Duty to co-operate

Support

Representation ID: 10638

Received: 27/08/2021

Respondent: Mr. Dennis R Whittaker

Logical approach.

Object

Representation ID: 11904

Received: 10/10/2021

Respondent: Land and horse owners

No council should be offering to build houses for another so some ones green belt can be destroted

Object

Representation ID: 11916

Received: 10/10/2021

Respondent: Ms Julie Edwards

Does not go far enough. One approach does not suit all the requirements. Councils are struggling financially. More bespoke structure needed to match each boroughs needs. You cannot apply the same structure to everyone.

Object

Representation ID: 11986

Received: 10/10/2021

Respondent: Mrs Lydia Ellis

Birmingham city council is notoriously underperforming in many areas. Dudley should not be under pressure to cope with Birmingham’s failings.

Comment

Representation ID: 11999

Received: 10/10/2021

Respondent: Miss Emma Thompson

Local authorities are required to cooperate with Local Nature Partnerships (LNPs) and must have regard to their activities when preparing local plans.

Object

Representation ID: 12118

Received: 11/10/2021

Respondent: Shifnal & Albrighton Labour

A brownfield-first policy benefits everyone except developers. Developers are not the constituency that the Black Country Authority should be representing.

Comment

Representation ID: 13136

Received: 17/09/2021

Respondent: Christopher Bradbury

BLACK COUNTRY PLAN

What strikes me immediately is that we should not be looking at the Black Country, in isolation. Even before we start, this should be a plan involving the whole conurbation. Three of our boroughs all share borders with Birmingham and as such, the plan should be resubmitted as a plan for 'Birmingham & Black Country City Region', including Birmingham and Solihull (as a minimum).
Only considering one half of the conurbation is as rridiculous as if we were providing separate plans for 'Eastern Black Country' and another for 'Western Black Country'.
Has nobody really considered this? Other metropolitan regions are forming and acting as City Regions. We need to as well. So speak to Birmingham. Speak to Solihull and think again. We are a mighty region, lacking full integration. We dhould be doubly mighty.

Comment

Representation ID: 16175

Received: 05/10/2021

Respondent: Ms Beryl Rayner

I am deeply concerned about several Staffordshire plans to build large housing estates on our border. I realise the ability of the Black Country’s Combined Authority to alter these plans, is limited but I hope that it is raising our concerns. As everyone knows, once one housing project is allowed on greenbelt land, others follow. Once this land is sold for building, it never comes back into the greenbelt for children and local people to enjoy. Our greenbelt area is the most valuable asset we have in the Black Country for the simple reason it saves lives and keeps people out of hospital.

Comment

Representation ID: 18417

Received: 05/10/2021

Respondent: Redditch Borough Council

Consultation on Draft Black Country Local Plan
Redditch Borough Council (RBC) welcomes the opportunity to comment on the above document and
to continue to engage constructively with the Black Country Plan in the best interests of positive planmaking. The response below has been written in consultation with the Council’s Portfolio Holder for
Planning, Economic Development, Commercialism and Partnerships and is due to be reported
to Members at Executive Committee on 26th October.

Firstly, we note and support the Black Country Authorities’ intention at Paragraph 1.10 of the Draft
BCP to draft and agree Statements Of Common Ground with all relevant bodies on Duty to Co-operate
issues at the Plan’s Publication Stage. RBC submitted its “Duty to Engagement Proforma” in 2018
which recognised the challenges of meeting the wider housing needs of the Birmingham and Black
Country Housing Market Area. RBC reiterated in this Proforma that this needs to be based on fully
evidenced scenarios and progressed through development planning work by the local authorities. We
continue to emphasise this view.

Comment

Representation ID: 18496

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: Under the duty to cooperate local authorities are required to cooperate with Local Nature Partnerships (LNPs) and must have regard to their activities when preparing local plans. This requirement is the same as that for Local Enterprise Partnerships. No reference is made in the BCP to the Birmingham and Black Country LNP and no evidence is provided in the Statement of Consultation that the LNP was consulted.
This contrasts to the section Black Country Local Enterprise Partnership (1.11 and 1.12) in the BCP, and to the evidence provided in the Statement of Consultation that the LEP was consulted at length.

Object

Representation ID: 18535

Received: 05/10/2021

Respondent: Hammerwich Parish Council

Coalescence. You have a duty to communicate with neighboring Councils, to date Hammerwich Parish Council have not been contacted.

Object

Representation ID: 21438

Received: 11/10/2021

Respondent: Bradford Estates

Agent: Savills

At present the BCP provides no certainty of how the full extent of the 210ha of unmet employment land need will be provided for. As set out above that requirement for cross boundary provision is more accurately 339ha+. The NPPF and PPG requires the plan to identify and allocate the land to meet all of the objectively assessed need, and where that cannot be achieved within the plan area the duty to co-operate requires the balance of that need to be identified and allocated in the development plans of other LPA.
The BCP currently fails in these respects. It is not sufficient to state as 3.24 does, that the Statement of Consultation sets out the current position which will be elaborated on at the submission stage. That approach does not meet the requirements of the duty to cooperate, which are to produce a single statement of common ground together with all those LPA which will contribute to satisfying the unmet need. That statement of common ground should set out the governance and process for agreeing the distribution of satisfying the unmet need amongst those authorities. It should also identify the capacity of the areas of the LPAs party to the statement of common ground, and the details of agreement and disagreement about how the unmet needs can be met across the combined area. At present there is no statement of common ground within the evidence base.
A substantial amount of land remains to be identified to meet identified needs in order for the duty to cooperate to be satisfied. It is imperative that BCA secures sufficient land through cross boundary provision, to meet the unmet needs in both quantitative and qualitative terms. That needs to be achieved without reliance upon reviews of other local plans.
The published evidence of duty to co-operate correspondence with other LPA indicates that the strongest potential source in quantitative and qualitative terms that meets the employment land needs of the BCP is Shropshire. The evidence of the last meeting / dialogue with Shropshire being in April 2020, and with outstanding objections from ABCA, Walsall and Dudley in early 2021 stating that the Submission Shropshire Plan is not sound, indicates that the engagement between BCA and Shropshire is not as constructive, active and ongoing as it is required to be. Notwithstanding the submission of the Shropshire Plan, we urge BCA to actively engage with Shropshire in the interests of securing appropriate land quantitatively and qualitatively to enable the BCP to be found sound.

Comment

Representation ID: 22077

Received: 11/10/2021

Respondent: Kinver Parish Council

Duty to Cooperate
We note the plan indicates a shortfall of circa 28000 new homes and feel:

• There is a presumption that these can be accommodated in adjacent authorities.
• This appears to be an over reliance on the duty to cooperate (which may not remain a statutory obligation in the future).
• Has the impact of increasing the pressure to release neighbouring protected Green Belt sites.

Comment

Representation ID: 22481

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

DUTYT TO COOPERATE
South Staffordshire District Council has sought to work closely alongside the Black Country
authorities in addressing its strategic cross boundary issues, primarily its unmet housing needs and
emerging potential employment land shortfall. We welcome the progress on the Black Country
Plan to date and support the Black Country in its efforts to meet its own development needs as
fully as possible whilst progressing Duty to Co-operate discussions with surrounding authorities to
address any remaining shortfalls. The comments below outline where the District Council consider
clarifications or alterations are required to the evidence which sits behind the proposed Draft Black
Country Plan policies, in order to fully address national policy requirements and respond to
regional evidence on unmet needs.

