Comment

Representation ID: 44974

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

14.0 Policy HOU5 - Education Facilities
14.1 Part 2 of Policy HOU5 states that where a housing development of ten or more homes would
increase the need for education facilities to the extent that new or improved facilities would be
required to meet this need, planning obligations or Community Infrastructure Levy will be
secured sufficient to meet the need, where this is financially viable. For strategic allocations, it
states that the likely requirement for on-site provision of new schools is set out in Chapter 13. In
this regard we note that Policy WSA.2 suggests that a new primary school will be required on the
allocation.
14.2 Whilst Taylor Wimpey recognises the need to provide sufficient education facilities to support
new development where there is an identified shortfall, we object to the policy as it does not
currently appear to be supported by any evidence to identify the impact of future development
on current provision and the subsequent needs for additional school places.
14.3 It is vital that this evidence is produced as part of the preparation of the BCP. The need for
education facilities should be established now as this is the only way that the policy
requirements for strategic allocations and future contribution from sites where on-site provision
is not being made can be transparently and accurately assessed.
14.4 With regard to these policy requirements, the BCP Viability Study29 states the following for
generic typologies and Key Large Sites [KLS]:
“For both the generic Typologies and the KLS we have included the sum of £4,471.40 per home,
unless there is a site-specific assumption for the cost of a new school to be provided to serve a
KLS.
Notwithstanding these allowances, the policy is specifically stated to be ‘subject to viability’”
14.5 The BCP Viability Study provides no explanation as to how this £4,471.40 cost has been derived
so it is not clear whether it is justified and whether it would be effective in providing sufficient
mitigation. Further information needs to be provided to clearly explain how this cost has been
derived and why this amount is sought.
14.6 In addition, the Viability Study30 states that a separate confidential report provides viability and
delivery advice in respect of the portfolio of KLSs so this information is not available for review
and cannot therefore be assessed on this basis. Taylor Wimpey considers that this information
should be provided as part of the BCP evidence base in order that the cost applied for such
provision can be properly reviewed to ensure that it is sound.
14.7 The justification text to Policy HOU5 [§6.50] states that depending on the extent of other
planning obligations required, this provision may not be viable on some sites. This appears to
be inconsistent with §4.21 of the Draft BCP which states that greenfield sites and most
brownfield sites will be able to sustain the full range of planning obligations required. It is
therefore essential that clarity is provided on any education contributions required and their
associated costs.
29 Black Country Viability and Delivery Study, 2021, page 26
30 Black Country Viability and Delivery Study, 2021, §1.13