Comment

Draft Black Country Plan

Representation ID: 21640

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

Representation Summary:

Draft Policy HOU1: Delivering Sustainable Housing Growth states that,


‘1. Sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020 – 2039. The key sources of housing land supply are summarised in Tables 3 and 4 and illustrated in the Housing Spatial Diagram. Housing allocations for each BCA are set out in the relevant tables of Chapter 13…’

Table 14 – Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) notes that the site (former Sandvik offices at Manor Way in Halesowen) is allocated for housing under Ref. No. DUH066. It is noted that the site has not previously been allocated.

The indicative development capacity is noted as being 60 homes and the indicative density is listed as being 40dph. The gross and net site area is listed as 1.5 hectares. The anticipated delivery timescale to deliver 60 homes is noted as being
2024-2029. The further information states that this is a mixed-use development opportunity.


It should be noted that:
1. The correct gross site area is 2.27 hectares (5.607 acres), not 1.5 hectares as listed in the draft policy wording.
2. The correct net developable area is 1.75 hectares (4.325 acres), not 1.5 hectares as listed in the draft policy wording.

3. Based on a density of 40dph, the site could therefore deliver 70 dwellings, not 60 as listed in the draft policy wording.
4. The draft policy wording notes that the delivery timescales for residential development being 2024-2029.
However, residential development could be delivered at the site much sooner than this. It is considered that residential development could be delivered from 2022-2027.

We respectfully request that changes are made to the draft policy wording with the correct information as set out above.