We note the findings of the Black Country Plan Duty to Co-operate Statement July 2021. However,
we are not entirely clear from the published statement what the intended next steps are to
distribute the Black Country’s housing and employment shortfalls. Specifically, there is no clear
reference to the evidential basis that will be used to determine surrounding authorities’
contributions to the GBHMA/Black County unmet housing needs or employment needs (if arising).
Given the Black Country’s role in currently generating the majority of unmet housing needs within
the GBHMA, it is important that the Black Country clarifies where additional contributions to its
unmet needs are required based on the existing GHBMA evidence base. It is equally important that
the Black Country does not solely accept existing housing contribution offers proposed by other
local authorities before deferring any remaining shortfalls to subsequent early reviews of Local

Plans to address any remaining shortfalls. Such an approach would fail to engage with the existing
HMA evidence base (i.e. the 2018 GBHMA Strategic Growth Study) and could risk undermining the
progress of plans in the surrounding area.

Given the number of years the HMA has had to respond to its findings, it is important the Black
Country ensures the findings of the 2018 GBHMA Strategic Growth Study are reflected in Duty to
Co-operate discussions on unmet housing needs with surrounding authorities. In the first instance,
we consider that the existing strategic growth locations recommended in each local authority area
around the GBHMA should be fully explored and delivered as far as possible, given the cross-
authority evidence base that sits behind them. We would only consider it appropriate to not bring
forward these recommendations if a local authority could show these are truly not deliverable or
that there are more sustainable options within its area that could accommodate a similar level of
growth. We would welcome clarity on whether the Black Country intends to pursue such an
approach to provide a framework for further Duty to Co-operate discussions prior to submission of
the Black Country Plan.


Notwithstanding the comments made above, it is acknowledged that there is a significant
possibility that the locations identified in the GBHMA Strategic Growth Study 2018 may not be
capable of fully addressing regional housing shortfalls, particularly in light of the emerging review
of the Birmingham Development Plan. To address this issue, we would support the Black Country
and Birmingham Authorities in seeking to review and update the 2018 Strategic Growth Study and
would welcome involvement in such a study. Any such review should:

• Build upon, rather than replace, the existing growth locations proposed in the 2018
Strategic Growth Study
• Offer an independent audit of urban capacity across the GBHMA, identifying areas where
further work could identify further non-Green Belt housing supply
• Be based upon close engagement with the West Midlands Combined Authority and any
other relevant Integrated Transport Authorities to ensure future growth locations are truly
aligned to existing or proposed sustainable transport improvements

To deliver the findings of any reviewed HMA-wide evidence base we would also support any
efforts to establish governance arrangements for the co-operation process on unmet housing
needs. The lack of such a formal structure has created significant uncertainty in current local plan
reviews and could be crucial to the effective delivery of any future updated growth study
recommendations.

Throughout the consultation period on the South Staffordshire Local Plan which is due to
commence on the 1st November, we will continually assess any housing shortfalls within the
context of duty to cooperate and our proposed approach to date. Further conversations regarding
our proposed contribution may be required depending on the outcome of ongoing duty to
cooperate conversations and the ongoing progression of Local Plans in our and neighbouring HMA
areas.

Comment

Representation ID: 23076

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

2.1 - 2.12 - Lack of clarity on the current position is the lack of any reference or recognition that the full extent of the York’s Bridge site promoted by St Modwen in fact straddles the Walsall-Cannock Chase District boundary.

Object

Representation ID: 23120

Received: 11/10/2021

Respondent: Clowes Developments

Agent: Savills

Black Country Draft Plan Regulation 18 Consultation Representations on behalf of CWC Group - Clowes Developments Land at Lawnswood Road, South Staffordshire

Savills (UK) Limited, on behalf of CWC Group - Clowes Developments sets out the below representations in respect of their land at Lawnswood Road, South Staffordshire.

The site is listed as site 108 in the current Black Country SHLAA, as shown in the below Plan.

See Attachment

The site is located within South Staffordshire District and has been submitted to a Call for sites consultation in December 2019, accompanying representations to the previous round of consultation of the emerging South Staffordshire Local Plan.

There is a discrepancy between the site boundary put forward in the Black Country SH LAA and that set depicted in a submission made to the South Staffordshire call for sites. The Black Country SHLAA includes land at Ridgehill Woods, whereas the South Staffordshire Plan does not. We request that the site boundary being considered by the Black Country is amended to reflect the submission made to South Staffordshire, and remove Ridgehill Woods as land for development, as this was never the intention. A copy of this plan is submitted with these representations.

Due to the site's location within South Staffordshire, our comments below focuses on the Black County's Duty to Cooperate (DtC) with neighbouring authorities, including South Staffordshire regarding their unmet housing need. According to the consultation draft of the emerging Local Plan this totals 28,239 dwellings (37 .12% of BC's total requirement). This shortfall has occurred as the Black Country conclude that they have identified and made effective and extensive use of brownfield and urban sites and have also undertaken density uplifts in relation to both existing and new allocations.

The Shortfall Position

The Black Country regulation 18 draft plan sets out how the Black Country intend to meet its housing requirement of 76,076 dwellings in the period 2020 - 2039. This is planned to be delivered as follows:

• Total new homes proposed: 47,837 (62.88% of total requirement)
• To be exported through DtC: 28,239 (37.12% of total requirement)

This means that over a third of the Black Country's housing requirement will need to be met outside of its boundaries. At present there is no definitive conclusion of how the 28,239 dwellings are to be accommodated, notwithstanding the potential need for a buffer in addition to this total. Below we discuss the current position in relation to the current status of "offers" made by neighbouring LPAs to deal with the DtC requirement.

LPA "Offers"

We have composed the below table taking account of the "offers" set out in the Black Country DtC statement which was released for consultation along with the draft plan. We have set out below how contributions from each LPA compares in terms of being proportionate to the overall shortfall of 28,239.

See Attachment for Table 1: Agreed Contributions to Black Country Shortfall

In calculating the overall contribution from HMA LPAs, we have only considered contributions that have been confirmed by LPAs to be made specifically in respect of the Black Country's need. This is because agreement on how contributions towards general GBBCHMA shortfall has not been reached, which makes the approach being taken in the Black Country Plan unjustified and ineffective.

From our analysis, only 3,500 of the dwelling offers being made can be directly attributed to meeting the needs of the Black Country shortfall. This is significantly lower than the 8,000 dwelling total claimed by the BCAs in paragraph 7 .6 of the DtC Statement. Paragraph 7 .6 of the DtC states that "some of this contribution would need to be attributed to meeting the needs of Birmingham...." Therefore it remains unclear what "offers" are solely for the Black Country shortfall.

A key points that we draw from this analysis only 12% of the Black Country's housing shortfall appears to have been identified to date from neighbouring authorities which we consider to be a weak position for progressing the Black Country Plan.

From the Duty to Cooperate Statement it appears that there is a lack of clarity in respect of some "offers" and whether the housing being offered is for the Birmingham HMA shortfall or the Black Country shortfall or both.

Table 2 below sets out a review of the Birmingham and Black Country Housing Market Area and provides an overview of the proposed offer by each LPA towards the general housing shortfall in the wider Birmingham and Black Country HMA. It sets out what the current "offers" are in relation to the overall current proposed contributions that have been put forward and what that "offer" is in terms of the % of the overall wider HMA shortfall.

See Attachment for Table 2: Agreed and Potential Contributions to GBBCHMA Shortfall

We note in paragraph 7.9 that the Council make reference to potential contributions totaling a higher figure. The same issue applies here, in that this is mostly comprised of contributions referencing the whole HMA, rather than the Black Country specifically. Even in a very best case scenario in which all of the "offers" are attributed to the Black Country, this only accounts for 61 % of the unmet need and leaves 10,834 dwellings still to be found.

