential of the Corbett Hospital site to accommodate housing is attached to these representations.

3.7. Furthermore, the proposed allocation of the site as Local Green Space, is inconsistent with national policy, specifically in that such a designation would conflict with the need for policies to contribute towards achieving sustainable development and delivering ‘sufficient homes’. It has already been identified within these representations that the emerging Plan is not addressing local housing needs appropriately, both in regards to the proposed reliance on neighbouring authorities and the proposed release of land from the Green Belt.

3.8. As such, it is considered that it would be highly inappropriate for the emerging Plan to continue to propose to allocate the Land at Corbett Hospital in the context of a significant shortfall in housing supply and the opportunity available to provide housing in a sustainable location within the urban area. Securing residential development on the site would accord fully with the Spatial Strategy set out in CSP1, which establishes that the intention is to deliver growth and sustainable patterns of growth by ‘Delivering the majority of development in the existing urban area’. It should therefore be preferable to seek to accommodate some of the identified level of housing need on suitable sites such as this, rather than seeking to restrict the potential for development through the designation of a site for Local Green Space.

4. Health and Wellbeing

Policy HW1 – Health and Wellbeing

4.1. This policy seeks to ensure that regeneration and transformation of the Black Country will create an environment that protects and improve the physical, social and mental health and wellbeing of residents. As part of this, it provides a list of requirements that should be delivered through new developments, including enabling active and healthy lifestyles, providing a range of housing types and tenures, and be designed with residential amenity and health and wellbeing in mind. It is considered reasonable to expect new developments to respect these requirements and these will be delivered through the proposed development on land at Corbett Hospital.

4.2. Importantly, as part of this policy it establishes that developments should ‘protect and include a range of social infrastructure such as social care, health, leisure, sport and recreation…. close to where people live’. Unlocking residential development on land at Corbett Hospital will directly contribute towards achieving this objective, by realising capital receipts for the NHS through the disposal of this surplus land. There is a mandate that 50% of this capital receipt is to be reinvested in the local health economy, thereby ensuring that local people will directly benefit from delivery of the development. If the Plan seeks to constrain the ability to secure development on the site through the proposed allocation as Local Green Space, this will have a detrimental impact in

respect of the realisation of capital receipts and accordingly reduce the potential for investment to be secured for local health developments. This will directly conflict with the objective of Policy HW1, and the wider aims of the emerging BCP.

4.3. Furthermore, it is considered that by seeking to resist development on the site, the authorities will be restricting the potential for development in a highly sustainable location within the urban area. This could, to a degree, reduce the need for development to be delivered in less sustainable locations either within the Borough or in neighbouring authorities, which should be a key consideration for the Plan and the need to ensure that it is consistent with national policy aims of achieving sustainable development. Ensuring that development is directed to appropriate locations such as this is a consideration for Policy HW1 specifically, as by securing development within the urban area it is more likely that future residents will be able to utilise active and environmentally sustainable forms of travel for accessing places of work, education and day-to- day services and facilities