Draft Black Country Plan

Support

Representation ID: 22127

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy HOU2 (Housing Density, Type and Accessibility)
In principle, Brockmoor Properties Limited generally support Policy HOU2 (Housing Density, Type and Accessibility), however the draft policy as currently worded could be clearer and more effective for future residential development proposals.

The draft policy promotes flexibility over the plan period for housing types to be assessed on a site-by-site basis which is important in the dynamic housing market and specific locational requirements. Part 3 of this draft policy however, states that the range of house types and sizes should be 'in line with the most recently available information' and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"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, such as:

The Black Country HMA 2021 (or any subsequent revision): or
Detailed Local Housing Market Assessments (where applicable); or
Current and future demographic profiles: or
Locality and ability of the site to accommodate a mix of housing: or
Market signals and local housing market trends."

Additionally, paragraph 6.20 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs for each of the four local authorities, as set out in the HMA", This is not however referred to in the policy wording itself nor does the HMA provide evidence that all four authorities will be undertaking further HMA assessments. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text need to be clear about which evidence is to be used to inform housing mix and the wording suggested above would assist in removing ambiguity in the policy. Paragraph 6.20 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.

Support

Representation ID: 22128

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy CSP1 (Development Strategy)
Brockmoor Properties Limited support the development strategy set out in Policy CSP1, to deliver the identified development requirements sustainably. It is agreed that the majority of development should be delivered within the urban area, and identified Strategic Centres and Core Regeneration Areas. It is important that overall development requirements are clearly set out as a minimum and this wording should be retained and reflected throughout the document.

It is also agreed that new homes should be supported by jobs and local services. The Brockmoor Foundry sites are located within well-established neighbourhoods and well-connected to employment areas, local services and the Strategic Centre of Brierley Hill

Comment

Representation ID: 22129

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy CSP2 (The Strategic Centres and Core Regeneration Areas)
The Brockmoor Foundry sites are located within a Core Regeneration Area, identified as the primary focus for new development, regeneration and infrastructure investment. As set out in the response to policy CSP1, it is agreed that Core Regeneration Areas should be a focus for sustainable growth.

Part 4)d) should refer to 'at least' 11,208 homes to account for flexibility over the plan period and remain consistent with NPPF paragraph 61. These additional words should be added to the policy.

Part 4 should also recognise that within Core Regeneration Areas, housing development should come forward as a mix of sized sites to ensure consistent delivery over the plan period, which will come together to achieve the strategy, including allocated and windfall sites.

Support

Representation ID: 22130

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy HOU1 (Delivering Sustainable Housing Growth)
Brockmoor Properties Limited support the policy requiring 'at least' 47,837 net new homes over the plan period. The policy however, should also recognise the role of Core Regeneration Areas as locations appropriate for housing development as set out in Policy CSP2.

Support

Representation ID: 22133

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

DUH016 Brockmoor Foundry North and DUH223 Brockmoor Foundry South
CBRE Ltd submitted the two sites as potential sites for residential development to the Black Country Call for Sites consultation in 2020. Both sites are now proposed as separate draft allocations for residential development in the Draft Black Country Plan, namely site references DUH016 and DUH223. These representations relate to both of the proposed draft housing allocations.

The owner of the site is fully supportive of the draft allocations for residential development as set out in the submissions to the Call for Sites in August 2020 given that Brockmoor Foundry is due to relocate in the next 2-3 years. Market advice obtained from CBRE identifies that owing to the site's incremental development and extension of existing facilities, the current industrial premises have been purpose-built to meet the needs of the occupier and are in poor condition. The incremental nature of the site's development limits the potential for alternative industrial occupiers to make use of the site, as the buildings and adjoining servicing and car parking areas do not meet the needs of modern business operations. The Promotion Document submitted with the Call for Sites submissions in August 2020 provides further detail of the opportunity.

Brockmoor Properties Limited support the principle of the proposals for the allocation of Land to the north and south of Leys Lane, Brockmoor within their ownership as draft housing allocations DUH223 and DUH016.

In terms of delivery, Table 14 estimates the delivery of development for both draft allocations in the period 2035-
2039. As set out earlier in this letter, Brockmoor Foundry's intention is to relocate off the site in the next 2-3 years at which time the site will become available for residential development. It is therefore requested that 'anticipated delivery' section within the table is updated for allocations DUH223 and DUH016 to show delivery from earlier in the plan period (i.e. 2024-2029).

Comment

Representation ID: 22134

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Table 14 of the Draft Black Country Plan sets out housing site capacities for all of the proposed allocations. It is not clear however how the gross and net areas have been calculated, and therefore how the housing site capacity has been calculated. Clarification is sought on how the gross to net calculations for the allocations have been arrived at.

Support

Representation ID: 22135

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

DUH223 Brockmoor Foundry North
The northern parcel of the Brockmoor Foundry sites is approximately 1.9ha and is bound by the Stourbridge canal to the north and west, industrial land to the east, and residential development to the south. The Premier Industrial Estate is located to the north of the canal. Access to the site is currently located on its southern boundary, with a secondary access to the east. This site has a draft allocation under reference DUH223. A site ownership plan is enclosed with this submission.

Currently, both draft allocations comprise industrial units, and associated car parking and loading areas, which have been purpose built for the occupier and evolved over time.

The owner of the site is fully supportive of the draft allocations for residential development as set out in the submissions to the Call for Sites in August 2020 given that Brockmoor Foundry is due to relocate in the next 2-3 years. Market advice obtained from CBRE identifies that owing to the site's incremental development and extension of existing facilities, the current industrial premises have been purpose-built to meet the needs of the occupier and are in poor condition. The incremental nature of the site's development limits the potential for alternative industrial occupiers to make use of the site, as the buildings and adjoining servicing and car parking areas do not meet the needs of modern business operations. The Promotion Document submitted with the Call for Sites submissions in August 2020 provides further detail of the opportunity.

The northern site (draft allocation reference DUH223) is stated within Table 14 of the Draft Black Country Plan to have capacity for 60 homes at a density of 40 dwellings per hectare (dph). The Call for Sites submission and associated Illustrative Masterplan - Dwg Ref C4746_SK001 submitted to the Black Country Authorities in 2020 however demonstrates that the site has capacity for 75-80 dwellings which includes areas for potential attenuation ponds, open space and a play area. We therefore consider that additional residential development can be easily accommodated on site DUH223 and as such we request that the allocation is increased to at least 80 dwellings.

Support

Representation ID: 22136

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

DUH016 Brockmoor Foundry South
The southern parcel of the Brockmoor Foundry sites is approximately 2ha and located south of Leys Road, Brierley Hill. The site is bound by commercial businesses to the north, an access road to the North east (and the Stourbridge Canal beyond), and residential estates to the east, south and west. Access to the site is gained from the northern boundary. This site has a current adopted allocation (H11B.18) within the Dudley Development Strategy (2017). Within the emerging Black Country Plan the site has a draft allocation under reference DUH016. A site ownership plan is enclosed with this submission.

The southern site (draft allocation reference DUH016) is stated within Table 14 of the Draft Black Country Plan to have capacity for 78 homes at 40dph. The Call for Sites submission demonstrated that the site owned by Brockmoor Properties Limited, of which the allocation is part, is capable of accommodating up to 85 dwellings. We therefore request that the allocation is increased to at least 85 dwellings plus any additional able to be accommodated on the western part of the allocation owned by another landowner.