In summary, only 3,500 dwellings have been secured towards the unmet need, accounting for only 12% of the unmet need and leaving a further 24,739 dwellings to be found. The BCAs therefore have a lot more work to do in order to secure a suitable level of contributions towards the unmet need from their neighbours and meet their shortfall.

We consider that in order to fully address the shortfall, LPAs with the greatest geographical and functional relationship with BCAs should be making the greatest contribution towards this unmet need. Our analysis below shows that South Staffordshire is the LPA with the greatest geographical connection to the Black Country. The map bellow shows geographical connections to the Black Country, with South Staffordshire sharing 44% of the Black Country boundary.

See Attachment for Figure 2

Functionally, the LPAs are connected by proximity and key connections such as the M54 and M5 motorways and the Shrewsbury to Birmingham railway line.

We also be consider a functional relationships to exist in the form of the Dudley Travel to Work Area (TTWA). Clowes Development's site at Lawnswood Road, South Staffordshire is located within the Dudley Travel to Work area, along with areas of the Black Country including Stourbridge, Kingswinford and Brierley Hill. TTWAs have been developed by ONS to provide an approximate self-contained labour market areas. These are areas where most people both live and work. They are based on statistical analysis rather than administrative boundaries. We consider that such measures should be used when determining the weight given to functional relationships with other Local Authorities.

The table below sets out the length of shared boundary between the Black Country and neighbouring LPAs. We consider this sort of geographical relationship should be considered when determining where contributions towards meeting the Black Country's shortfall should come from.

See Attachment for Table

This table demonstrates that only Lichfield of the LPAs bordering the BCAs has agreed to make a contribution to explicitly meet the Black Country's shortfall of housing land. This represents only 7.08% of the total shortfall of 28,239. In this context the Black Country should be seeking to secure a much larger amount from South Staffordshire as by far the largest LPA bordering the Black Country, particularly considering Birmingham's inability to contribute to remedy The Black Country's shortfall due to having a shortfall themselves.

Statements of Common Ground

We note at section 1.10 of the draft local plan there is reference to an intention to draft and agree statements of common Ground with relevant authorities and publish them at the publication stage of the Local Plan. The DtC statement also references that a SoCG will be produced taking on board engagement through the regulation 18 consultation with neighbouring LPAs. It is proposed that the SoCG contains actions and the SoCG will be submitted with the draft plan for examination.

We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (PPG Paragraph: 020 Reference ID: 61-020-20190315). Furthermore the BCAs proposal for the SoCG to contain actions and then be submitted at such is at odds with the requirement for Duty to Cooperate to be dealt with before submission of a Local Plan (PPG Paragraph: 031 Reference ID: 61•
031-20190315).

Meetings with Neighbouring LPAs

We note that another way the Black Country intends to evidence constructive engagement is through the publication of evidence such as that seen at appendix 3 of the DtC Statement, entitled: "Duty to Cooperate Meetings held from 2017 onwards". This lists out a number of meetings with different partners. The minutes, actions and outcome of these actions should be made public (albeit redacted where necessary). This would then suitably evidence cooperation. Otherwise it is not clear whether meetings have been useful I ensuring effective cooperation.

Another issue we have identified with the meetings that have taken place is that they are recorded as taking place at the earliest from September 2019 in the case of South Staffordshire, with meetings engaging other LPAs beginning in 2020. Consultation of the emerging Black Country Plan first took place in 2017. These meetings should have therefore been taking place and engagement being recorded at this point. We ask the BCAs to publish detailed minutes, lists of attendees etc. for the meetings referenced in appendix 3 and furthermore provide a clear indication of the level of engagement that has been taking place with HMA LPAs previous to February 2019 in order to satisfy the requirement for ongoing and meaningful engagement.

Level of unmet need from GBBCHMA

As set out above we have serious concerns regarding the level of housing that neighbouring LPAs to the Black Country can deliver in order to satisfy the unmet need. A key issue not discussed within the Black Country's consultation submission is the likelihood of the HMA shortfall being larger than the
2,597 dwelling figure identified in the HMA position statement 3.

Significantly, a consortium of housebuilders and promoters have recently commissioned a review of the Housing Market Area shortfall. They have concluded that up to 2031, the shortfall is around 19,000 dwellings and up to 2036 this could range between 50,000 and 60,000 homes.

Several issues exist with the HMA shortfall calculations, which are based on position statement 3, including:

- It covers the period 2011 to 2031, whereas the Local Plan runs until 2039.

- It does not reflect the standard method, particularly including the 35% uplifts required of Birmingham and Wolverhampton.

- Raw data has not been made readily accessible alongside the latest position statement, making it difficult to scrutinise the statement properly.

There is therefore compelling evidence for the existence of a higher level of unmet need from across the HMA LPAs, including the Black Country Authorities.

The level of unmet need across the GBBCHMA impacts the Black Country as it has the potential to reduce the amount of additional housing need that can be met and attributed to the Black Country.

There are a limited number of suitable sites currently identified and this will need to increase in order to accommodate the wider GBBCHMA need and the Black Country's individual need.

Key points for the Black Country Authorities to Consider

Only around 7% of the Black Country's shortfall has been agreed to be dealt with by neighbouring LPAs. Even in a very best case scenario this rises to 61 %, albeit a more realistic figure is perhaps around half as other contributions are made in relation to the wider GBBCHMA.

We consider that in order to fully address the obvious and identified shortfall, LPAs with the greatest geographical and functional relationship with BCAs should be making the greatest contribution towards this unmet need.

Our analysis below shows that South Staffordshire is the LPA with the greatest geographical connection to the Black Country (44% of the Black Country Boundary) and is partly within the Dudley TTWA, demonstrating a clear functional relationship for the part of the district within the TTWA.

The BCA should review their approach to maintaining records of and publishing SoCG and meetings, in order to suitably evidence compliance with DtC at examination of the Local Plan.

The BCAs should also consider a recent review of the Birmingham HMA shortfall which suggested the level of unmet need was much higher up to 2031 than has been set out by the LPAs. The BCAs should consider that the positon of the GBHMA unmet need from 2031 upto the end of the plan period in 2039 is unknown. The level of unmet need across the GBBCHMA impacts the Black Country as it has the potential to reduce the amount of additional housing need that can be met and attributed to the Black Country.

Comment

Representation ID: 23210

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Harris Lamb Planning Consultancy (‘HLPC’) are instructed by Heyford Developments (‘HD’) to submit representations to the Draft Black Country Plan (‘BCP’) and welcome the opportunity to comment at this time. HD are promoting land for residential development at land to the north Enville Road, Wall Heath within South Staffordshire and have previously submitted details of the site to the Call for Sites.

Notwithstanding HD’s support for the Black Country’s ongoing working relationship with South Staffordshire as its main functional neighbour and the identification that sites beyond the existing urban area need to be identified to meet the significant development needs identified, we set out our detailed comments below

Comment

Representation ID: 23323

Received: 11/10/2021

Respondent: Miller Homes

Land south of Holly Lane, Landywood
This representation has been prepared and submitted by Miller Homes Limited (“Miller”) and concerns Policy CSP1 “Development Strategy, and accompanying Table 2, of the Draft Black Country Plan (DBCP) and the significant unmet housing need in the period up to 2039.

The purpose of this representation is to highlight the availability of land south of Holly Lane, Landywood which provides a highly sustainable option to deliver much needed housing that can contribute towards the Black Country’s significant shortfall.

