Draft Black Country Plan

Object

Representation ID: 21247

Received: 11/10/2021

Respondent: Newlands Developments

Draft Policy TRAN7 (Parking Management) identifies that the Black Country Authorities will ensure a consistent approach to maximum parking standards is enforced in new developments, as set out in supplementary planning documents.

Whilst it is considered important to promote sustainable transport methods as part of new developments, the provision of parking is critical to the success of logistics schemes. Indeed, where a logistics development is in operation for 24-hours a day, it can mean a shift change takes place overnight where public transport is either limited or not available.

a. achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than this that is required under new national planning policy or building regulations; and, in addition
b. incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion.

We would therefore recommend that draft Policy TRAN7 is amended to confirm that maximum parking standards would not relate to logistics developments.

Support

Representation ID: 21248

Received: 11/10/2021

Respondent: Newlands Developments

Draft Policy TRAN5 (Creating Coherent Networks for Cycling and Walking) also encourages new developments to create an environment that encourages sustainable travel via safe and direct links that connect to existing walking and cycling networks, and good walking and cycling links to public transport nodes and interchanges. We are generally supportive of this policy as it accords with the requirements of Paragraph 110 of the NPPF, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users.

Comment

Representation ID: 21249

Received: 11/10/2021

Respondent: Newlands Developments

Biodiversity Net Gain
NPPF Paragraph 32 advises that Local Plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Moreover, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

As such, it is considered that draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) is not consistent with national policy as it requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The NPPF places no requirement on development proposals to deliver a notional target of a 10% net gain. It is therefore considered that draft Policy ENV3 should be amended to simply require all development proposals to achieve a biodiversity net gain.

Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. Part 1(d) of Draft Policy ENV9 is of particular relevance to employment developments as it encourages developments to consider crime prevention measures and Secured by Design Principles. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards.

Object

Representation ID: 21250

Received: 11/10/2021

Respondent: Newlands Developments

Biodiversity Net Gain
NPPF Paragraph 32 advises that Local Plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Moreover, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

As such, it is considered that draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) is not consistent with national policy as it requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The NPPF places no requirement on development proposals to deliver a notional target of a 10% net gain. It is therefore considered that draft Policy ENV3 should be amended to simply require all development proposals to achieve a biodiversity net gain.

Support

Representation ID: 21251

Received: 11/10/2021

Respondent: Newlands Developments

Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. Part 1(d) of Draft Policy ENV9 is of particular relevance to employment developments as it encourages developments to consider crime prevention measures and Secured by Design Principles. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards.

Support

Representation ID: 21252

Received: 11/10/2021

Respondent: Newlands Developments

Policy CC2 (Energy Infrastructure) identifies that development proposals would need to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Such an approach is supported, given that the policy suitably reflects that opportunities for decentralised energy provision may not always be appropriate or viable.

Support

Representation ID: 21253

Received: 11/10/2021

Respondent: Newlands Developments

Policy CC7 (Renewable and Low Carbon Energy and BREEAM Standards) identifies that major development must:

With regard to BREEAM Standards, Part 6 of Draft Policy CC7 requires all new non-residential developments greater than 5,000 sqm gross to meet BREEAM Excellent Standards, unless it can be demonstrated that achievement of the standard would make the proposal unviable, through submission of an independently assessed financial viability appraisal. Draft Policy CC7 is therefore generally supported as it notes that achieving BREEAM excellent may not always be a viable option.

Support

Representation ID: 21254

Received: 11/10/2021

Respondent: Newlands Developments

Sub-areas and Site Allocations (Section 13)
The strategy for Walsall is set out at Paragraph C.8 in Chapter 13 of the draft Black Country Plan, which is as follows:

“In the future, Walsall will be a more confident place, with renewed investment in key infrastructure and key centres, greater opportunities for work and leisure and an affordable, accessible housing stock.”

We are supportive of this strategy and consider the delivery of the Site will help this to be achieved, particularly as the development will comprise an employment development which will generate direct and indirect jobs in construction and direct local employment opportunities when operational. The development will be sustainable in accordance with the strategy proposed for Walsall.

Walsall to Wolverhampton Core Growth Area
At Paragraph C.26 of Chapter 13, the Draft Plan defines the Walsall to Wolverhampton Core Regeneration Area as being located around the road, rail and waterway corridor, with the Black Country Route linked to M6 Junction 10, the re-opened railway stations at Darlaston and Willenhall, and the Wyrley and Essington Canal which provides a pedestrian, cycle and leisure route from Birchills, through Walsall Strategic Centre, Phoenix 10 and Darlaston to Moxley.

Paragraph C.26 goes on to state:

“Much regeneration has already taken place in this area, and many new homes and jobs are expected to be delivered in the future at key locations such as Phoenix 10, Bentley Lane, Moxley Tip and in Willenhall Town Centre. The Core Regeneration Area will continue to be the focus of public sector investment to regenerate brownfield sites” [Our emphasis].

We strongly support the strategy for the Core Regeneration Area and consider that land south of Bentley Lane can contribute to the aims for this area. As noted in Table 36 (Walsall Sites Allocated for Employment by Black Country Plan Policy EMP1), the Site (BCP Site Ref. WAE404 ‘Lynx / Beatwaste Site, Bentley Lane) has the capacity to deliver up to 11.22 hectares of employment land. In addition, Table 36 anticipates that such development can be delivered within the Plan period (i.e. by 2039).

Notwithstanding the above, we note that the Site is referred to as ‘Lynx / Beatwaste Site, Bentley Lane’ within Table 36. However, the Site Assessment Form refers to the Site as ‘Land to the South of Bentley Lane, Willenhall, Walsall.’ We can confirm that the Site should simply be referred to as ‘Land south of Bentley Lane’, to avoid confusion.