Object

Representation ID: 43850

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

1.0 INTRODUCTION
1.1 This Representation has been prepared by Pegasus Group on behalf of Taylor Wimpey UK Ltd (hereafter referred to as 'Taylor Wimpey') to respond to the Draft Black Country Plan 2039 (Regulation 18) Consultation (hereafter referred to as 'the Plan') and accompanying published evidence.
1.2 This representation relates to Land North of Grassy Lane (Site Ref: WOH263), which is allocated for approximately 80 dwellings within the Plan as part of the wider Fallings Park Strategic Allocation (Policy CSA2) (see Site Location Plan at Appendix 1 to this Representation).
1.3 Land North of Grassy Lane forms part of a wider land holding known as Land at Linthouse Lane, which Taylor Wimpey is promoting for a residential-led development through both the Black Country Core Strategy Review and the South Staffordshire Local Plan Review (see Promotional Document at Appendix 2).
1.4 This representation is prepared in the context of national planning policy which requires local plans to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework ('NPPF') at paragraph 35. For a development plan to be considered sound it must be:
· Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreement with other authorities, so that unmet need from neighbouring areas is accommodated where it is practicable to do so and is consistent with achieving sustainable development;
· Justified – an appropriate strategy taking into account the reasonable alternatives, and based on proportionate evidence;
· Effective – deliverable over the plan period and based on effective joint working on cross boundary strategic matters that have been dealt with rather than deferred, as evidenced by the Statement of Common Ground; and
· Consistent with National Policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
1.3 This representation also considers the legal and procedural requirements
associated with the plan making process.

2.0 THE SITE
2.1 Taylor Wimpey is in control of land referred to as Land North of Grassy Lane (Site Ref: WOH263), which is allocated for approximately 80 dwellings within the Plan as part of the wider Fallings Park Strategic Allocation (Policy CSA2).
2.2 Land North of Grassy Lane forms part of a wider land holding known as Land at Linthouse Lane, which Taylor Wimpey is promoting for a residential-led development through both the Black Country Core Strategy Review and the South Staffordshire Local Plan Review (see Location Plan at Appendix 1).
2.3 A Promotional Document is included at Appendix 2 to this Representation which provides information relating to Green Belt, landscape and visual impact, ecology, transport, flood risk and drainage, and agricultural land quality. In addition, a development brief has been prepared which sets out how the proposal could deliver a strategic housing allocation in a fundamentally sustainable fashion and can readily integrate itself with the surrounding urban edge of Wolverhampton.

13.0 SUB-AREAS AND SITE ALLOCATIONS – WOLVERHAMPTON
13.1 Chapter 13 of the Plan concerns Sub-Areas and Site Allocations and is split into four parts concerning Dudley, Sandwell, Walsall and the City of Wolverhampton. This Representation concerns the City of Wolverhampton sub¬area and the Fallings Park Neighbourhood Growth Area.
13.2 Taylor Wimpey supports the recognition in the introductory paragraphs (D1-D5) that Wolverhampton plays a significant role in contributing towards the employment and the Black Country economy. However, it is submitted that the paragraphs should also recognise the role the City plays in terms of housing. In particular, it is paramount to recognise that the City is one of the 20 local authorities which are subject to a 35% 'uplift' under the Government's Standard Method for calculating housing need.
13.3 This should also be reflected within the vision presented at paragraph D6, which begins by confirming the aspiration for the City is to be "a place where people come from far and wide to work, shop, study and enjoy...". This opening statement should include being a place where people want to 'live'.
13.4 Policy CSA 2 concerns the Fallings Park Strategic Allocation and is preceded by a map on page 624 which illustrates how the strategic allocation is comprised of four individual allocations (refs: WOH263, WOH264, WOH262 and WOH271). Whilst this map is useful in clarifying the composition of the allocation, it is not understood why the lines which delineate the individual allocations overlap one another in places (WOH262 and WOH263), and fall slightly short of the full extent of the strategic allocation in others (north of WOH263). There is also a small area of the strategic allocation along the western edge of WOH271 which does not appear to be covered by any individual allocation. It is not understood whether these are drawing errors or whether clarity is required regarding the actual extent of the four individual allocations.
13.5 Paragraph D47 confirms that the individual allocations are collectively anticipated to deliver approximately 303 homes at an average density of 40dph (excluding WOH271). This includes 1 hectare of central public open space to be delivered on allocation WOH262. This is supported by Taylor Wimpey, although the Plan should be clear that the density referred to is a net, rather than gross, figure.
13.6 However, paragraph D51 goes on to confirm that "...a masterplan will be prepared to guide the comprehensive development of the Fallings Park Strategic Allocation". Paragraph D55 also states that details of major highways improvements along Cannock Road and Wood Hayes Road are likely to be required and will be detailed within the masterplan.
13.7 The principle of an allocation-wide masterplan is not disputed by Taylor Wimpey. However, the Plan is not clear as to the format or timescales of such a masterplan. The current wording implies that this will be in the form of a supplementary planning document to be produced following the adoption of the Plan. This would not be supported by Taylor Wimpey. Any masterplan should be produced now and should be integral to the Plan. Furthermore, any masterplan should consider how allocations in neighbouring South Staffordshire (specifically Policy SA3 – Strategic development allocation: Land North of Linthouse Lane) influence and interact with the allocation within the Black Country Plan. It is suggested that a significant amount of this masterplanning work has already been undertaken by Taylor Wimpey (see Promotional Document at Appendix 2 to this Representation).
13.8 Paragraph D56 stipulates that mitigation for the loss of Green Belt at the Strategic Allocation will be provided through improvements to the significant areas of recreational open space located in the nearby Bushbury Hill area, which are owned and managed by City of Wolverhampton Council. Paragraph 61 also confirms that these areas could also be utilised as part of securing 10% biodiversity net gain for the allocations. An off-site approach is supported by Taylor Wimpey and the suggested location is broadly considered to represent a logical approach to both Green Belt and biodiversity mitigation.
13.9 However, Paragraph D57 goes on to require all Green Belt loss mitigation works and any necessary transfer of land ownership to be completed before 'substantial completion' of development at the Strategic Allocation. This is not supported by Taylor Wimpey, as it may unnecessarily delay the delivery of much needed housing through the allocation, should unforeseen delays arise that are beyond the control of either the applicants or the Council.
13.10 Notwithstanding this, there is also no clarity as to what constitutes 'substantial completion' of the development. It is submitted that it is not necessary for the mitigation to be in place prior to the completion of the development, as long as any necessary contributions towards that mitigation have been secured.
13.11 Lastly, it is submitted that, given the interrelationship between the Black Country allocation and the neighbouring strategic allocation in South Staffordshire District (Land North of Linthouse Lane), the land within South Staffordshire also represents a significant opportunity for providing biodiversity net gains. As illustrated within the Promotional Document at Appendix 2 to this Representation, a significant portion of Land North of Linthouse Lane is to be delivered as a country park and therefore provides a significant opportunity for biodiversity net gain. As such, a collaborative approach is considered to be most appropriate regarding biodiversity in this location.

