Policy DEL2 – Balance between employment land and housing

Object

Representation ID: 10966

Received: 18/09/2021

Respondent: Mr Khaled Amin

Please do not build on the Seven Cornfields. It is a valuable an much used open space for the surrounding community. Thank you.

Comment

Representation ID: 14842

Received: 10/10/2021

Respondent: Alison Wilkes

Policy DEL2
4.30
Comment: Policy ENV1 should be added to the list of policies that development proposals need to consider.

5.1
Comment: The link between health and wellbeing and the natural environment should be explicitly described. Accessible high-quality greenspace is important to local communities, as demonstrated in lockdown and in scientific research.

Comment

Representation ID: 19215

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

4.30
Comment: WTBBC request that Policy ENV1 – Nature Conservation is added to the list of policies that such development proposals will also need to consider. Reinforcing the requirement for windfall development to consider the Environmental Transformation policies will add further to their significance and ensure developers are considering the purpose of these polices at the earliest stage.

Support

Representation ID: 22271

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Balance between Employment Land and Housing

4.3 Draft Policy DEL2 (Balance between employment land and housing) sets out that “development of housing or employment (E(g) (ii) (iii), B2 or B8 class uses) on previously developed land that is not allocated for these uses (“windfall sites”) will be permitted where the proposal accords with other BCP and local plan policies and strategic priorities” subject to four criteria. We agree that this is appropriate on windfall sites only within the Black Country where there is an inadequate provision of land available to meet both the housing and employment requirement. We consider this policy approach is reasonable where windfall sites will secure provision over and above the anticipated supply, and will make the best use of available land and infrastructure, whilst not having an adverse effect on neighbouring uses.

Object

Representation ID: 23372

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy DEL2
CPRE supports this policy as it sets out how development on brownfield sites will be judged. However, the policy should be more positive in its approach to brownfield development.
The use of brownfield registers and other tools should be encouraged so that there is a positive encouragement of the use of redundant brown field sites.
As set out in our objection to CSP1, we consider there is considerable scope for further brownfield land to come forward and there is likely to be on-going change and regeneration both in the Black Country centres and in areas of renewal. The Plan needs to support this on-going change, not only to protect the countryside from incursion but to allow for renewal and to ensure the Black Country remains an attractive area to invest in

Object

Representation ID: 23570

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

BROWN FIELD AND DERELICT LAND SITES FIRST (Policy DEL2 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group considers that the changing evidence and absolute scale of Brownfield and Derelict Land sites development for housing purposes and needs has to be monitored thoroughly and plotted to understand the dynamics at play in the sub-region and neighbourhoods.

With few reservation, mostly relating to the characteristics and locality of specific sites, the Save the Seven Cornfields Campaign Group supports Housing Development on Brownfield and Derelict Land sites. The Save the Seven Cornfields Campaign Group opposes development on the Seven Cornfields Green Belt and other important Green Belt zones.

There is ample Brownfield and Derelict Land sites within the Black Country sub-region to service its needs for several years into the next decade and further. Incentives can assist developers to make the right decision.

When Derelict Land grant, sometime ago, was available to Local Authorities for tackling Dereliction, many sites where annually transformed into productive use including housing across the sub-region.

Taxation relief is another method to ensure a faster rate of transformation of Derelict and Brownfield sites. Governments should be lobbied to provide such assistance.

The failure to develop Brownfield sites has much to do with margins of profitability and economies of scale. This a private sector consideration and not necessarily an economic concept applicable to the public who instinctively know what is known as a Public Good in Economic Theory.

It is easier and more profitable to develop on most Green Belt and Green field sites than on Derelict and Brown Field sites. It is not, however, always easier and more profitable to develop on most Green Belt and Green Field sites when the infrastructure costs of over-intensification of use of services are taken into consideration.

In addition, Housing Developers and Speculators favour the acquisition and land banking of Greenfield sites to control the price of land already held by them and can be classed in their accounts as an investment. In the same manner, the most famous Diamond monopoly merchant buys and then withholds diamonds to ensure a higher price than would be naturally be the case if these diamonds where released on the open market. Artificial scarcity is created for Housing land (and diamonds).

Notwithstanding these facts, there is no logical reason for a Local Authority to release Greenfield sites or extinguish Green Belt status when there are many Brown Field and Derelict Land sites to develop first.

Allowing easy access to Green Belt development means the unsightly Brownfield and Derelict Land sites will remain for longer than necessary were the natural market mechanisms not distorted by Land Banking. They will not be transformed into useful use when they could have been.

