Comment

Draft Black Country Plan

Representation ID: 45875

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

Representation Summary:

24.0 Sub Areas and Site Allocations – Walsall
Policy WSA.2 - Land at Vicarage Road and Coronation Road,
High Heath and land at Mob Lane, Pelsall
24.1 Taylor Wimpey fully supports the allocation of the Mob Lane site as part of Strategic Allocation
WSA.2 (Land at Vicarage Road and Coronation Road, High Heath and land at Mob Lane,
Pelsall).
24.2 The estimated capacity of the Strategic Allocation is 713 homes. Mixed tenure housing is
considered to be suitable with higher densities of at least 35dph and affordable housing
provision. The Strategic Allocation is identified as a Neighbourhood Growth Area in the BCP
spatial strategy.
24.3 Policy WSA.2 sets out the following design principles:
• Deliver appropriate local facilities to support the new residents and to enhance the
sustainability of the existing area, including a new primary school and local health centre.
• Investigation of and detailed proposals for the remediation of contaminated land.
• A transport strategy that includes improvements to Mob Lane and Green Lane.
• A site-wide Sustainable Drainage Strategy, to ensure that drainage requirements can be met
on site and that is designed to deliver landscape, biodiversity and amenity benefits.
• A strategy for landscape and habitat creation that provides enhancement, retention and / or
mitigation for established trees and hedges, to ensure there are no significant adverse
impacts on visual amenity and character or on protected animal species.
• The site is in a MSA and requires prior extraction where practical and environmentally
feasible. Where practical and environmentally feasible prior extraction for bedrock and
superficial sand and gravel, shall take place.
24.4 The Mob Lane site itself is identified as Allocation WAH240 in Table 31 of the Draft Plan
(Walsall Sites Allocated for Housing by Black Country Plan (Policy HOU1). WAH240 has an
indicative capacity of 209 new homes at 35dph. The anticipated delivery timescale of site
WAH240 is between 2027-2031. The remainder of the Strategic Allocation is identified as
Allocation WAH238 (Land at Vicarage Road / Coronation Road, High Heath) which has an
indicative capacity of 504 new homes at 35dph. The anticipated delivery timescale of site
WAH238 is 400 by 2039.
24.5 Walsall Council has indicated that the full extent of the technical issues on the strategic
allocation are still being investigated and we are keen to work with the Council and provide
input into these matters where required.
24.6 In this regard, the transport impacts of the Mob Lane site have been assessed on behalf of Taylor
Wimpey and there are no technical highways constraints preventing development of the site
(please see the Transport Note submitted alongside these representations). The Site can be
accessed from the existing road network, with a single vehicular access proposed within the
existing constraints of the highway boundary and land ownership on Mob Lane. This access
point represents a suitable location, and limits impact on existing residents and established
hedgerows. Further work is to be undertaken to investigate the cumulative impact of the whole
of Strategic Allocation WSA.2.
24.7 There is also potential to provide a pedestrian and cyclist only access onto Mob Lane at the
southwestern corner of the Site, allowing for a continuous footway on the northern side of Mob
Lane. This will maximise the permeability of the Site for active travel users, ensuring full
integration with the existing active travel environment.
24.8 Taylor Wimpey supports the delivery of education and healthcare facilities on the Strategic
Allocation in principle. However, as set out in our response to Policies HW2 and HOU5, we
consider that the evidence required to justify the provision of these facilities needs to be
produced as part of the preparation of the BCP in order that the requirement for theses facilities
is transparent and the implications of this provision can be fully assessed.
24.9 The draft policy does not indicate where the new primary school and health centre are envisaged
on the site and we understand that the BCP authorities have yet to determine where these
facilities would go. Clarity should be provided on this matter in time for the next stage of
consultation on the BCP in order to assist in the delivery of the site.
24.10 In terms of the delivery timescales identified for Mob Lane, we would emphasise that site is
capable of delivery in advance of 2027. It is deliverable and is capable of coming forward for
development shortly after the anticipated adoption of the BCP (i.e. 2024) and the BCP should be
updated to reflect this position. The site is capable of early delivery as it is not reliant on the
wider Strategic Allocation for access or any other technical reasons.
24.11 Whilst not mentioned specifically in the policy, the draft proposals map identifies parts of the
Mob Lane site as a Site of Local Importance for Nature Conservation [SLINC]. The Birmingham
& Black Country Local Sites Assessment Report identifies the site as part of a wider area
referred to as ‘Land at Vicarage Road / Coronation Road, High Heath’. It provides the following
assessment:
“When assess against the Birmingham and Black Country Local Sites Criteria, Land at
Vicarage Road / Coronation Road, High Heath scores mostly low to medium and medium for
the ecological criteria. This ecological value is attributed specifically to the intact native
hedgerows, woodland plantation and semi-improved neutral grassland.
In addition, the site provides an important ecological corridor through the site to the nearby
protected sites. Therefore, these specified habitats above, meet the threshold for selection as a
Site of Local Importance for Nature Conservation (SLINC).
The arable farmland, defunct hedgerows and improved grassland fields holds some ecological
value for protected species such as ground nesting birds and local bat population, however,
are limited in species and structural diversity, as such when assessed against the Birmingham
& Black Country Local Sites Selection criteria, however, it fails to meet the criteria of Local
Wildlife Site”.
24.12 We would request further clarification on any resultant implications for development in this
part of the site in order to inform future development proposals.
24.13 For the reasons set out in the Green Belt Technical Report submitted with these representations
we consider that the assessment of the site in the Council’s Green Belt evidence is not accurate
as it has not been considered in isolation. We consider that the site does in fact make a lower
contribution to the Green Belt purposes and provide more detail to justify this position in the
Green Belt Technical Report.
24.14 The suitability of the site for Green Belt release has been established through its identification as
a draft allocation and we consider that the evidence provided in our Technical Report further
supports the allocation of the site.