Draft Black Country Plan

Support

Representation ID: 21635

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

[General]

In principle, we support the policies contained within the Draft Black Country Plan and the allocations, subject to the changes to the details contained within this letter.

Comment

Representation ID: 21640

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

Draft Policy HOU1: Delivering Sustainable Housing Growth states that,


‘1. Sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020 – 2039. The key sources of housing land supply are summarised in Tables 3 and 4 and illustrated in the Housing Spatial Diagram. Housing allocations for each BCA are set out in the relevant tables of Chapter 13…’

Table 14 – Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) notes that the site (former Sandvik offices at Manor Way in Halesowen) is allocated for housing under Ref. No. DUH066. It is noted that the site has not previously been allocated.

The indicative development capacity is noted as being 60 homes and the indicative density is listed as being 40dph. The gross and net site area is listed as 1.5 hectares. The anticipated delivery timescale to deliver 60 homes is noted as being
2024-2029. The further information states that this is a mixed-use development opportunity.


It should be noted that:
1. The correct gross site area is 2.27 hectares (5.607 acres), not 1.5 hectares as listed in the draft policy wording.
2. The correct net developable area is 1.75 hectares (4.325 acres), not 1.5 hectares as listed in the draft policy wording.

3. Based on a density of 40dph, the site could therefore deliver 70 dwellings, not 60 as listed in the draft policy wording.
4. The draft policy wording notes that the delivery timescales for residential development being 2024-2029.
However, residential development could be delivered at the site much sooner than this. It is considered that residential development could be delivered from 2022-2027.

We respectfully request that changes are made to the draft policy wording with the correct information as set out above.

Comment

Representation ID: 21641

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

[DUH066]

Draft Policy HOU1: Delivering Sustainable Housing Growth states that,

‘1. Sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020 – 2039. The key sources of housing land supply are summarised in Tables 3 and 4 and illustrated in the Housing Spatial Diagram. Housing allocations for each BCA are set out in the relevant tables of Chapter 13…’

Table 14 – Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) notes that the site (former Sandvik offices at Manor Way in Halesowen) is allocated for housing under Ref. No. DUH066. It is noted that the site has not previously been allocated.

The indicative development capacity is noted as being 60 homes and the indicative density is listed as being 40dph. The gross and net site area is listed as 1.5 hectares. The anticipated delivery timescale to deliver 60 homes is noted as being
2024-2029. The further information states that this is a mixed-use development opportunity.


It should be noted that:
1. The correct gross site area is 2.27 hectares (5.607 acres), not 1.5 hectares as listed in the draft policy wording.
2. The correct net developable area is 1.75 hectares (4.325 acres), not 1.5 hectares as listed in the draft policy wording.

3. Based on a density of 40dph, the site could therefore deliver 70 dwellings, not 60 as listed in the draft policy wording.
4. The draft policy wording notes that the delivery timescales for residential development being 2024-2029.
However, residential development could be delivered at the site much sooner than this. It is considered that residential development could be delivered from 2022-2027.

Draft Policy HOU2 – Housing Density, Type, and Accessibility notes that,


1. The density and type of new housing provided on any housing site should be informed by:
a. The need for a range of types and sizes of accommodation to meet identified sub-regional and local needs;
b. The level of accessibility by sustainable transport to residential services, including any improvements to be secured through development, as set out in Table 5;
c. The need to achieve high-quality design and minimise amenity impacts, considering the characteristics
and mix of uses in the area where the proposal is located.
2. Each authority will aim to provide an overall mix of house types over the plan period, tailored to best meet local and sub-regional needs.
3. Developments of ten homes or more should provide a range of house types and sizes that will meet the
accommodation needs of both existing and future residents, in line with the most recently available information.
4. All developments of ten homes or more should achieve the minimum net density set out below, except where this would prejudice historic character and local distinctiveness as defined in Policy ENV5:
a. 100 dwellings per hectare where Table 5 accessibility standards for very high-density housing are met
and the site is located within a Strategic Centre or Town Centre.
b. 45 dwellings per hectare where Table 5 accessibility standards for high density housing are met;
c. 40 dwellings per hectare where Table 5 accessibility standards for moderate density housing are met.
5. Chapter 13 provides details of the appropriate density and, where appropriate, house type mix, to be sought on each housing allocation site, in accordance with the requirements set out in this Policy. Further details of design requirements for housing developments may be set out in Supplementary Planning Documents.


