4 Infrastructure & Delivery

Comment

Representation ID: 21242

Received: 11/10/2021

Respondent: Newlands Developments

Infrastructure and Delivery (Section 4)
Strategic Policies should make sufficient provision for infrastructure, as confirmed in parts b) and c) of NPPF Paragraph 20, which states:

“Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for infrastructure for:
b) transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
c) community facilities (such as health, education and cultural infrastructure)”

Draft Policy DEL1 (Infrastructure Provision) of the Draft Black Country Plan emphasises that all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impacts on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area. We are therefore generally supportive of this policy, owing to its conformity with national planning policy.

It is however noted that Part 3 of Draft Policy DEL1 advises that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents and, where appropriate, masterplans:

a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure provision.

Whilst generally supportive of this approach, it is considered that the Site can be suitably delivered without significant upgrades to the supporting infrastructure. We would therefore be grateful to be included as part of any future consultation on the Infrastructure Delivery Plan. Indeed, we would expect the Infrastructure Delivery Plan to support the emerging Black Country Plan through Examination.

Comment

Representation ID: 22509

Received: 11/10/2021

Respondent: Environment Agency

Chapter 4 states that ‘Parts of the Black Country's existing highway infrastructure, and the motorway network, suffer from congestion.’ Some of that will involve movements of waste vehicles, from small vans, to articulated lorries. As mentioned above reducing waste movements and mileages will help reduce this congestion (and air pollution), but requires provision of sufficient accessible waste infrastructure.

Comment

Representation ID: 22632

Received: 11/10/2021

Respondent: National Highways

Infrastructure Delivery
It is noted within the draft BLP it states that parts of the Black Country’s existing highway
infrastructure, and the motorway network, suffer from congestion, and that detailed
transport modelling work is ongoing, and this evidence will be available to inform the
documents publication.
National Highways disagrees with this approach as the transport evidence base and
transport modelling work should have been provided alongside this document as part of
the consultation. This would enable a robust assessment of the proposals to be identified
to ensure that the proposed levels of growth can be accommodated on the SRN and LRN.
As well as identifying what the transport infrastructure needs, and requirements are to
enable the proposed levels of growth to be sustainably accommodated and delivered.

At present we conclude that without the transport evidence base to support infrastructure
requirements and their delivery that the Local Plan in its current form is unsound.

Comment

Representation ID: 22635

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Black Country Plan Consultation
August – October 2021
Representations on behalf of National Grid



National Grid has appointed Avison Young to review and respond to local planning authority
Development Plan Document consultations on its behalf. We are instructed by our client to
submit the following representation with regard to the current consultation on the above
document.



About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission
system in England and Wales. The energy is then distributed to the electricity distribution
network operators, so it can reach homes and businesses.



National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system
across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas
distribution networks where pressure is reduced for public use.



National Grid Ventures (NGV) is separate from National Grid’s core regulated businesses. NGV
develop, operate and invest in energy projects, technologies, and partnerships to help accelerate
the development of a clean energy future for consumers across the UK, Europe and the United
States.



National Electricity Transmission System
Specific development proposals within your local planning authority area are unlikely to have a
significant direct effect upon National Grid’s electricity transmission system. Generally,
improvements to the system to provide supplies to the local distribution network are as a result
of overall regional demand growth rather than site specific developments.



Electricity Distribution System
National Grid does not distribute electricity to individual sites and premises directly. It is the role
of local distribution companies to distribute electricity to homes and businesses. The website
below includes a map showing the areas that the local distribution network operators are
responsible for and provides links to their websites:
http://www.energynetworks.org/info/faqs/electricity-distribution-map.html
The local distribution network operator is responsible for operating the local electricity
distribution network which supplies electricity from the national electricity transmission system
direct to sites and premises. If new infrastructure is required in response to an increase in
demand across the local electricity distribution network the operator may request
improvements to an existing National Grid substation or a new grid supply point.



National Gas Transmission System
National Grid owns and operates the high-pressure gas transmission system in England,
Scotland and Wales. This consists of around 4,300 miles of pipelines and 26 compressor stations
connecting to the distribution networks.



New gas transmission infrastructure developments (for example pipelines and associated
installations) are periodically required to meet increases in regional demand and changes in
patterns of supply. Developments to the network occur as a result of specific connection
requests, for example power stations, and requests for additional capacity on the network from
gas shippers.



Gas Distribution Networks
In the UK, gas leaves the transmission system and enters the distribution networks at high
pressure. It is then transported through a number of reducing pressure tiers until it is finally
delivered to sites and premises. The website below includes a map showing the distribution
networks and their regions:



http://www.energynetworks.org/info/faqs/gas-distribution-map.html

A plan showing details of the site locations and details of National Grid’s assets is attached
to this letter. Please note that this plan is illustrative only.



