Object

Draft Black Country Plan

Representation ID: 21481

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Representation Summary:

Policy HOU1 – Delivering Sustainable Housing Growth

5.1. The Policy establishes that sufficient land is to be provided to deliver at least 47,837 net new homes over the period 2020-2039. As set out in response to Policy CSP1, it is considered that the authorities’ approach to determining this figure, is not sound, in that it does not accord with the Framework’s requirement for Plan’s to be positively prepared. The Framework requires that Plan’s should as a minimum, seek to meet the area’s objective assessed needs, which the Plan as currently drafted is not seeking to achieve. Whilst this approach may be reasonable and justified, it is not considered that sufficient justification has been provided at this stage.

5.2. As such, the scale of housing the Plan seeks to achieve is not considered appropriate, or robust, and should be reconsidered as the preparation of the Plan progresses. Given the scale of the shortfall, and the proposed reliance on neighbouring authorities to deliver housing despite a lack of formal agreement on where this is to be accommodated, it is considered that the Plan as a whole and Policy HOU1 in particular should reflect a higher level of housing to be delivered within the Plan area.

5.3. This is particularly the case in light of the opportunity to deliver housing on Land at Corbett Hospital, which has been overlooked in the draft of the Plan that has been published for consultation at this stage. The site could accommodate in the region of 100 dwellings including a range of house types and sizes and affordable housing, which would be delivered in a highly sustainable location within the urban area. These would be accommodated within a sensitively designed development, which responds to the site’s natural features including the variations in topography and existing mature trees, as well as provides substantial areas of public open space and soft landscaping.