Comment

Representation ID: 22560

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy HOU1 – Delivering Sustainable Housing Growth

We are in support of the delivery of at least 47,837 dwellings across the Black Country through housing allocations and existing planning permissions.
We note that Table 4 has no housing allocations on Occupied Employment Land in Walsall at all despite all other authorities having some allocations. Also, in Table 4 there are no additional supply/site capacity in the strategic centre of Walsall. It states that this additional capacity is to be allocated in Local Plans which we assume means the relevant AAPs (please refer to comments made on Policy CSP2).
The adopted Walsall Town Centre AAP is predicated on the existing BCCS and does not therefore provide the sound basis for securing housing growth in the period to 2039 – i.e. it does not align now with the new BCP plan period and will need to be updated.
The site has not been submitted as part of the Call for Sites consultation period; however, it has also not been carried over as site for housing development despite it being allocated as suitable for employment land release in the Walsall Town Centre Area Action Plan (AAP) which is Appendix B of the current adopted BCCS. As set out above, it is not clear why this is the case, and whether Walsall attempted to revisit the sites in the AAP to check their status and ability to be carried forward.
We note that paragraph 6.6 of the Consultation Draft refers to the fact that the housing supply from allocations on occupied employment land has been discounted by 15% to take into account of the multiple delivery constraints that typically affect such sites and that are likely to reduce the delivery on a minority of sites. As a general approach, discounting can work but there is, in the case of major opportunities in town / strategic centres a realistic case to reduce the discount (especially as our Site already has an allocation for release via the AAP).
Paragraph 6.8 states that the Plan is not making or reviewing allocations within Strategic Centres, we assume as a result of the Urban Capacity Review 2021 conclusions about the ability of employment sites to come forward in the Plan Period. It goes on to say, “Existing allocations will be reviewed, and new allocations made in line with these targets when Local Plan documents covering Strategic Centres are updated, alongside or immediately following adoption of the BCP.” There is no clear route to update the AAP so no certainty as to if / when the allocation of housing land in Walsall Town Centre will be updated. The AAP will be out of sync with the new BCP potentially for many years (given how long it took to get the current AAP adopted).

This delay in updating the AAPs is not acceptable in light of the fact the DBCP is intending to release Green Belt land and the NPPF position concerning long-term review and release of GB through Local Plan process leading to long-term settled boundaries) and also asking other local authorities to accept their unmet housing and employment needs.
These representations have been made with regards in making it clear that the Site is available for housing development now, it can be allocated as part of the DBCP and the only constraints on the delivery of the Site will be the balanced placed on the level of impact on the historic environment verses the public benefits/good. Comments on draft Policy ENV5 are provide separately.