Comment

Representation ID: 21606

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Land at Heath Street/Cranford Street, Smethwick,
Sandwell, B66 2QZ

Accordingly, our client supports the continued allocation of this site for residential development that is proposed by site allocation SAH085 in the draft BCP.

The subject site is included within Table 22 - Sandwell Residential Site Allocations (BCP Policy HOU1) and hence is a proposed residential site allocation in the BCP.

Whilst our client welcomes the continued allocation of the site for residential use, as it will enable them to bring forward residential development of the site when the current use (facilitating the construction of the Midland Metropolitan Hospital) ceases, we have several
comments/observations on the draft site allocation

Reference: SAH085 included at Page 458, as follows:
• ‘Appropriate Uses’ - despite being included a residential site allocation, the ‘appropriate uses’ column for the draft allocation in Table 2 states that ‘mixed use’ is appropriate rather than ‘housing’ (as is the case for this site, and for some, but not all, of the neighboring sites within the CRA).

We can find no clarity, definition or justification in the BCP for the residential site allocation being earmarked as ‘mixed use’ in the column rather than ‘housing’.
Hence, this should be clarified in the revised version of the BCP.

Whilst our client would welcome flexibility for some mixed (i.e. small scale ancillary mixed uses) to be included as part of a future residential scheme, given the brownfield nature of the site, any uses other than residential would need to be subject to both market demand being identified, and the viability test.

• Gross Site Area (ha) (Brownfield/Greenfield) – the gross site area has been calculated to be 1.85
hectares of land. We assume, having regard to the draft BCP Policies Map for Sandwell, that the proposed allocation includes both our client’s land, and the small parcel of land that originally formed part of the site, but is now in the control of the NHS Trust by virtue of the CPO. To confirm, our client’s land therefore comprises the large majority of this proposed allocation and hence will be able to deliver the large majority of the proposed site allocation.

• Indicative Development Capacity and Density (dph) - the net density per hectare is highlighted as 38 dwellings per hectare (dph). This equates to 70 dwellings over the
1.85 hectares assumed in the draft allocation.

Our client is currently preparing a masterplan/layout plan for the site in anticipation of commencing pre-planning application discussions with Sandwell Metropolitan Borough Council (SMBC). However, we anticipate that the 38 dph (which we believe is based upon the gross site area) is at the lower end of the range of development densities that we would anticipate being achievable for this site, and that the achievable site capacity falls between the range of approximately 80 to 90 dwellings (based upon initial masterplan work undertaken to date). This would equate to a density
of approximately 43 to 49 dph.

It should be noted that the proposed density of 38 dph falls below the minimum requirement for residential sites set out in draft Policy HOU2, which requires a minimum of 40 to 45 dph respectively, depending upon site location and accessibility (etc.).

The indicative site capacity should therefore be increased for proposed site allocation SAH 085 from 70 to approximately 80 to 90 dwellings, to ensure that the allocation is realistic and in line with the likely density achievable.

• Further Information - the column entitled ‘Further Information’ states that the capacity of the site will be confirmed following ‘the masterplan work’. We understand that this masterplan work is currently being undertaken for the wider Grove Lane area by Sandwell MBC, and will be due for public consultation later this month. Our client will review this masterplan work when released, and will make representations to this consultation process in due course.

The ‘Further Information’ column also refers to the ‘phasing’ of the site. We anticipate that it is unlikely that a site of this nature and scale would need to be phased to the market (given the size of approximately 90 dwellings which will equate to approximately two to three years of residential development, depending
upon the market conditions at the time). Therefore, we are confused as to why the draft allocation refers to the site being delivered in multiple phases. Hence, this
text should be omitted from the ‘Further Information’ column.

Summary
In summary, our client, Pall Mall Investments, welcomes the continued allocation of the site for residential redevelopment proposed by the emerging BCP. Our client has already commenced master planning work in anticipation of undertaking pre-application discussions with Sandwell MBC and securing a residential planning consent, so that the site can be brought forward when it is no longer required by the NHS Trust for car parking to facilitate the construction of the nearby Midland Metropolitan Hospital.
However, our client has made several observations on the emerging policies as currently drafted, and in particular, the indicative site capacity of 70 dwellings should be increased to 80 to 90 dwellings. The indicative site capacity currently proposed by the allocation is below the density aspirations set out in draft Policy HOU2. The initial masterplan work undertaken to date by my client suggests that a density range of 80 to 90 dwellings is achievable. This increase in site capacity will assist with ensuring that the proposals are both in line with the emerging Policy HOU2, but also, will assist viability and deliverability,along with the delivery of housing throughout the BCA areas.

In addition, the ‘mixed-use’ annotation included in Table 2 for the site should be clarified,as any other uses as part of a wider residential development of the site will need to be subject to market demand being identified and the impact on development viability.