Comment

Draft Black Country Plan

Representation ID: 43913

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

Representation Summary:

Infrastructure
3.26 At the current stage of draft BCP preparation it is acknowledged that the evidence base is still being prepared, and this is particularly true with regards to infrastructure.
3.27 Paragraph 4.9 states “Parts of the Black Country’s existing highway infrastructure, and the motorway network, suffer from congestion”. Development should therefore be located at the most sustainable and accessible locations. Land at Pennwood benefits from being located near to a variety of existing amenities and facilities that are within walking or cycling distance of the proposed development. Figure 2 ‘Facilities Plan’ of the accompanying Vision Document demonstrates this.
3.28 Paragraph 4.11 emphasises the need for infrastructure investment in order to support future development. Barratt are proposing to create extensive green infrastructure (over 50% of the total site area) within their site that is multi-functional through the delivery of biodiversity, amenity, aesthetic and drainage benefits. In addition, where development is planned between new areas of public open space and new woodland park, new footpaths, cycle routes and landscape corridors are proposed.

Policy DEL1 (infrastructure provision)
3.29 The Councils need to be cautious with their approach to viability given the scale of brownfield land in the proposed supply. The draft BCP is highly dependent upon development in the existing built-up area (40,117 dwellings) and brownfield sites (81%). The Black Country’s Viability & Delivery Study (September 2021) confirms that 65% of urban typologies tested are marginally viable (27%) or unviable (38%). The Councils must grapple with this matter as part of the plan and in identifying its proposed supply.