Comment

Representation ID: 23195

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

5.4. The Black Country Urban Capacity Review Update (May 2021) when assessing the potential to increase densities across the area acknowledges that character constraints such as listed buildings, conservation areas and existing local character/density reduces typical density to around 15-25 dph. The following table highlights some of the areas of concern in respect of the proposed densities which are likely to reduce the level of actual housing delivery on a number of the proposed allocations:

Table 1: Density and known constraints

[Headings:] Policy (SA Reference) / Proposed Density (dph) / Known Constraints

WSA1 (SA-/At least 35/SLINC, surrounding low density character, retention of exisitng buildings, site originally proposed at 15 dph.
0022-WAL)//
WSA2 (SA-/At least 35/

character.
0048-WAL)//
WSA3 (SA-/At least 35/Surrounding low density character.
0034-WAL)//
WSA4 (SA-/At least 35/Listed Buildings on site, SLINC, surrounding low density character.
0014-WAL)//
WSA5 (SA-/At least 35 and Site Assessment identifies 45/surrounding low density character.
0030-WAL)//
WSA6 (SA-/At least 35/SLINC (whole of the site), existing field patterns, surrounding low density character.
0012-WAL)//
WSA7 (SA-/At least 35//landscape/sensitivity,
0078-WAL)//Arboretum impacts//
WSA8 (SA-/At least 35 and Site Assessment identifies 45/Conservation Area, Listed Buildings, visual prominence and topography.
0017-WAL)//


5.5 located sites were to reduce by even 5 dwellings per hectare this would see an overall reduction in numbers across the allocations of over 800 dwellings. This further adds to the need for additional sites to be allocated for development in the plan.
6. Wider spatial planning for the Greater Birmingham and Black
Country Housing Market Area;


6.1. When considering the t is important to highlight that the Green Belt is a spatial planning land typology of and not a landscape designation. To that end it is important to consider the proposed allocations in the plan spatially in relation to the wider housing market area (HMA) and not just where they are bound by the administrative area of the plan.


6.2. Spatially it is clear that the delivery of new Green Belt sites is heavily weighted to Walsall.

However, the Site Assessments for a number of the proposed allocations located on the on the edge of the plan area have failed to fully consider their wider spatial and landscape impacts. Indeed, a number do not appear to have been appropriately considered in relation to the settlements beyond the Black Country boundary or their landscape impact beyond the Black Country boundary. Rather, they have been allocated based on historic administrative boundaries. This plan represents the opportunity to develop sites which can be developed more comprehensively, which would represent proper spatial planning

6.3. To this end, it is our opinion that appropriate sites that can be sustainably planned as a whole within the plan area, rather than relying on development in neighbouring authorities should be given greater weight than appears to be the case in the plan. This is certainly the case for the Bloor site, which follows the settlement pattern of the area and can be wholly planned and defined within the Black Country area.