Anybody with an eye to sustainable Land Use policy and environmental conservation in its largest sense would ensure the future Housing Demand was met by a policy of Brownfields first.

On 17th March 2017, West Midlands Combined Authority (WMCA) Board received a Report entitled Land Fund: Black Country Strategic Brownfield Land Programme. The Report noted:

“The Brown Field Strategic Brownfield Land Programme has identified a robust and deliverable pipeline of £342m of schemes, leveraging total investment of over £1.4b within three Priority Propositions of Delivering Black Country Garden City, Establishing High Value Manufacturing (HVM) Capital City and Strategic Population Centres.”

With investment from the WMCA Board, the Report made it clear that remediation would deliver 1600 houses. What higher levels of reclamation could be achieved over the Local Plan period with a more targeted approach? Enough to not need development of the Green Belt (or the additional 4,000 pledged by South Staffordshire Council).

Given the rising vacancy trends in retail, office and industrial property and the diminishing demand, the annual growth of the supply rate of unwanted commercial and Derelict Land and Brownfield sites will increase and the net result will be a year-on-year incremental growth and, therefore, a much higher total availability of such sites -unless of course there is a consequential turnover of reclamation for productive use like Housing. (This then suggests that less of the South Staffordshire Housing requirement -either normal (4,000) or exaggerated target (8,000) - will have to come from Green sites or the Green Belt.)

TRIPLE LOCK - PREVENTION OF PLANNING BLIGHT (policy Del 2 in the Black Country Plan 2039)

If the prospect of additional houses as planned and formally agreed in the Black Country Plan 2039 moves to that reality then measures must be in place to prevent the problems, recently witnessed, when retailers acquired land or development rights in cities to prevent expansion of their competitors. In Wolverhampton City Centre this created long standing problems.

If developers or builders were to start but not complete work on all the Green Belt sites then the worst of all worlds would have arrived; lost Green Belt but not completed sites with a few houses but no amenities.

Planning Blight is where the reduction of economic activity or property values in a particular area result from expected or possible development.

The Save the Seven Cornfields Campaign Group proposes that there should be a Triple Lock applied to Green Belts. There should be proper monitoring of housing development in Black Country (& South Staffordshire) and Green Belts at risk and other important Green Sites should not be released at once but a phasing should be operable.

The release of individual sites should then only occur when it is obvious that the available non-Green Belt sites in the Black Country (& South Staffordshire) and the Brownfield and Derelict Land sites in the districts within the Black Country have been developed, that the Black Country Housing figures have not been met year-on-year and the lowest graded Green Belt sites with the fewest constraints get released first.

This Triple Lock should be written within the Black Country 2039 Plan’s Objective and Planning and Development Briefs and it must form the basis of future agreements with developers and builders.

Object

Representation ID: 43914

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.30 This policy covers development of housing or employment on previously developed land ‘that is not allocated for this uses’, so would apply for any planning applications for residential development on existing employment sites. Both the housing and employment shortfalls are significant – circa 37% of the total need (notwithstanding that no evidence has been prepared to indicate whether the proposed component of the housing supply on existing employment sites has been factored into the employment land shortfall).
3.31 As set out in the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) there is limited evidence that there is any trend of housing sites coming forward for employment development in the urban area, where as there is evidence that employment sites are sometimes redeveloped for new homes. Examples of this are the Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated supply from this source going forward).
3.32 So it is anticipated this policy would mostly be applied to new housing on employment sites. Any further loss of employment land would only exacerbate the Council’s already significant employment land shortfall of 210ha, at a time when the Black Country’s economy is growing, with the employment rate growing faster than the average in England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft BCP).
3.33 Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that momentum”. Policy DEL2 should reflect this growth and ensure the employment land shortfall does not unnecessarily increase, it should therefore be seeking to provide greater protection of existing employment sites (no protections are provided in draft policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to the NPPF, which requires a sufficient supply of employment sites to be provided.
3.34 This can be done through requiring any application for residential development on an existing employment site to include evidence the site has been marketed for a certain period and that there is no reasonable interest. This is an approach taken by a number of authorities, including neighbours such as Lichfield District.
3.35 Rather than compromising its employment land supply further, the plan should be seeking to maximise locations for development outside of the urban area, and increasing the number of homes allocated on sites currently in the Green Belt. Land at Pennwood can assist in ensuring the Black Country’s housing land supply is robust (we set out the site’s benefits at Section 2 and discuss the Councils’ assessment of the site
further at Section 4) and does not compromise the plan’s ability to meet the area’s employment needs.