The land is identified and proposed development presented through the Vision Document at Appendix 1 (see attachment). Through the Local Plan Review, South Staffordshire is proposing that part of the site be removed from the Green Belt and allocated to deliver a minimum of 84 dwellings. However, Miller contest that the whole site, which could deliver in the region of 350 dwellings, remains suitable and could make a valuable contribution towards addressing the acute housing need in the Black Country.

Policy CSP1 and Table 2
Policy CSP1 sets out the proposed Development Strategy for the Black Country including the scale and distribution of new development and proposes to deliver “at least 47,837” dwellings over the period to 2039. Miller contends that to deliver this quantum of housing will require land to be released from the Green Belt. This scale of housing provision falls significantly short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings.
The unmet need is to be “exported” to the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA), or other authorities, as presented in Table 2, and this will be achieved through the Duty to Co-operate. Paragraphs 3.24 and 3.26 state that the Black Country Authorities (BCA) have, and will continue to work constructively with neighbouring authorities to deliver the housing shortfall. We are aware that formal requests for assistance have been raised with the other HMA authorities, as well as wider local authorities.

Miller supports the positive and proactive approach adopted by the BCA to seek assistance and secure commitments to the significant housing shortfall through preparation of the BCP, rather than seeking to defer this strategic cross-boundary issue post-adoption. It is noted that a number of local authorities have already pledged contributions, albeit there will remain a considerable “gap”. South Staffordshire Council’s Draft Preferred Options Plan (September 2021) is proposing to contribute 4,000 dwellings towards the Black Country shortfall “…in order to ensure that that emerging and existing shortfalls from the conurbation are addressed in a genuinely sustainable manner” (paragraph 4.12).
Miller will be making representations to the emerging South Staffordshire Local Plan Review to request an increased housing requirement so that an even greater contribution can be made to the Black Country.

The Opportunity at Landywood
Whilst part of the site has been identified through the South Staffordshire Local Plan Review, Miller contends that the entirety of the controlled land to the south of Holly Lane is sustainable and deliverable and should therefore be released from the Green Belt to meet needs to 2038. Through allocating the entirety of the site, or a larger proportion of it, the site could make a greater contribution to the Black Country housing shortfall to 2039.

We hope this representation provides helpful insight into the availability of sustainable land at Landywood which can deliver c.350 dwellings and thereby further contribute towards the Black Country’s housing shortfall.

Comment

Representation ID: 23345

Received: 11/10/2021

Respondent: Miller Homes

Lichfield Road, Burntwood
This representation has been prepared and submitted by Miller Homes Limited (“Miller”) and concerns Policy CSP1 “Development Strategy”, and accompanying Table 2, of the Draft Black Country Plan (DBCP) and the significant unmet housing need in the period up to 2039. The purpose of this representation is to highlight the availability of land at Lichfield Road, Burntwood, which provides a highly sustainable option to deliver much needed housing that can contribute towards the Black Country’s significant shortfall.

The land is identified and proposed development presented through the Vision Document at Appendix 1(see attachment). The site has not been identified for development within Lichfield’s Draft Submission Local Plan. However, Miller contest that the site, which could deliver in the region of 300 dwellings, remains suitable and could make a valuable contribution towards addressing the acute housing need in the Black
Country.

Policy CSP1 and Table 2
Policy CSP1 sets out the proposed Development Strategy for the Black Country including the scale and distribution of new development and proposes to deliver “at least 47,837” dwellings over the period to 2039. Miller contends that to deliver this quantum of housing will require land to be released from the Green Belt. This scale of housing provision falls significantly short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings.
The unmet need is to be “exported” to the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA), or other authorities, as presented in Table 2, and this will be achieved through the Duty to Co-operate. Paragraphs 3.24 and 3.26 state that the Black Country Authorities (BCA) have, and will continue to, work constructively with neighbouring authorities to deliver the housing shortfall. We are aware that formal requests for assistance have been raised with the other HMA authorities, as well as wider local authorities.

Miller supports the positive and proactive approach adopted by the BCA to seek assistance and secure commitments to the significant housing shortfall through preparation of the BCP, rather than seeking to defer this strategic cross-boundary issue post-adoption. It is noted that a number of local authorities have already pledged contributions, albeit there will remain a considerable “gap”. Lichfield’s Proposed Submission Local Plan (July 2021) is proposing to contribute 2,665 dwellings towards the Black Country shortfall (paragraph 4.22) though no explanation is given as to how this number has been calculated. Of concern is that the contribution this now planned for is some 1,835 homes lower than the contribution (4,500) suggested at the Preferred Options stage of the plan.

Miller has submitted representations to Lichfield’s Draft Submission Plan which raise significant concerns with the plan’s soundness and, more specifically the plan’s spatial strategy, to request an increased housing requirement so that an even greater contribution can be made to the Black Country and raise concern over the limited quantum of growth directed towards Burntwood, a Tier 2 settlement and highly sustainable location.

The opportunity at Burntwood
Miller contends that land at Lichfield Road, Burntwood is sustainable and deliverable and should therefore be released from the Green Belt and form a residential allocation in the Lichfield Local Plan to meet needs to 2040. Such an allocation could make a further significant contribution to the Black Country housing shortfall to 2039.

We hope this representation provides helpful insight into the availability of sustainable land at Burntwood which can deliver c.300 dwellings and thereby further contribute towards the Black Country’s housing shortfall.

We would welcome the opportunity to discuss the site and emerging proposals with the BCA following the close of the Regulation 18 consultation but please do not hesitate to contact me in the meantime should you require further information.

Comment

Representation ID: 23360

Received: 30/09/2021

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

1. INTRODUCTION
1.1. This is a representation to the Regulation 18 Draft Black Country Plan which is subject to
consultation until 11 October 2021. It is made on behalf of Seven Homes.
1.2. This document is submitted alongside a Vision Document for land at Sandyfields Road, Sedgley,
which largely falls within South Staffordshire with a very small area falling into Dudley Borough.
1.3. The Vision Document explains the background work that has been undertaken and how the site
constraints and characteristics have influenced a framework masterplan, which Seven Homes
would like both Dudley and South Staffordshire Councils to consider. Similar representations will
be made to the South Staffordshire Preferred Options plan, where consultation is due to begin in
the coming weeks.
1.4. The following document covers a number of policies and paragraphs in the plan which are
considered to be relevant to Seven Homes and/or the site they are promoting. Seven Homes
reserve the right make further representations in due course. It should be noted that not
commenting on an aspect of the emerging plan does not mean they agree with that content.