Please also see attached information outlining further guidance on development close to
National Grid assets.



Further Advice
National Grid is happy to provide advice and guidance to the Council concerning their networks.
Please see attached information outlining further guidance on development close to National
Grid Infrastructure.



If we can be of any assistance to you in providing informal comments in confidence during your
policy development, please do not hesitate to contact us.



To help ensure the continued safe operation of existing sites and equipment and to facilitate
future infrastructure investment, National Grid wishes to be involved in the preparation,
alteration and review of plans and strategies which may affect their assets. Please remember to
consult National Grid on any Development Plan Document (DPD) or site-specific proposals that
could affect National Grid’s infrastructure.

Guidance on development near National Grid assets
National Grid is able to provide advice and guidance to the Council concerning their networks
and encourages high quality and well-planned development in the vicinity of its assets.



Electricity assets
Developers of sites crossed or in close proximity to National Grid assets should be aware that it
is National Grid policy to retain existing overhead lines in-situ, though it recognises that there
may be exceptional circumstances that would justify the request where, for example, the
proposal is of regional or national importance.



National Grid’s ‘Guidelines for Development near pylons and high voltage overhead power lines’
promote the successful development of sites crossed by existing overhead lines and the creation
of well-designed places. The guidelines demonstrate that a creative design approach can
minimise the impact of overhead lines whilst promoting a quality environment. The guidelines
can be downloaded here: https://www.nationalgridet.com/document/130626/download



The statutory safety clearances between overhead lines, the ground, and built structures must
not be infringed. Where changes are proposed to ground levels beneath an existing line then it is
important that changes in ground levels do not result in safety clearances being infringed.
National Grid can, on request, provide to developers detailed line profile drawings that detail the
height of conductors, above ordnance datum, at a specific site.



National Grid’s statutory safety clearances are detailed in their ‘Guidelines when working near
National Grid Electricity Transmission assets’, which can be downloaded
here:www.nationalgridet.com/network-and-assets/working-near-our-assets



Gas assets
High-Pressure Gas Pipelines form an essential part of the national gas transmission system and
National Grid’s approach is always to seek to leave their existing transmission pipelines in situ.
Contact should be made with the Health and Safety Executive (HSE) in respect of sites affected by
High-Pressure Gas Pipelines.



National Grid have land rights for each asset which prevents the erection of permanent/
temporary buildings, or structures, changes to existing ground levels, storage of materials etc.
Additionally, written permission will be required before any works commence within the
National Grid’s 12.2m building proximity distance, and a deed of consent is required for any
crossing of the easement.

National Grid’s ‘Guidelines when working near National Grid Gas assets’ can be downloaded here:
www.nationalgridgas.com/land-and-assets/working-near-our-assets

Comment

Representation ID: 23031

Received: 17/08/2021

Respondent: Severn Trent Water

[Attachment: DPR Wal 1 Severn Trent]

Potential impact of proposed developments on sewage treatment works

General comment regarding treatment capacity:
Whilst sewage treatment works may not have sufficient spare capacity to accept the levels of development being proposed in its catchment area this does not necessarily mean that development cannot take place. Under Section 94 of the Water Industry Act 1991 sewerage undertakers have an obligation to provide additional treatment capacity as and when required. Where necessary we will discuss any discharge consent implications with the Environment Agency. If there are specific issues which may prevent or delay the provision on additional capacity these have been highlighted below.
[Headline data taken from the attachment: ’DPR Wal 1 Severn Trent’]
BARNHURST (WRW)
1. Estimate headroom based on current quality performance (RAG) - Significant
2. "Future quality issues (RAG)" – [None]
3. "Physical constraints regarding provision of additional treatment capacity (RAG)" - [None]
4. Any other comments - AMP7 scheme for CM - sufficient spare capacity on site for the proposed growth.
COVEN HEATH (WRW)
1. Significant
2. [None]
3. [None]
4. AMP7 scheme for CM - sufficient spare capacity on site for the proposed growth.

GOSCOTE (WRW)
1. Significant
2. Probable issue
3. Limited potential to provide additional capacity
4. Scheme for quality purposes. Sufficient spare capacity to accommodate proposed growth. Ammonia performance is challenging (unknown discharge into sewerage system).

GOSPEL END (WRW)
1. Significant
2. [None]
3. [None]
4. AMP7 scheme for quality purposes, scope also includes reduction of DWF to 1,800m3/d which will reduce the spare capacity on site. There will still be spare capacity even though at the moment there is no growth proposed for this site.

LITTLE ASTON (WRW)
1. Significant
2. [None]
3. [None]
4. Sufficient spare capacity to accommodate proposed growth.