Comment

Representation ID: 43932

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy DEL2 (balanced between employment land and housing)
3.28 This policy covers development of housing or employment on previously developed
land ‘that is not allocated for this uses’, so would apply for any planning applications
for residential development on existing employment sites. Both the housing and
employment shortfalls are significant – circa 37% of the total need.
3.29 There is limited evidence that there is any trend of housing sites coming forward for
employment development in the urban area, where as there is evidence that
employment sites are sometimes redeveloped for new homes. Examples of this are the




10

Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on
Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated
supply from this source going forward).
3.30 It is anticipated this policy would mostly be applied to new housing on employment
sites. Any further loss of employment land would only exacerbate the Council’s already
significant employment land shortfall of 210ha, at a time when the Black Country’s
economy is growing, with the employment rate growing faster than the average in
England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft
BCP).
3.31 Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that
momentum”. Policy DEL2 should reflect this growth and ensure the employment land
shortfall does not unnecessarily increase, it should therefore be seeking to provide
greater protection of existing employment sites (no protections are provided in draft
policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to
the NPPF, which requires a sufficient supply of employment sites to be provided.
3.32 This can be done through requiring any application for residential development on an
existing employment site to include evidence the site has been marketed for a certain
period and that there is no reasonable interest. Indeed this is an approach taken by a
number of authorities, including neighbours such as Lichfield District.
3.33 Rather than compromising its employment land supply further, the plan should be
seeking to maximise locations for development outside of the urban area, and if
anything, increasing the number of homes allocated on sites currently in the Green
Belt. This only emphasises how important IM Land’s site at Queslett Road, Walsall is to
ensuring the plan delivers on its objectives and meets it housing and employment
needs.

Comment

Representation ID: 45887

Received: 11/10/2021

Respondent: Transport for West Midlands

There is strong evidence that the spatial proximity of amenities have greatly influenced and will continue to influence peoples patterns of travel demand. As land uses have become more dispersed and cars more affordable, greater switches from public transport to car usage have been witnessed, leaving many services out of easy reach of the 32% of the region’s population who don’t own a car. It is therefore vital that all new development provides appropriate access to opportunities for training, apprenticeships and local jobs, especially for those most vulnerable and those living in deprived deciles within the indices of multiple deprivation.

The WM LTP Green Paper has also outlined the benefits of closer links between transport and land use planning – in order to help create places in which people’s daily needs can be met within a short walk, cycle or by public transport.

Comment

Representation ID: 46179

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Draft policy DEL2 is concerned with ‘windfall sites’ for housing or employment development. It is drafted as a criteria based policy with (1d) stating that ‘Proposals for new development must take account of existing adjacent activities where the proposed development could have an adverse effect on or be affected by neighbouring uses. Mitigation of the impact of noise and other potential nuisances will need to be demonstrated’. This criterion should also reference taking account of proposed adjacent activities (in addition to existing), where the proposed development could have an adverse effect on or be affected by development coming forward in accordance with Black Country Plan allocations.

Comment

Representation ID: 47035

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

This policy covers development of housing or employment on previously developed land ‘that is not allocated for this use’, so would apply for any planning applications for residential development on existing employment sites. Both the housing and employment shortfalls are significant – circa 37% of the total need (notwithstanding that no evidence has been prepared to indicate whether the proposed component of the housing supply on existing employment sites has been factored into the employment land shortfall).

As set out in the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) there is limited evidence that there is any trend of housing sites coming forward for employment development in the urban area, where as there is evidence that employment sites are sometimes redeveloped for new homes. Examples of this are the Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated supply from this source going forward).

So it is anticipated this policy would mostly be applied to new housing on employment sites. Any further loss of employment land would only exacerbate the Council’s already significant employment land shortfall of 210ha, at a time when the Black Country’s economy is growing, with the employment rate growing faster than the average in England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft BCP).

Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that momentum”. Policy DEL2 should reflect this growth and ensure the employment land shortfall does not unnecessarily increase, it should therefore be seeking to provide greater protection of existing employment sites (no protections are provided in draft policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to the NPPF, which requires a sufficient supply of employment sites to be provided.

This can be done through requiring any application for residential development on an existing employment site to include evidence the site has been marketed for a certain period and that there is no reasonable interest. Indeed this is an approach taken by a number of authorities, including neighbours such as Lichfield District.

Rather than compromising its employment land supply further, the plan should be seeking to maximise locations for development outside of the urban area, and increasing the number of homes allocated on sites currently in the Green Belt. HIMOR’s site at Birmingham Road, Great Barr can assist in ensuring the Black Country’s housing land supply is robust and does not compromise the plan’s ability to meet the area’s employment needs.