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Representation ID: 22420

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Black Country Plan 2039 – Draft (Regulation 18) Consultation
Representations of Barnardo’s – Land south of Stonnall Road, Aldridge

Avison Young (‘AY’) is instructed by Barnardo’s to prepare and submit representations to the Draft
Black Country Plan (Regulation 18) consultation (‘Draft Plan Consultation’). Barnardo’s controls
land south of Stonnall Road, Aldridge (‘the site’), edged red on the Site Location Plan attached to
these representations at Appendix I.
Barnardo’s has reviewed the Black Country Authorities’ (‘BCA’) consultation document and wishes
to make representations on it. This letter should, therefore, be taken as Barnardo’s’
comprehensive response to the consultation. It should be read alongside the completed response
form that we have provided as part of the representations.
In particular, our Client welcomes the Draft Plan’s recognition that the site can, and should, deliver
a development that is capable of materially contributing to Walsall, and the Black Country’s
housing requirements. In this respect, Policy HOU1 (site ref. WAH253) allocates the site for 38
dwellings.
Notwithstanding the support for the site’s allocation, these representations made by Barnardo’s
make a number of observations on the policies contained within the Draft Plan and the emerging
evidence base that underpins the draft policies and allocations contained in the Plan.
With these introductory points in mind, the remainder of our submission goes on to:
• describe our Client’s site;
• provide our Client’s response to the Draft Plan consultation; and
• summarises the key points arising and set out our overarching conclusions.
We address each of the above in turn.

Site Background and Context
The site comprises two parcels of land which, together, cover approximately 5.1 ha. The northern
development parcel extends to approximately 3.8 ha and consists of arable farmland. The south-
western parcel comprises a vacant area of hard standing, with a buffer of mature trees and
vegetation on its northern and western boundaries. This parcel is the subject of a Tree
Preservation Order (Walsall Tree Preservation Order No. 14). In between the parcels lies Richmond
Hall Care Home.
To the north, the site is bound by Stonnall Road, with residential uses located beyond this. To the
west and east, the site is surrounded by mainly agricultural pasture land, with Druids Heath Golf
Club located to the south.
The site is located approximately 0.6 miles (1 km) south east of Lazy Hill District Centre, which
contains a range of facilities including a pharmacy, foodstore, takeaways / restaurants and a
hairdresser. Aldridge Town Centre, which contains a wider range of facilities and employment
opportunities is located approximately 0.8 miles (1.3 km) south west of the site. The nearest health
centre / GP and primary school are located 1.0 miles (1.6km) south west and 0.7 miles (1.2km)
west of the site respectively.
Bus stops are located directly opposite the site along Stonnall Road and are served by route 35A
which provides frequent services to Walsall.
Response to Draft Plan Consultation
We set out below our comments of relevant policies identified in the Draft Plan and respond
accordingly to ensure that it is positively prepared, justified, effective and consistent with national
planning policy. Responses are only provided to the subject matters which Barnardo’s consider
are the most critical issues and are most relevant to the proposals to allocate its land at Stonnall
Road, in Aldridge for residential development.

Policy GB1 – The Black Country Green Belt

Our Client’s site is well contained, will with well
defined, defensible boundaries on its eastern, southern and western sides (i.e. the Druids Heath
Golf Club access road to the west, the Golf Club to the south and farm buildings and other
residential dwellings to the east).

Policy DEL1 – Infrastructure Provision

With respect to our Client’s site, we note that Table 31 of the Draft Plan suggests that the
development of the site could deliver:
• Footpaths to serve the development and provision for a controlled / uncontrolled pedestrian
crossing on Stonnall Road; and
• On site provision or funding for off-site arrangements to improve access to a primary school
and local health centre.
In terms of any necessary infrastructure required in Aldridge or the wider Black Country, we note
that paragraph 4.5 of the Draft Plan states that the Plan will be supported by an Infrastructure
Delivery Plan, however we cannot locate this within the evidence base the BCA have published on
the Black Country Plan website. We would be grateful to have sight of this document if it is publicly
available, in order that we can review and comment on it.

Housing Allocations

Our Client welcomes the Draft Plan’s recognition that the site can, and should, deliver a
development that is capable of materially contributing to Walsall, and the Black Country’s housing
requirements. In this respect, Policy HOU1 (site ref. WAH253) allocates the site for 38 dwellings.
In order for the Draft Plan to be sound it must provide a clear strategy for bringing sufficient land
forward, and at a sufficient rate, to address objectively assessed needs over the Plan period.
Because the Council must also identify and update annually a supply of specific deliverable sites
sufficient to provide a minimum of five years’ worth of housing against its housing requirement,
the Draft Plan is also required to identify specific, deliverable sites for years one to five of the plan
period and then sufficient developable sites, or broad areas of growth, for the remainder of the
plan period.
The Glossary to the NPPF defines ‘deliverable’ sites as being available now, offering a suitable
location for development. In order for a site to be considered ‘developable’ it should be in a
suitable location for housing development with a reasonable prospect that it will be available and
could be viably developed at the point envisaged.
Barnardo’s welcomes the Draft Plan’s proposals to allocate its site at Stonnall Road for residential
development. The site is available, offers a suitable location for development and is achievable
with a realistic prospect of delivering housing within the first five years of the plan period.
Chapter 13 provides details of the number of dwellings that could be delivered on each site that
is proposed to be allocated for housing. It suggests that land south of Stonnall Road, Aldridge is
capable of delivering 38 dwellings, assuming a net density of 35 dph, lower than the minimum net
densities prescribed in Policy HOU2. There is, therefore, every possibility that the site is capable of delivering more than 38 dwellings. In Barnard’s view, Policy HOU1 (Table 31) should be amended
so that it enables the final capacity of the site to be informed by masterplanning and other
technical work submitted with any planning application, rather then being pre-determined in the
allocation, which has not been based on any robust evidence.
Our Client would therefore welcome the opportunity to discuss its proposals in more detail with
Officers to determine whether this is an acceptable approach.
Conclusion
These representations have been prepared by Avison Young, on behalf of Barnardo’s, in response
to the Draft Black Country Plan Regulation 18 consultation document.
These representations are intended to form a robust evidence base upon which an allocation in
the Black Country Plan can be found sound at Examination stage. The inclusion of land south of
Stonnall Road and its acknowledgement by the Council as a viable site is supported. The site
remains available and could be delivered as a sustainable development opportunity in the short
term (0-5 years) to help ensure that the Black Country Authorities are able to meet their objectively
assessed housing needs in accordance with the requirements of the NPPF.
Accordingly, it is requested that the Council continue to support the allocation of land south of
Stonnall Road, Aldridge through the remainder of the plan making process.

[See Map 1 Attachment]