LOWER GORNAL (WRW)
1. Significant
2. [None]
3. [None]
4. AMP7 quality scheme - this site will close and flows will be transferred to Roundhill. Any load from the new dwellings would also have to be redirected.

MINWORTH (WRW)
1. Significant
2. [None]
3. [None]
4. Sufficient spare capacity to accommodate proposed growth.

RAY HALL (WRW)
1. Significant
2. [None]
3. [None]
4. AMP7 scheme for CM. Sufficient spare capacity to accommodate proposed growth.

ROUNDHILL (WRW)
1. Minimal
2. [None]
3. [None]
4. AMP7 scheme for quality purposes and allowance to treat tranferred load from Lower Gornal. DWF will be increased to 64,500m3/d which will create spare headroom sufficient to accommodate the proposed growth.

TRESCOTT (WRW)
1. Significant
2. [None]
3. [None]
4. Sufficient spare capacity to accommodate proposed growth.

WALSALL WOOD (WRW)
1. Minimal
2. Probable issue
3. [None]
4. Sufficient spare capacity can accommodate majority of proposed growth. Ammonia performance is challenging.

WILLENHALL (WRW)
1. N/A
2. N/A
3. N/A
4. Load transferred to Minworth STW

Comment

Representation ID: 23034

Received: 17/08/2021

Respondent: Severn Trent Water

[PDF Severn Trent Draft Black Country Plan (BCP) consultation]

[Introductory/overarching paragraphs (other attachments include data and responses)]

FUTURE IMPACT ON WATER SUPPLY – Our Demand Team have responded back to me and having reviewed the list of sites along with the details in the consulta on document for the housing need. Having also checked the housing need against the WRMP19 housing that we have, whilst this is slightly higher than what is in our current plan, we do not have any concerns for the addi onal level of sites. As we are currently refreshing our housing data at the moment for the next plan, we will be including your latest levels. Overall, we have no concerns from a resource side.
FUTURE IMPACT ON WATER RESOURCES – The Water Resources Team have reviewed the allocated sites. Please find attached the spreadsheets showing the impact in a RAG status format for each individual site. As mentioned previously, whilst we await the waste water assessment information, please also note, having looked at the sewer records, the following sites appear to have Wastewater assets either very close to, or passing through the site
Also, in October 2012, due to a change in legislation, some former private sewers have now become this Company’s responsibility and may also be present on the site. Any underground asset (such as gravity sewers or rising mains) will need to be protected and any new proper es will need to be positioned a certain distance away from these pipes (dependent upon the size of the pipe). Alternatively, it may be possible for the pipes to be diverted, in some certain circumstances, work to divert assets may be deemed as high risk and would need to be undertaken by this Company. This can be a lengthy process and may impact the delivery of any building work on site. Also, we would advise that where a proposed development site is close to a Non-Infrastructure site (such as a Sewage Treatment works or a Sewage Pumping Sta on), the proposed buildings need to be set a certain distance away from the compound site in order to minimise on future noise / smell / nuisance issues. Any developer wishing to build on these allocated sites would be advised to discuss this with our Asset Protec on Team at the most earliest convenience. They can be contacted via email at net.dev.west@severntrent.co.uk.

Comment

Representation ID: 23036

Received: 17/08/2021

Respondent: Severn Trent Water

Attachment: PDF DI Wastewater Treatment Query Template BCP July 2021

Potential impact of proposed developments on sewage treatment works Date
These are desktop assessments using readily available information and have not been subjected to detailed hydraulic analysis
General comment regarding treatment capacity:
Whilst sewage treatment works may not have sufficient spare capacity to accept the levels of development being proposed in its catchment area this does not necessarily mean that development
cannot take place. Under Section 94 of the Water Industry Act 1991 sewerage undertakers have an obligation to provide additional treatment capacity as and when required. Where necessary
we will discuss any discharge consent implications with the Environment Agency. If there are specific issues which may prevent or delay the provision on additional capacity these have been highlighted below


[Headline data from table headings summarised below, further detail in document if needed]
1. Sewage Treatment Works Name
2. Estimate headroom based on current quality performance (RAG)
3. Future quality issues (RAG)
4. Physical constraints regarding provision of additional treatment capacity (RAG)
[sites as below]
1. BARNHURST (WRW)
2. Significant
3. None
4. None
AMP7 scheme for CM - sufficient spare capacity on site for the proposed growth.

1. COVEN HEATH (WRW)
2. Significant
3. None
4. None
AMP7 scheme for CM - sufficient spare capacity on site for the proposed growth.


1. GOSCOTE (WRW)
2. Significant
3. Probable issue
4. Limited potential to provide additional capacity
Scheme for quality purposes. Sufficient spare capacity to accommodate proposed growth. Ammonia performance is challenging (unknown discharge into sewerage system).

