Draft Black Country Plan

Comment

Representation ID: 22567

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

The justification of the policy also appears to be short given the policy itself is so detailed. Paragraph 10.83 states “To ensure that heritage assets make a positive contribution towards the wider economic, social and environmental regeneration of the Black Country, it is important that they are not considered in isolation but are conserved and enhanced within their wider context. A holistic approach to the built and natural environment maximises opportunities to improve the overall image and quality of life in the Black Country by ensuring that historic context informs planning decisions and provides opportunities to link with other environmental infrastructure initiatives.” . We agree that a holistic approach is needed, but it needs to be clearer what this approach includes, as well as actually being explicit in the policy wording itself. This does not mention the need to look at physical site constraints, viability, the public benefits a development could bring or even a reference to developments being of high quality.

Comment

Representation ID: 22568

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Sub-Areas and Site Allocations Part C – Walsall

We note that within Walsall there are a number of proposed housing allocations within the Green Belt with one site located within the same ward as our Site (Policy WSA7 – Calderfields West, Land at Aldridge Road, Walsall). The site has capacity for 592 dwellings, with mixed tenure housing at a density of 35 dwellings/ha and affordable housing provision. This Site is allocated in an area of higher land values and so would be required to provide a higher level of affordable housing provision subject to a viability assessment.

There are no sites allocated within the Town Centre of Walsall which should be the first priority in order to meet the Council’s Development Strategy in Policy CS1 Development Strategy and Policy CEN2 – Tier One: Strategic Centres. This matter has been commented on in our submission on Policy HOU1, and the need to update the AAPs for each Town Centre as part of the consultation process for the DBCP.

We acknowledge that some Green Belt land will need to be released, however the fact that no Town Centre sites which are currently allocated for employment land release in the adopted AAP have been carried forward, demonstrates that the Draft Plan has not fully explored the capacity within the urban areas. A Town Centre development will provide different types of housing a Green Belt allocation will, and they will also have different land values, however no rationale has been provided as to why no allocations in the AAP have been carried forward. Our Site was not put forward during the Call for Site consultation period, however Walsall LPA are now fully aware of our aspiration for the Site and have undergone a round of pre-application advice. Whilst there are a number of issues which needs to be demonstrated as part of any future planning application, it is clear that from the DBCP that the ability for a Site like this is being made purposely difficult by not undertaking a holistic and balanced approach to development and heritage.

Our Site provides a real opportunity to provide a high-quality residential development in a sustainable Town Centre location, meeting the reasonable and justified objectives of the DBCP as a whole. The conclusion of the DBCP that there are no sites in Walsall Town Centre/Strategic Centre which will be able to provide high density residential development is a fundamental flaw, especially when several Green Belt sites are being proposed for release which should be a very last resort. The benefits of the Proposed Development are as follows:

Re-use of a redundant, low quality non-designated employment site (PDL/Brownfield)

The provision of high-quality housing to meet housing needs and delivery

Enhanced green spaces and landscaping to compliment the surrounding environment

Bringing forward a Site which is highlighted in the adopted AAP for employment land release

Provision of obligations to enhance social and physical infrastructure (as appropriated and required)

The opportunity to introduce a high-quality sustainable development within easy walking distance of all public transport modes

Provision of housing which will be able to help further support the viability and vitality of the Town Centre and the overall aspirations of the Council and Black Country.

Comment

Representation ID: 22569

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

There are no sites allocated within the Town Centre of Walsall which should be the first priority in order to meet the Council’s Development Strategy in Policy CS1 Development Strategy and Policy CEN2 – Tier One: Strategic Centres. This matter has been commented on in our submission on Policy HOU1, and the need to update the AAPs for each Town Centre as part of the consultation process for the DBCP.