2. REPRESENTATION
2.1. We consider that Dudley and South Staffordshire councils should work more closely together to
deliver growth along the western boundary of Dudley – as is the case with the boundary with
South Staffordshire and its shared boundary with Wolverhampton. We consider there is a real
risk of a missed opportunity to make the most of the linkages to existing services and facilities in
areas such as Sedgley. Paragraph 24 of the NPPF sets out clearly that councils have a duty to
cooperate over strategic matters including housing and infrastructure delivery.
2.2. The following table summarises the policies that we have commented on in this representation:
Table 1 – Policies/Paragraphs subject to comment:
Policy/Para Title Page
HOU1 Delivering Sustainable Housing Growth 89 (Table 3 and
Table 4)
HOU2 Housing Density, Type and Accessibility 96
HOU3 Delivering Affordable, Wheelchair Accessible and
Self Build / Custom Build Housing
101
CC2 Energy Infrastructure 267
CC7 Renewable and Low Carbon Energy and BREEAM
Standards
290
HOU3 – Delivering Sustainable Housing Growth
2.3. The BC authorities aspire to deliver 47,837 new homes over the course of the plan period 2020 to
2039.
2.4. We note that in Table 4, there has been a lapse rate allowance of 10% discounted to allow for
some sites which may not come forward over the course of the plan. We would like to know
whether this truly represents the historic lapse rate pattern, as we are aware of a substantial
number of sites within Dudley Borough that have not come forward because of persistent
viability problems associated with heritage, site contamination and other issues which include
tensions between commercial/industrial land values being similar to those of residential (postremediation).
We are not clear whether this has been considered carefully enough.
2.5. Further, the BC authorities propose to ‘export’ 28,239 dwellings outside of its boundary – but as
South Staffordshire Council have just publicised their preferred options Local Plan, it remains the
case that they propose to take c.4,000 dwelling as (unmet need), but it is not clear whether this is
unmet need from the GBSLEP area, or the Black Country. This needs clarification.
2.6. At 7,657 (Table 3), we consider the windfall allowance to be high – it represents around 16% of the
total housing target for the plan period, which is a considerably proportion. Given the
requirements of the NPPF, we consider the plan is at risk of not being ‘positively prepared’ given
this (we feel) overreliance on unallocated housing in the emerging plan. Paragraph 71 of the
NPPF sets this out clearly: ‘Where an allowance is to be made for windfall sites as part of
anticipated supply, there should be compelling evidence that they will provide a reliable source
of supply. Any allowance should be realistic having regard to the strategic housing land
availability assessment, historic windfall delivery rates and expected future trends. Plans should consider the case for setting out policies to resist inappropriate development of residential
gardens, for example where development would cause harm to the local area.’
HOU2 - Housing Density, Type and Accessibility
2.7. We are broadly supportive of the densities proposed in the emerging plan, however we consider
they are aspirational when it comes to the central areas of the main Black Country settlements,
with the exception of perhaps Wolverhampton, because of viability (specifically build costs v
likely sales values). Apartments continue to be difficult to sell in much of the Black Country and
it is hard to imagine how (post-covid) high density apartment schemes will, in reality, come
forward on any great scale. We would urge the BC authorities to reconsider their expectations on
this moving forwards.
2.8. We would seek some flexibility in the application of accessibility standards – particularly as a
result of the move towards more sustainable personal travel modes, such as electric cars.
2.9. We would also seek flexibility in the application of housing mix standards, where evidence from
the availability of second hand stock within the immediate area demonstrates an oversupply of a
particular size of dwelling.
HOU3 - Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing
2.10. We are broadly supportive of the affordable housing policy but would suggest the policy is
slightly reworded to make it absolutely clear that those minimum proportions should only be
required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but
unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).
2.11. We are broadly supportive of the requirements to make more homes accessible for disabled
people.
2.12. The 5% self-build requirement does raise some concerns, however – related to maintaining
health and safety on large housing sites, as well as in relation to the ultimate control over
phasing. Given the council’s strong reliance on windfall sites – many of which are likely to be self
or custom build, we cannot see why the council can justify requesting a proportion of self-build
on large housing developments that are proposed for allocation.
CC2 – Energy Infrastructure
2.13. We are concerned about the proposal to require a decentralised energy network on sites of 10
dwellings or more. We remain unconvinced that decentralised energy is always appropriate in
anything other than unconstrained, strategic level development sites (000’s rather than 00’s of
dwellings), and certainly not for smaller schemes.
2.14. This is because of the limitations this can place on the ultimate consumer – where decentralised
energy can limit consumer choice in terms of energy provider and where the consumer may
wish to add further energy saving measures – such as solar power, heat pumps, etc.
2.15. It is not clear from this policy why it would be beneficial: district heating systems have had a
mixed result, where residents have had to sign up for long term contracts of 25 years or more.
Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same,
so the larger the scheme, the more viable it could be. The industry itself is not regulated in the
same way and physical problems with a district heating system or decentralised energy system
can often result in whole areas being without heating or hot water for period of time.

2.16. We would therefore urge the BC authorities to reconsider the wording of this policy to
‘encourage’ the use of such systems, but not to stipulate that they must be used.
CC7 - Renewable and Low Carbon Energy and BREEAM Standards
2.17. We consider that, linked to the above policy CC2, the aims of CC7 are laudable, it is clear that
there is some duplication between this planning policy and Building Regulations, which are
delivered in any case. There are therefore elements of this policy which are not particularly
justified or necessary, insofar as they effectively repeat Building Regulations requirements.

4. CONCLUSION
4.1. We consider that there is a strong case to include the land at Sandyfields Road, Sedgley as a
residential allocation within the emerging Dudley and South Staffordshire Local Plans because
much of the site offers only a very limited contribution to the role and function of the Green Belt.
The site is visually well related to the edge of Sedgley and the site is sustainably located for the
purposes of accessing employment in Pensnett, Brierley Hill, Dudley and Wombourne, as well as
being close to local schools, shops, sporting facilities and other services.
4.2. We have produced a Vision Document which sets out how the site could deliver housing with
significant benefits for the wider community in a sustainable way.
4.3. The site offers significant opportunities to add new open spaces for future and existing residents,
where access to the land is currently limited to a small number of public rights of way. We urge
the council to consider the site for allocation, to deal with some of the unmet need within Dudley
Borough.
4.4. We have made comments on more generic planning policies where we consider it is justified,
and we urge the BC councils to consider the points we have made.

Seven Homes - Land to the West of Sandyfields Road. Development Vision Document August 2021- submitted with representation. Please see attachment.

Comment

Representation ID: 23361

Received: 08/10/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

WOH265 & Perton Court Farm, Wrottesley Park Road, Perton.
1.1. This is a representation to the Regulation 18 Draft Black Country Plan which is subject to
consultation until 11 October 2021. It is made on behalf of Barberry in respect of land they are promoting for residential development at Perton Court Farm, Wrottesley Park Road, Perton.
1.2. The site itself falls entirely within South Staffordshire, however, a neighbouring area of land
(which falls within the Wolverhampton City boundary) to the south east at Perton Road (Ref
WOH265 WTNA) has been proposed to be released from the Green belt as a housing allocation.
1.3. This is relevant to Barberry and the site they are promoting as they are directly adjacent and share a boundary.
1.4. Barberry have submitted a Vision Document to South Staffordshire Council communicating the
constraints and opportunities of the site, together with a proposed masterplan.
1.5. Barberry would like Wolverhampton City Council to consider this and how their site might better
tie in with the proposed allocation at Perton Road.
1.6. Clearly, Barberry intend to make representations to the South Staffordshire Preferred Options
plan, where consultation is due to begin in the coming weeks.
1.7. Barberry reserve the right make further representations to the Black Country Plan as
opportunities arise. It should be noted that not commenting on an aspect of the emerging plan
does not mean they agree with that content.