1. GOSPEL END (WRW)
2. Significant
3. None
4. None
AMP7 scheme for quality purposes, scope also includes reduction of DWF to 1,800m3/d which will reduce the spare capacity on site. There will still be spare capacity even though at the moment there is no growth proposed for this site.

1. LITTLE ASTON (WRW)
2. Significant
3. None
4. None

Sufficient spare capacity to accommodate proposed growth.

1. LOWER GORNAL (WRW)
2. Significant
3. None
None
AMP7 quality scheme - this site will close and flows will be transferred to Roundhill. Any load from the new dwellings would also have to be redirected.

1. MINWORTH (WRW)
2. Significant
3. None
4. None
Sufficient spare capacity to accommodate proposed growth.

1. RAY HALL (WRW)
2. Significant
3. None
4. None
AMP7 scheme for CM. Sufficient spare capacity to accommodate proposed growth.

1. ROUNDHILL (WRW)
2. Minimal
3. None
4. None
AMP7 scheme for quality purposes and allowance to treat tranferred load from Lower Gornal. DWF ill be increased to 64,500m3/d which will create spare headroom sufficient to accommodate the proposed growth.

1. TRESCOTT (WRW)
2. Significant
3. None
4. None
Sufficient spare capacity to accommodate proposed growth.

1. WALSALL WOOD (WRW)
2. Minimal
3. Probable issue
4. None
Sufficient spare capacity can accommodate majority of proposed growth. Ammonia performance is challenging.

1. WILLENHALL (WRW)
2. None
3. None
4. None
Load transferred to Minworth STW

Comment

Representation ID: 23330

Received: 11/10/2021

Respondent: Bloor Homes

BHL recognise the importance of providing an appropriate mix and amount of affordable housing as
part of meeting BCA’s identified housing needs, and in particular recognise the significance of meeting the housing needs of specific groups within society in accordance with NPPF paragraph 61. Although BHL supports BCA’s differentiated approach, it is noted that the proposed percentages are in excess of the recommendations of the Black Country Viability and Delivery Study. Further clarification on this is requested.

Additionally, in accordance with paragraph 16(d) of NPPF 2021, policies should be unambiguous and
clearly written, so it is evident how a decision maker should react to development proposals. BHL considers that the type and tenure of affordable housing sought is ambiguous: BCA should provide further clarification of its requirements which should be justified by supporting evidence.

Notwithstanding the above points, the requirements in relation to affordable housing delivery and mix, will need to be tested alongside the other policy requirement set out in the plan through a full Viability Assessment that should seek to ensure that the total cumulative cost of all relevant policies will not undermine deliverability of the plan.

Object

Representation ID: 44797

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Current supply – 10% discount on existing allocations

5.8 A total of 4,973 new homes are identified as being deliverable from this source of supply over the new plan period (2020-39) with the largest contributions to supply coming from Dudley (2,506 homes) and Wolverhampton (2,248 homes).

5.9 The ‘Existing Allocations’ included in this source of supply are stated by Table 4 in the Draft BCP as to be located in defined Strategic Centres.

5.10 As a result of being located in Strategic Centres, these sites are allocated in the subsequent Area Action Plans (AAPs) that were intended to deliver the strategic policies for those areas of the BCCS. As far as we can tell, there is no new evidence in relation to them in the Draft BCP. The sites are not, for example, listed individually in the Draft BCP but do appear in the SHLAA.

5.11 The evidence in relation to the deliverability of these sites is therefore included in the AAPs, within which (from our assessment) there is limited evidence of developer involvement or justification/explanation that the allocations were sound, developable or deliverable.

5.12 There are numerous examples in the supporting evidence base and documentation where it is acknowledged by the Councils themselves that there are possible constraints including land ownership, viability, need to relocate existing uses and remediation issues. This immediately casts doubt on whether the sites can be considered developable, which requires the sites to be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged.

5.13 The BCP Evidence Base includes a Viability and Delivery Study (May 2021), where at para 7.7 it is concluded that:

“The analysis also excludes housing development in Strategic Centres, given that the BCP will not allocate land in the Strategic Centres. No specific sites have been identified in those centres for the purposes of this assessment. The viability assessment above has however found that development there is unviable, even with zero developer contributions. Without grant support therefore, it is likely that no housing – either market or affordable – would be delivered in the Strategic Centres. The viability assessment does not consider what level of grant would be required to make development viable in the centres - because each strategic centre scheme is likely to be unique, with its own set of challenges and subject to site-specific assessment.”

5.14 This is a critical finding when considering whether these sites can be relied on to be developed in the plan period.

5.15 Turley have analysed the status of existing allocations in the Councils’ evidence base and consider each authority area in turn below.