Table 5 – Black Country Housing Accessibility Standards addresses the issue of density based upon the proximity of the site to local services and facilities via sustainable means such as walking, cycling, or bus. The site at Manor Way performs well against the parameters for 40 dwellings per hectare (dph). I deal with each of the parameters in turn, below:

1. Employment – Strategic Centre or other employment area. The nearest Strategic Centre to the site is Brierley Hill which is accessible by public transport in approximately 25 minutes. On this basis, the site would fall under the 40+ dph density category.
2. Health – Primary Care e.g. GP Surgery or Health Centre. The nearest NHS GP surgery to the site is Stourside Medical Practice, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 45+ dph density category.

3. Fresh Food – Centre or food store. The nearest food store to the site is Aldi at Earls Way, which is accessible by public transport in approximately 13 minutes. On this basis, the site would fall under the 40+ dph density category.
4. Education – Primary School (walking distance only). The nearest primary school to the site is Manor Way Primary Academy. This primary school is within 10 minutes walking distance of the site. On this basis, the site would fall under the 40+ dph density category.
5. Education – Secondary School. The nearest secondary school to the site is Windsor High School and Sixth Form, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 40+ dph density category.

Having assessed the site against the parameters outlined in Table 5 – Black Country Housing Accessibility Standards
in the Draft Black Country Plan, we consider that the site is suitable to deliver a housing density between 40-45 dph.

Comment

Representation ID: 21643

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

Draft Policy HOU2 – Housing Density, Type, and Accessibility notes that,


1. The density and type of new housing provided on any housing site should be informed by:
a. The need for a range of types and sizes of accommodation to meet identified sub-regional and local needs;
b. The level of accessibility by sustainable transport to residential services, including any improvements to be secured through development, as set out in Table 5;
c. The need to achieve high-quality design and minimise amenity impacts, considering the characteristics
and mix of uses in the area where the proposal is located.
2. Each authority will aim to provide an overall mix of house types over the plan period, tailored to best meet local and sub-regional needs.
3. Developments of ten homes or more should provide a range of house types and sizes that will meet the
accommodation needs of both existing and future residents, in line with the most recently available information.
4. All developments of ten homes or more should achieve the minimum net density set out below, except where this would prejudice historic character and local distinctiveness as defined in Policy ENV5:
a. 100 dwellings per hectare where Table 5 accessibility standards for very high-density housing are met
and the site is located within a Strategic Centre or Town Centre.
b. 45 dwellings per hectare where Table 5 accessibility standards for high density housing are met;
c. 40 dwellings per hectare where Table 5 accessibility standards for moderate density housing are met.
5. Chapter 13 provides details of the appropriate density and, where appropriate, house type mix, to be sought on each housing allocation site, in accordance with the requirements set out in this Policy. Further details of design requirements for housing developments may be set out in Supplementary Planning Documents.


Table 5 – Black Country Housing Accessibility Standards addresses the issue of density based upon the proximity of the site to local services and facilities via sustainable means such as walking, cycling, or bus. The site at Manor Way performs well against the parameters for 40 dwellings per hectare (dph). I deal with each of the parameters in turn, below:

1. Employment – Strategic Centre or other employment area. The nearest Strategic Centre to the site is Brierley Hill which is accessible by public transport in approximately 25 minutes. On this basis, the site would fall under the 40+ dph density category.
2. Health – Primary Care e.g. GP Surgery or Health Centre. The nearest NHS GP surgery to the site is Stourside Medical Practice, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 45+ dph density category.

3. Fresh Food – Centre or food store. The nearest food store to the site is Aldi at Earls Way, which is accessible by public transport in approximately 13 minutes. On this basis, the site would fall under the 40+ dph density category.
4. Education – Primary School (walking distance only). The nearest primary school to the site is Manor Way Primary Academy. This primary school is within 10 minutes walking distance of the site. On this basis, the site would fall under the 40+ dph density category.
5. Education – Secondary School. The nearest secondary school to the site is Windsor High School and Sixth Form, which is accessible by public transport in approximately 10 minutes. On this basis, the site would fall under the 40+ dph density category.

Having assessed the site against the parameters outlined in Table 5 – Black Country Housing Accessibility Standards
in the Draft Black Country Plan, we consider that the site is suitable to deliver a housing density between 40-45 dph.


We respectfully request that the text in Policy HOU1 - Delivering Sustainable Housing Growth is amended to reflect the correct information in respect of the gross site area, the net site area, the number of units that the site is capable of delivering and anticipated delivery timescales.