Object

Representation ID: 43844

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

1. INTRODUCTION
1.1. This is a representation to the Regulation 18 Draft Black Country Plan which is subject to consultation until 11 October 2021. It is made on behalf of St Philips in respect of land they are promoting for residential development at Blackhalve Lane, Wolverhampton.
1.2. A Vision Document for the site has already been submitted and is included again with this submission. The site largely falls within South Staffordshire with the area to the south falling within the Wolverhampton City boundary.
1.3. The Vision Document explains the background work that has been undertaken and how the site constraints and characteristics have influenced a framework masterplan, which St Philips would like both Wolverhampton City and South Staffordshire Councils to consider. Similar representations will be made to the South Staffordshire Preferred Options plan, where consultation is due to begin in the coming weeks.
1.4. The following document covers a number of policies and paragraphs in the plan which are considered to be relevant to St Philips and/or the site they are promoting. St Philips reserve the right make further representations in due course. It should be noted that not commenting on an aspect of the emerging plan does not mean they agree with that content.
1.5. The remainder of this representation document is as follows:
· Representation
· Conclusion

2. REPRESENTATION
2.1. St Philips would like to begin by expressing their support for the allocation of the land (inside the Wolverhampton CC boundary) at Blackhalve Lane, particularly as it relates well to the existing established settlement edge, with the opportunity to provide a more definitive boundary to the Green Belt beyond.
2.2. The following table summarises the policies that we have commented on in this representation: Table 1 – Policies/Paragraphs subject to comment:
Policy/Para Title Page
HOU1 Delivering Sustainable Housing Growth 89 (Table 3 and Table 4)
HOU2 Housing Density, Type and Accessibility 96
HOU3 Delivering Affordable, Wheelchair Accessible and
Self Build / Custom Build Housing 101
CC2 Energy Infrastructure 267
CC7 Renewable and Low Carbon Energy and BREEAM
Standards 290
HOU1 – Delivering Sustainable Housing Growth and WOH271 FPNGA - Land east of Wood Hayes Road, Wolverhampton and CSA2 Fallings Park Strategic Allocation.

2.3. The land east of Wood Hayes Road is proposed to be allocated for about 40 dwellings at a density of around 25 dwellings per ha. We consider this could be increased on the basis that there are opportunities within the wider side for compensatory access to open spaces, should the wider site be included as an allocation in the emerging South Staffordshire Local Plan. Moreover, a development density of around 30 dwellings per ha would be more aligned to the established densities within the immediate vicinity of the site.

2.4. The site would fall into the ‘Fallings Park’ strategic housing allocation for this edge of the city, which is proposed as an allocation under Policy CSA2 for around 300 dwellings, plus open space and other facilities.
2.5. It is noted that the council expect the partners within the allocation to enter into dialogue over the delivery of the allocation as a strategic whole and this is something St Philips welcome and would like to take part in, particularly where it relates to ensuring there is adequate apportionment over school place impacts, highways impacts, provision of green infrastructure (including recreational open space) and biodiversity net gain.

4. CONCLUSION
4.1. Overall St Philips welcome the inclusion of their site east of Wood Hayes Road as part of the Fallings Park strategic allocation and its removal from the Green Belt. We agree with the reasoned justification and evidence that underpins the approach the city council have taken so far. St Philips will make further representations to the emerging South Staffs Local Plan when the consultation begins as they believe there is an opportunity for further land to be included in this allocation within their administrative boundary.

4.2. They fully intend to cooperate with the other landowners/promoters of the parcels within the allocation and agree that a holistic approach is clearly preferable. Whilst St Philips have prepared a Vision document for the site, this is subject to further conversations with the other partners within the allocation.

4.3. We have made comments on more generic planning policies where we consider it is justified, and we urge the BC councils to consider the points we have made.