2. REPRESENTATION
2.1. Barberry would like to begin by expressing their support for the allocation of the land (inside the
Wolverhampton CC boundary) East of Perton Road, Wightwick (Ref WOH265 WTNA) particularly
as it relates well to the existing established settlement edge, with the opportunity to provide a
more definitive boundary to the Green Belt beyond.
2.2. Barberry agree that there should be mitigation for green belt loss to be provided through
accessibility, biodiversity and environmental quality improvements to nearby Smestow Valley
Local Nature Reserve. However, Barberry dispute the fact that the ‘track to the north west, which
runs along the Wolverhampton / South Staffs District boundary’ , (which forms at the junction
between Pattingham Road and Perton Road) is capable of providing a defensible new green belt
boundary. The track itself is neither robust nor enduring and could easily change over time.
2.3. Paragraph 143 (f) of the NPPF is clear that when defining new Green Belt boundaries, plans
should ‘define boundaries clearly, using physical features that are readily recognisable and likely
to be permanent.’
2.4. We consider a better solution would be to holistically plan for the wider site, which is controlled
by Barberry, as shown in the attached Vision Document. Here, it is shown that the development
of the site would result in new parks and play spaces, as well as a safe route to school for children
living in Perton itself.
2.5. The following table summarises the policies that we have commented on in this representation:
Table 1 – Policies/Paragraphs subject to comment:
Policy/Para Title Page
HOU1
and
WOH265 WTNA
Delivering Sustainable Housing Growth 89 (Table 3 and
Table 4)
HOU2 Housing Density, Type and Accessibility 96
HOU1 – Delivering Sustainable Housing Growth and WOH265 WTNA - Land East of Perton Road,
Wightwick.
2.6. The land east of Perton Road is proposed to be allocated for about 4 dwellings on 0.6 ha of land,
which is substantially low in terms of density, and an inefficient use of land. We consider this
could be increased because there are opportunities within the wider site for compensatory
access to open spaces. Of course, the wider site would have to be included as an allocation in the
emerging South Staffordshire Local Plan. Moreover, a development density of around 30
dwellings per ha would be more aligned to the established densities within the immediate
vicinity of the site. An extract of the proposals map is shown overleaf:
2.7. We consider, in reality, that if this site were to be allocated that it is unlikely just 4 dwellings
would be delivered, particularly with the added burden of delivering any noticeable
improvements to the Smestow Valley Local Nature Reserve. Nor would 4 dwellings deliver any
affordable housing or tangible public benefits, other than marginally improving housing choice
within the local area. Developers of this site are likely to push for more.
2.8. Clearly, Green Belt is a strategic planning policy which exists on a permanent basis, transcending
plan periods. It should only be released in exceptional circumstances. To that end, a small ‘nibble’
of the Green Belt as proposed is unlikely to pass the exceptional circumstances test, nor is it
likely to be warranted on such a small-scale site. It is our view that the wholesale removal of the
wider site, together with the small site should be considered, where the exceptional
circumstances test could be met and where the compensatory measures as set out in the NPPF
at para 142 could be properly addressed: ‘Strategic policy-making authorities should……. also set
out ways in which the impact of removing land from the Green Belt can be offset through
compensatory improvements to the environmental quality and accessibility of remaining Green
Belt land’.
2.9. There are some strategic allocations included in the BC Plan proposed at Linthouse Lane, Cross
Green and Bilbrook, all of which will require substantial lead-in times, smaller strategic sites like
the land at Perton Court Farm could conceivably come forward quicker as they do not require
substantial infrastructure investment.
2.10. The BC authorities aspire to deliver 47,837 new homes over the course of the plan period 2020 to
2039. We note that in Table 4, there has been a lapse rate allowance of 10% discounted to allow
for some sites which may not come forward over the course of the plan. We would like to know
whether this truly represents the historic lapse rate pattern, as we are aware of a substantial
number of sites within Wolverhampton that have not come forward because of persistent
viability problems associated with heritage, site contamination and other issues which include tensions between commercial/industrial land values being similar to those of residential (postremediation).
We are not clear whether this has been considered carefully enough.
2.11. Further, the BC authorities propose to ‘export’ 28,239 dwellings outside of its boundary – but as
South Staffordshire Council have just publicised their preferred options Local Plan, it remains the
case that they propose to take c.4,000 dwelling as (unmet need), but it is not clear whether this is
unmet need from the GBSLEP area, or the Black Country. This needs clarification.
2.12. At 7,657 (Table 3), we consider the windfall allowance to be high – it represents around 16% of the
total housing target for the plan period, which is a considerable proportion. Given the
requirements of the NPPF, we consider the plan is at risk of not being ‘positively prepared’ given
this (we feel) overreliance on unallocated housing in the emerging plan. Paragraph 71 of the
NPPF sets this out clearly: ‘Where an allowance is to be made for windfall sites as part of
anticipated supply, there should be compelling evidence that they will provide a reliable source
of supply. Any allowance should be realistic having regard to the strategic housing land
availability assessment, historic windfall delivery rates and expected future trends. Plans should
consider the case for setting out policies to resist inappropriate development of residential
gardens, for example where development would cause harm to the local area.’
HOU2 - Housing Density, Type and Accessibility
2.13. We are broadly supportive of the densities proposed in the emerging plan, however for reasons
already given, we consider that the densities on the proposed allocation at WOH265 are far too
low and represent an inefficient use of land, contrary to paragraph 124 of the NPPF, which states:
‘Planning policies and decisions should support development that makes efficient use of land’.
4. CONCLUSION
4.1. Overall Barberry welcome the inclusion of the land at Perton Road, Wightwick as a housing
allocation and its removal from the Green Belt. Barberry will make further representations to the
emerging South Staffs Local Plan when the consultation begins as they believe there is an
opportunity for further land to be included in this allocation within their administrative
boundary.
4.2. Barberry consider a holistic and strategic approach is clearly preferable and this is demonstrated
within the Vision Document, which is submitted with this representation.
4.3. We have made comments on more generic planning policies where we consider it is justified,
and we urge the BC councils to consider the points we have made.

Comment

Representation ID: 23456

Received: 11/10/2021

Respondent: Miller Homes Ltd

Agent: Turley Assocs

Turley is instructed to submit a representation on behalf of Miller Homes Ltd (“Miller”) to Policy CSP1
“Development Strategy”, and accompanying Table 2, of the Draft Black Country Plan (BCP), in relation to
the significant unmet housing need in the period to 2039.
This representation highlights the availability of a significant area of land within Miller’s control at Shifnal
(Shropshire), which provides a highly sustainable option to deliver a community of c.1,300 dwellings to
meet Shropshire’s own housing needs but which could also contribute towards the Black Country’s
identified housing shortfall. With all of this land being controlled by a national housebuilder, delivery of
this sustainable community would be swift.
The Miller land is identified on the plan attached as Appendix 1 (see attachment), and is proposed to be removed from the Green Belt and “safeguarded” to meet housing needs beyond 2038 in the submitted Shropshire Local Plan Review (LPR). However, Miller are promoting this land for allocation so that it can meet needs to
2038, as explained below.
Policy CSP1 and Table 2
CSP1 sets out the proposed Development Strategy for the Black Country including the scale and
distribution of new development and proposes to deliver “at least 47,837” dwellings to 2039. This will
require Green Belt release given the capacity of the urban area. This scale of housing provision falls well
short of the sub-region’s minimum Local Housing Need, by at least 28,239 dwellings. We have made
separate representations to the BCP which question the soundness of certain components of the
assumed supply so the already significant shortfall has the potential to grow even further.

