Draft Black Country Plan

Object

Representation ID: 13843

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Draft Policy HOU3 proposes that on all sites of 100 dwellings or more, at least 5% of plots should be made available for self-build or custom build, where there is currently an identified need. The onus of identifying areas for self and custom build is on the Council, who are required keep a register of those seeking to acquire a plot for self/custom build and give enough development permissions to meet the identified demand 2. The use of land should not be restricted by policy to deliver self and custom build, as this is not a suitable approach to the best use of land. Rather, the provision of self/custom build should only be negotiated on a demand basis as part of a planning application.

2 Under section 1 of the Self Build and Custom Housebuilding Act 2015

Object

Representation ID: 13844

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Biodiversity Net Gain is an important approach to improving the natural environment and ensures the future of local habitats. The emerging Environment Bill states that the relevant percentage for Biodiversity Gain is 10%3.
The Councils should be aware of the cost implications that Biodiversity Net Gain can have on an
otherwise viable scheme. It can result in lower unit numbers or the requirement to acquire additional land for off-setting, which can come at a great cost to a developer. Therefore, the Policy should provide some flexibility. This is particularly in relation to the proposed allocations within the Green Belt, such as WOH264. The draft allocation request a high-density scheme which will make contributions to Green Belt betterment. At this time, the extent of this contribution is unknown.
Therefore, having to meet a requirement of 10% biodiversity net gain on top of this will mean having to compromise on either density or contributions. The Councils need to ensure that the proposed policies and allocations work in conjunction with each other in order to be sound. As presented, the proposed density requirements, biodiversity net gain requirements, and green belt betterment initiative are in conflict with one another when it comes to the proposed allocations.

3 Schedule 14, Part 1, page 227 of the emerging Environment Bill – Schedule 7A, Part 1, paragraph 2(3) to be inserted in the Town & Country Planning Act 1990