14.0 DELIVERY, MONITORING AND IMPLEMENTATION
14.1 This section of the Plan merely sets out the Black Country Authority's commitment to monitoring the implementation of the plan and to ensure it is delivered successfully, efficiently and working in partnership with stakeholders. It sets out that the purpose of the monitoring indicators identified in the PLAN is to assess the performance of the plan in delivering the spatial vision, identify the need to amend the policies and to demonstrate that the plan is deliverable. It also indicates that the Plan is prepared to be flexible over the plan period and adjust where changes arising. The one obvious omission in considering these factors is how the plan will relate to the shortfall in housing supply over the plan period which amounts to some 28,000 dwellings. Other plans including the currently adopted Birmingham Development Plan, had provisions within it to deal with occurrences where the shortfall was not being addressed. The Plan does not include this and therefore requires further consideration by the relevant authorities.

15.0 LAND NORTH OF GRASSY LANE, FALLINGS PARK (WOH263)
15.1 Taylor Wimpey is in control of land collectively known as Land North of Linthouse Lane, Wolverhampton, as shown on the Site Location Plan included at Appendix 1 to this Representation. This includes land located within both the City of Wolverhampton and South Staffordshire District.
15.2 The land which falls within the City of Wolverhampton is identified within the Plan as Land North of Grassy Lane, Fallings Park (site ref: WOH263). This site is identified as comprising 2.7 hectares of land and as being capable of accommodating 80 dwellings (at 40 dwellings per hectare, net), following its removal from the Green Belt. Taylor Wimpey supports this allocation.
15.3 Pegasus Group has prepared an Illustrative Development Framework Plan on behalf of Taylor Wimpey which shows how site WOH263 might come forward for development (see page 45 of the submitted Promotional Document). The Illustrative Plan also shows how site WOH263 might interact with neighbouring allocations WOH262, WOH264 and WOH271, although it should be made clear that Taylor Wimpey does not control these other allocation parcels.
15.4 The Framework Plan illustrates how the Fallings Park allocation will be accessed from Cannock Road (A460) to the west, with a network of secondary and tertiary streets connecting the four development parcels. The allocation includes a centralised area of open space within parcel WOH262, as required by the Black Country Plan.
15.5 The Framework Plan also illustrates how the Fallings Park Allocation has the potential to link into further land within South Staffordshire District to the north, controlled by Taylor Wimpey.
15.6 Pegasus Group and Taylor Wimpey will continue to refine proposals for the site going forward, in conjunction with the neighbouring landowners and promotors. less