6 Housing

Comment

Representation ID: 22048

Received: 11/10/2021

Respondent: Ms Jan Norton

Members of the public raise concerns about the types of houses that are planned. Many point to the possibility that there is an under-estimate of quality, affordable homes that people can afford to heat (BCP, 5.12 c – “a key priority for tackling health and wellbeing”; “an increased proportion of being affordable or in the social housing sector”)

I have heard the Black Country Plan described as both a “speculators’ charter” and a “landlords’
charter”.

Object

Representation ID: 22218

Received: 11/10/2021

Respondent: Miss Nikita Melling

I do not agree that housing should be put where you want it to be!

Object

Representation ID: 22545

Received: 11/10/2021

Respondent: Mr Roger Morton

Objects to green belt proposals.
Cites sufficient brownfield/derelict land.
Cites greenbelt development will continue if allowed.
Objects as green belt should never be encroached upon.
Denies population pressure to remove it justified, claims Africa & Brazil population harming wildlife & rain forest.

Comment

Representation ID: 22639

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Proposed development sites crossed or in close proximity to National Grid assets:
Following a review of the above Development Plan Document, we have identified that one or
more proposed development sites are crossed or in close proximity to National Grid assets.

Details of the sites affecting National Grid assets are provided below.

[Table headings: Development Plan Document Site Reference/Asset Description]

HOU1, HOU2, HOU3 New Road (former car showroom), Willenhall
275Kv Underground Cable route: BUSHBURY - WILLENHALL
[See Attached Map 2]

HOU1, HOU2, HOU3 Land to North of Painswick Close Sub Station
- 4YP ROUTE TWR (002 - 101): 400Kv Overhead Transmission Line route: BUSTLEHOLM - DRAKELOW 1
- 4YP ROUTE TWR (001A - 002): 400Kv Overhead Transmission Line route: BUSTLEHOLM - DRAKELOW 1
- 4YP ROUTE TWR (001 - 002): 400Kv Overhead Transmission Line route: BUSTLEHOLM - DRAKELOW 2
[See Attached Map 6]

Comment

Representation ID: 23543

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC's principal concern is to optimise the provision of affordable housing.
HAPC is a sig. developer/investor in people, contributes to plan objectives & acts in the community.
Notes that for AH targets to be met, AH must be located across region in various models.

Support

Representation ID: 23544

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC supports BCCS update & collaborative comp. plan making.
Supports Strat Policies : to facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places, and support to meet housing needs between now and 2039,
Supports plan end date 2039 & 15 years remaining at adoption.

Support

Representation ID: 23545

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC supports: greenbelt release for affordable housing purposes, redefined permanent GB boundary,
ENV3 compensatory biodiversity & access mitigations, esp Bio. Net Gain initiatives.

Support

Representation ID: 23547

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC supports: min target of HOU1, as there is high level of housing need.
supports HOU2: Housing Density, Type and Accessibility, but urges flexibility.
Supports HOU3 with amended target of 867 new affordable homes, not a percentage.
Supports proactive/flexible approach to delivery of AH.
Supports policies CC2 & CC7, and a greener, more efficient and more environmentally friendly future.

Support

Representation ID: 23548

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC supports 10 as thresholds for AH, notes 10% & 20% AH are minimums, supports 30% AH in affluent locations.
Supports rigorous testing of viability to get most AH possible.
Supports tailored approach to tenure in HOU3.

Object

Representation ID: 23549

Received: 08/10/2021

Respondent: Tetlow King Planning

Agent: Tetlow King Planning

HAPC wishes alternative locations to centres & core regen areas to be considered.
HAPC urges 4 Mets not to discount new applications coming forward.
HAPC wishes role of 100% AH schemes to be recognised
HAPC wishes that no more than 25% First Homes are sought.
HAPC wishes clustering of AH in larger schemes to not exceed 10 to 15 dwellings

Comment

Representation ID: 43906

Received: 11/10/2021

Respondent: Department of Education

Developer Contributions and Community Infrastructure Levy (CIL)

One of the tests of soundness is that a Local Plan is ‘effective’, meaning the plan should be deliverable over its period. In this context and with specific regard to
planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to
meet the increase in demand generated by new developments. The department notes that both Sandwell MBC and Dudley MBC have adopted CIL regimes in
place and that the Black Country Plan seeks to ensure appropriate rates are levied and the right infrastructure is secured across the Black Country Plan area.

Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer
contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer
contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106
relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. The department supports
the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations.

We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively when it has
been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a
secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period.

19. The department would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability
assessment or other evidence relevant to education which may be used to inform local planning policies and CIL charging schedules. As such, please add
the department to the database for future consultations on relevant plans and proposals.

Comment

Representation ID: 45419

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Comment

Representation ID: 45890

Received: 11/10/2021

Respondent: Transport for West Midlands

Policy HOU1 & 2 Delivering Sustainable Housing Growth

Alongside the focus for new homes to be built within Centres and Core Regeneration Areas, housing policies should consider the importance of building new homes along key transport corridors and transport hubs. And while these Core Regeneration Areas may well be along some key public transport corridors, this is not explicitly highlighted in the policies, but we feel this needs to be demonstrated throughout the plan.

To help meet housing requirements, the Black Country should also continue to examine increasing minimum housing density levels in its centres to 50 or more per hectare as promoted by the RTPI4 and the Urban Transport Group. A review of minimum densities of local plans and spatial frameworks in other UK City Regions could be of value, with areas including Greater Manchester and Liverpool presenting housing density levels as high as 75 dwellings per hectare for houses and 150+ dwellings per hectare for apartments. Increasing dwelling densities, in more built up urban areas will then help create more walkable mixed-use developments, with excellent sustainable mobility options while reducing the need to travel by car.