The unmet need is to be “exported” to the wider Greater Birmingham and Black Country Housing Market
Area (GBBCHMA), or other authorities, as presented in Table 2, and this will be achieved through the
Duty to Co-operate. Paragraphs 3.24 and 3.26 state that the Black Country Authorities (BCA) have, and
will continue to, work constructively with neighbouring authorities to deliver the housing shortfall. We
are aware that formal requests for assistance have been raised with the other HMA authorities, as well
as wider local authorities.
Miller supports the positive and proactive approach adopted by the BCA to seek assistance and secure
commitments to the significant housing shortfall through preparation of the BCP, rather than seeking to
defer this strategic cross-boundary issue post-adoption. It is noted that a number of local authorities
have already pledged contributions, albeit there will remain a considerable “gap”. Shropshire Council’s
submitted LPR (3 September 2021) is proposing to contribute 1,500 dwellings towards the Black Country
shortfall which “…responds to the functional relationship between the two areas” (paragraph 3.7).
Miller has made representations to the submitted Shropshire LPR to request an increased housing
requirement so that an even greater contribution can be made to the Black Country, given Shropshire’s
connections to the housing and economic markets through sustainable transport linkages such as railway
corridors and the M54 Motorway.
The opportunity at Shifnal
Shifnal has a particularly strong functional relationship with the Black Country, benefitting from a railway
station with hourly services to Wolverhampton and Birmingham, as well as immediate access to M54
Junction 3. 18% of Shifnal residents work in the GBBCHMA (Census 2011).
Whilst the Shropshire LPR recognises the sustainable credentials of Shifnal and proposes it is the focus
for growth in the regionally and nationally significant M54/A5 “Strategic Corridor” (including allocation of
a strategic employment site (SHF018)), housing development is restricted to only 300 new dwellings to
2038, beyond completions and existing commitments.
No new Green Belt releases are therefore proposed at Shifnal to deliver housing before 2038. Instead,
Green Belt is proposed to be “safeguarded” to meet housing needs beyond 2038. This includes 65ha of
land controlled by Miller (SHF029 and SHF015; Policies Map extract at Appendix 2) which Shropshire
Council propose will form a longer term “strategic housing extension capable of creating a new
neighbourhood” (paragraph 2.215). It is capable of delivering a sustainable community of c. 1,300
dwellings, as presented on the Illustrative Masterplan at Appendix 3.
This land is sustainable and deliverable and should therefore be “elevated” from safeguarded land to
form a residential allocation in the Shropshire LPR to meet the County’s needs to 2038. However, such
an allocation could also assist in making a contribution to the Black Country housing shortfall over this
period. With the land being controlled exclusively by a national housebuilder, the sustainable community
can be delivered swiftly.
We hope this representation provides helpful insight into the availability of sustainable land at Shifnal
which is already proposed for Green Belt release and which can deliver c.1,300 dwellings to meet
Shropshire’s housing needs but which is also ideally placed to contribute towards the Black Country’s
housing shortfall.

Comment

Representation ID: 44899

Received: 10/10/2021

Respondent: Cannock Chase Council

Paragraph 3.24 -3.25 Agree it is beyond the powers of the BCA to establish the limits
of sustainable development in neighbouring authorities. However, the methodologies
utilised to identify sufficient strategic sites to meet the needs arising are currently
inconsistent between all the HMA authorities. A mechanism should be included
within the Plan to enable a consistent and fair approach to be taken to address the
longer term needs once the final shortfalls are understood.

Object

Representation ID: 44961

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Clent View Road, Stourbridge

24.17 Land at Clent View Road, Stourbridge has not been allocated for residential development and
Taylor Wimpey objects to the Draft BCP on this basis.

24.18 Insufficient land is available within the Black Country and South Staffordshire on non-Green Belt land to meet the unmet housing needs of present and future generations and the release of Green Belt land is required. For the reasons identified in these representations, it is essential that further housing sites are allocated in the BCP. This will involve the release of additional Green Belt land. Exceptional circumstances therefore exist to remove land from the Green Belt.

24.19 A Delivery Statement has been prepared to support the allocation of the site and is submitted alongside these representations. We have also provided a brief description of the site and the reasons why it is considered suitable for allocation below.

24.20 The site will deliver up to 400 high quality homes suitable to the needs of the local community with a varied mix of house type, tenure and size, including affordable housing.

Clent View Road Site Description

24.21 The site is located on the western edge of Stourbridge and is bordered by Clent View Road to the east. The site is located primarily within the local authority boundary of South Staffordshire District Council [SSDC] but is also partially within the authority boundary of Dudley Metropolitan Borough Council [DMBC].

24.22 The Site comprises 19.6ha of improved grassland (16.5ha in South Staffordshire and 3.1ha in
Dudley) currently used as equestrian paddocks.

24.23 The site is situated approximately 2.5km south-west of the centre of Stourbridge and immediately abuts the established residential suburb of Stourbridge to the east, which is located within DMBC.

24.24 The Site is contained within well defined existing boundaries. It is bounded to the north by a public bridleway beyond which is dense woodland and agricultural land. To the east there is a permissive footpath named ‘Roman Road’, Clent View Road and the urban area of Stourbridge. This footpath is separated from the Site and Clent View Road by hedgerows. To the south there is a Public Right of Way and a line of mature trees, beyond which lies agricultural land; and to the south-west is a heavily wooded area (Bunkers Hill Wood). To the west, a line of trees extending from the northern boundary of the site to Frog Hall Cottages, bound the site towards the centre west. The site is further bounded to the west by a heavily wooded area, and a further line of trees which joins the wooded area to the south-west of the site, beyond which lies agricultural land.

Suitability of Clent View Road for Green Belt Release

24.25 We note that the site has not been considered in isolation in the BCGBS and this has a resultant impact upon the ratings identified in the Assessment.

24.26 In the Green Belt Technical Report submitted with these representations we have carried out our own assessment of the site in isolation as this is considered to be the most appropriate and transparent method of assessing its suitability for Green Belt release. The Technical Report sets out the reasons why land at Clent View Road, Stourbridge is suitable for release from the Green Belt.

Deliverability of Clent View Road

24.27 The site is being promoted by a national housebuilder, Taylor Wimpey, who can deliver the proposed residential scheme. Taylor Wimpey is seeking to commence development as soon as the Site is allocated.

24.28 It could deliver a up to 400 high quality family houses and will make a valuable contribution towards meeting the quantitative and qualitative needs of the community for market and affordable housing.

24.29 The site is not subject to any known constraints that would impede deliverability. There are no legal impediments, or any need for land in third party ownership.

24.30 Taylor Wimpey has reviewed the economic viability of the proposals in terms of the land value, attractiveness of the locality, level of potential market demand and projected rate of sales; as well as the cost factors associated with the Site including site preparation costs and site constraints. The site is economically viable and Taylor Wimpey is confident that residential development can be achieved within the first five years of the plan period

24.31 The land also benefits from clear, well-defined boundaries and it is considered that its allocation and future development will not have a detrimental impact on the form and character of the settlement. The allocation and development of the Site provides an opportunity to create a long term defensible boundary to Stourbridge and the provision of housing development for South Staffordshire and Dudley.

24.32 For the above reasons the site is fully deliverable.

Sustainability of Clent View Road

24.33 Stourbridge is identified within the adopted BCJCS and the emerging BCP as a Town Centre, which provides for convenience shopping as well local comparison shopping opportunities, local services and local leisure facilities. It is a key area in the settlement hierarchy below Strategic Centres. The provision of housing to maintain Stourbridge’s role in the settlement hierarchy of Dudley and the wider Black Country is therefore of importance. The delivery of high-quality housing in the locality will contribute to ensuring that population growth is focused in an area close to employment opportunities, which can be easily accessed via a sustainable transport network

24.34 The Site is located to the west of the residential area of Stourbridge in close proximity to a number of services and facilities in Stourbridge. Schools, shops, residential communities, and leisure facilities are all accessible by a choice of means of transport, including walking and cycling.

24.35 Stourbridge Town Centre is approximately 30 minutes walking distance from the northwest of the site where access to Stourbridge Town railway station is also available. Stourbridge Junction rail station is located approximately 3km from the proposed site and provides regular services to nearby and well-connected stations including Birmingham New Street, Kidderminster, Solihull, Worcester Shrub Hill, and Stratford-Upon-Avon.

24.36 The site is situated is situated 0.4km from Shenstone Avenue bus stop, which provides regular services to the centre of Stourbridge and Dudley.

