Comment

Draft Black Country Plan

Representation ID: 47032

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Representation Summary:

Policy CSP3 1 recognises the importance of providing a mix of good quality residential areas where people choose to live and recognising the inherent sustainability of directing new development through the allocation of a network of new NGAs. This is why NGAs are crucial to the success of this plan – as traditionally certain types and sizes of housing are more readily delivered on urban brownfield sites due to factors

such as viability and density. Indeed table 2.2 of the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) demonstrates that, based on analysis of the Council’s housing need assessment and Valuation Office Agency data, two thirds (66%) of the overall needs for housing in the Black Country relates to houses, with a much smaller need for flats (27%) or bungalows (6%). In response NGAs offer the opportunity to deliver a wider range of housing types to meet the area’s identified needs.

HIMOR agrees that it will be important to the success of the NGAs for them to be masterplanned comprehensively. HIMOR own all the land promoted at Birmingham Road, Great Barr, so can deliver it comprehensively.

The allocation of NGAs allows for greater public access to the countryside which urban sites are not able to, so it is right parts e) and g) of the draft policy require integrated and where possible continuous networks of green infrastructure and easy access to the countryside. This would not be possible without NGAs and the need for this infrastructure is a central theme to the illustrative masterplan for the site.

This is set out at section 4 of the Vision Document enclosed at Appendix 6, which identifies the key design principles for each masterplan option. This includes the provision of a defensible Green Belt boundary to the north / west.

On point e), it will be essential that the Councils’ evidence base appropriately identifies necessary infrastructure to facilitate and mitigate the proposed development to allow for NGAs to be appropriately phased and delivered alongside any necessary infrastructure.