24.37 The site is therefore located in an accessible location and would contribute to supporting existing services and facilities in the area including Stourbridge Town Centre.

24.38 The development of the site would provide a suitable range of dwellings in various types, sizes and tenures, including affordable housing, to meet the needs of the local population, and establish a mixed and sustainable community.

24.39 As detailed in the Delivery Statement for the site, the proposal will bring a number of economic and fiscal benefits in terms of job creation, additional monies to the Local Authority and increased expenditure in the economy.

24.40 No environmental constraints have been identified that would inhibit the future allocation and development of the site. It is currently in agricultural use and is considered to be of limited ecological value. The proposals will provide numerous compensatory improvements, and seek to retain, enhance or mitigate the existing ecological and environmental features of value on the Site.

24.41 Existing hedgerows and trees will be retained and incorporated where possible within the proposed development supplemented with further woodland planting to help screen the site and integrate it with surrounding assets such as Iverley Heath and Bunkers Hill Woods. The site extent allows the opportunity to provide wide-ranging enhancements to demonstrate a
‘biodiversity net gain’.

Masterplan for Clent View Road

24.42 The proposed masterplan is designed to:
• Create a development which is specific to Stourbridge by sensitively responding to the unique attributes and characteristics of the Site and its wider context.
• To provide safe and convenient access for both new and existing residents to local amenities and facilities through the delivery of public open space and pedestrian connections to Clent View Road, Roman Road, the public footpath adjacent to the Site leading to Iverley Heath and Bunkers Woods, and the adjacent public bridleway ‘Westwood Avenue’ to allow for opportunities to access nearby recreation assets, including Little Iverley Covert woodland.
• To provide a central area of greenspace to create a sense of place and provide recreational opportunities within the site through the provision of facilities such as LEAPs and MUGAs, and the use of sustainable links through the site incorporating existing assets such as the
Roman Road.
• To provide green gateways into the site along the main accesses, with the opportunity to create tree lined streets to contribute to the character and quality of the development and help mitigate and adapt to climate change.
• To provide a development of suitable scale, form and appearance which meets both the needs of the local community in a sustainable way, whilst also being sensitive to the character of the surrounding townscape and landscape setting.
• To retain, enhance and embrace the Site’s natural assets through the inclusion of naturalised green infrastructure including wetland attenuation basins, managed wild grasslands and the planting of native shrubs/trees to contribute to a well-designed and beautiful place in accordance with the Framework.

Alternative Masterplan

24.43 Taylor Wimpey is currently investigating the potential to include additional areas of land within the proposed masterplan for Clent View Road. The Alternative Masterplan includes these additional areas. As these areas would effectively provide development in areas surrounded by the land being promoted, or between this land and the existing urban area, they are not considered to perform any significant additional Green Belt role and are therefore suitable for release. The Alternative Masterplan is included in the Delivery Statement for Clent View Road which has been submitted alongside these representations.

24.44 These additional pieces of land would provide approximately 150 additional dwellings within a network of high-quality greens, routes and open spaces which would integrate with and connect to the wider development area. Existing tree belts and hedgerows to boundaries would be retained and enhanced to further improve containment and mitigate visual impact and would provide a well-connected and comprehensive greenspace network as part of the overall scheme. The additional open space brought forward in these areas would provide further recreational and placemaking opportunities within the site.

24.45 The Alternative Masterplan also identifies a ‘Potential Expansion Site’ to the west of the masterplanned area which measures 24ha in area. The potential to acquire and develop this land is also being investigated by Taylor Wimpey.

24.46 This land is well contained by existing permanent defensible boundaries which are capable of preventing urban sprawl and preventing encroachment into the wider countryside. An access road lined by established boundary hedgerows runs to the north and a thick belt of woodland planting at Bunkers Hill Woods to the west and south. The land would be contained by development on the Clent View Road site to the east. The future development of the site would not result in merging of settlements. It would retain a significant gap of approximately 2.3km between Stourbridge and Kinver and a gap of approximately 4.9km between Stourbridge and Kidderminster. This land does not affect the setting and special character of a historic town and therefore does not contravene this purpose. The release of this land from the Green Belt would not prevent the recycling of derelict land and other urban land within South Staffordshire or Dudley, as insufficient previously developed land and land in the urban area is available to meet future housing requirements.

24.47 It is considered that this land would form a logical future phase of development once the masterplanned area is completed and could potentially come forward for release towards the end of the BCP Site Assessment Report

24.48 The Clent View Road site is identified as Site Reference SA-0105-DUD in the Council’s Site
Assessment Report. The Assessment Report concludes the following on the site:

“The western boundary of the submitted site follows the borough boundary with South Staffordshire at the northern end and then expands to form a cross boundary ‘call for sites’ submission. The land within Dudley MBC is long and narrow.

The Green Belt and Landscape Sensitivity Assessment considers the landscape to have a
‘Moderate’ overall sensitivity to residential development, as the majority of the criteria score moderate and no criteria overrides that judgement. It rates harm to the Green Belt from release as ‘Moderate to High’ noting that the sub-parcel makes a strong contribution to preventing sprawl of the West Midlands conurbation to the east of the suburbs of Stourbridge, and to preventing encroachment on the countryside, and a moderate contribution to maintaining the separation of Stourbridge and Kidderminster (via intervening settlements). It goes on to say that the area, to the south of Westwood Avenue has an urban edge that is bounded by the well-treed hedgerow along Roman Road. Indeed, Sandy Lane acts as a strong defensible boundary to the Green Belt at this point.

If development were to be allowed on this site it would effectively allow the conurbation to expand into open countryside. Furthermore, the borough boundary cuts though the centre of the grazed fields and the consequent new boundary to the built-up area would be very weak. This makes this site a poor choice for the receipt of new development.

There is a high-pressure gas pipeline running north south along the Roman Road, the zone of influence of which effectively covers the majority of the site. This creates a physical constraint”.

24.49 For the reasons set out in the Green Belt Technical Report submitted with these representations, we consider that the BCGBS does not accurately assess the contribution of the site to the Green Belt and its contribution is lower than recorded.

24.50 Whilst the allocation of the site would involve the expansion of the conurbation into the open countryside, this would be the case for any site on the edge of the existing conurbation (many of which have been allocated in the draft BCP) so we do not consider that this is a valid reason to discount the site.

24.51 The assessment that the borough boundary cuts though the centre of the grazed fields and the consequent new boundary to the built-up area would be very weak, is also flawed as the site would not be delivered on this basis. The site is being promoted as a cross boundary site which extends into South Staffordshire and would be defined by well established boundaries, including existing field boundaries. As a result, the new boundary to the built up area would be strong.

24.52 Taylor Wimpey is aware of the gas pipeline running along Roman Road and the scheme would be designed to ensure that it would not impact upon the zone of influence. The pipeline does not therefore create a physical constraint which would preclude the development of the site.

24.53 For the above reasons, the conclusions in the BCP Site Assessment Report are considered to be unfounded and the site is suitable for removal from the Green Belt and allocation for residential development.

Conclusions

24.54 Land at Clent View Road, Stourbridge is considered suitable for allocation for residential development because:

• It is entirely deliverable and would make a valuable contribution to meeting future housing needs, including affordable housing within the first five years of the plan period.
• There is no overriding constraint that will impede the delivery of the site.
• It does not make a significant contribution to the purposes of the Green Belt and is suitable for release.
• The site should be identified as it will meet the needs of both South Staffordshire and
Dudley where there are clear issues with regards to the duty to cooperate and meeting cross- boundary strategic needs.