Draft Black Country Plan

Object

Representation ID: 44951

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows

20.1 Taylor Wimpey recognises the important contribution that trees make to the character and quality of urban environments and mitigating climate change. However, this needs to be balanced with the need to make efficient use of land as advocated by the Framework [§124].

20.2 Part 1 of the policy requires development adjacent to ancient woodland to provide an appropriate landscaping buffer, with a minimum depth of 15m and a preferred depth of 50m. However, there is no clear justification for the preferred 50m buffer in the BCP and Taylor Wimpey considers that this preferred depth should be deleted from the policy.

20.3 Part 13 of the Policy ENV4 states that new developments should make a minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site. We note that this requirement is based upon recommendations prepared by the Woodland Trust33 rather than being informed by Government policy and guidance so is not based around any national policy requirement. We consider that this minimum contribution and recommended contribution are completely unrealistic.

20.4 It would be necessary to ensure that this level of planting would not cause unacceptable harm in terms of shading and the need to distance dwellings accordingly would have a resultant impact upon the areas within site where homes can be located. As a result, we consider that the policy requirement would prejudice the ability for developers to make the efficient use of land as required by the Framework [§124]. It also fails to take into account other policy requirements which need to be considered in the development of sites and have a further impact upon density, such as the provision of open space and highways infrastructure. Taylor Wimpey therefore considers that Part 13 of the policy should be deleted.

20.5 Part 14 of the policy states that new houses and other buildings must be carefully designed and located to prevent an incompatible degree of shade being cast by both existing and new trees that might result in future pressure for them to be removed. Taylor Wimpey agrees with this approach and considers that the requirements of Part 13 of the policy are completely at odds with this aim as the canopy cover sought would undoubtedly lead to pressure for trees to be removed in the future.

20.6 Part 15 of the policy suggests that the positioning of trees in relation to streets and buildings should not worsen air quality for people using and living in them by allowing street level ventilation to occur. It is not clear how this could be accurately assessed or achieved in practice and we do not consider that Part 15 would be effective. On this basis we consider that Part 15 should be deleted.

20.7 Part 18 of the policy requires trees proposed for removal during development to be replaced at a ratio of at least three for one. There is no clear justification in the Policy or explanatory text for the additional replacement trees. Taylor Wimpey is concerned that this requirement would place unnecessary burdens upon developers and could limit the development potential of residential sites if land is lost to facilitate the additional planting of trees and hedgerows.

20.8 As the wording of the policy states “a ratio of at least 3 for one” this indicates that the Council could seek a higher provision than the three to one ratio. The justification text to the policy notes that there will be circumstances where the ratio of replacement planting will be greater than this – especially in cases where significant / mature trees contributing to the visual and ecological amenity of an area and its character are to be removed.


20.9 As this will vary on a site by site basis, it is not possible to ascertain the impact the Policy would have upon the development potential and viability of sites.

20.10 The justification text to the policy states that where a development site cannot accommodate additional planting, replacement trees will be expected to be planted in an appropriate off-site location. It is that this approach would be practical and whether it would actually be implementable in practice as there may be no additional land available within the developers ownership to provide this off-site mitigation.

20.11 The financial and practical burdens placed on developers by the requirements of Part 18 could impact on the development potential of sites and therefore cannot be seen to be positively prepared. In addition, the impacts of this policy requirement do not appear to have been fully considered in the BCP Viability Assessment. The replacement of trees on a ratio of one for one
is therefore considered to be appropriate and the policy should be amended to reflect this.

Comment

Representation ID: 44952

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy ENV9 - Design Quality

Part 2

21.1 Part 2 of the policy identifies a number of matters that development proposals must address.
However, these matters are very high level such as addressing “the townscapes and landscapes of the Black Country”. As with Policy CSP4, Part 2 of the policy would benefit from further clarification either within the policy text itself or the justification text and it may be worthwhile for a design guide to be prepared as part of the BCP which reflects local character and design preferences and would provide more specific guidance to developers on design requirements. The policy requirements should be set out in sufficient detail to determine a planning application without relying on, other criteria or guidelines set out in a separate SPD.

21.2 It is essential that this is prepared as part of the BCP so that any cost implications can be properly viability tested in conjunction with other policy requirements.

Object

Representation ID: 44953

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Part 3

21.3 Part 3 states that new residential development will be required to meet water efficiency standards of 110 litres per person per day. If the BCA wish to adopt the optional standard for water efficiency of 110 litres per person per day then they need to justify doing so by applying the criteria set out in the Practice Guidance34. The Water Cycle Study (2020) identifies the Severn Trent Water and South Staffordshire Water supply regions as areas of only moderate water stress. A clear local need has not been demonstrated.

Object

Representation ID: 44954

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Part 4

21.5 Taylor Wimpey objects to Part 4 of Policy ENV9 which requires all new residential development to meet the Nationally Described Space Standards [NDSS].

21.6 Taylor Wimpey notes that the Government’s decision to make these standards optional suggests that they do not expect all properties to be built in accordance with them. If the standards are to be applied, the Practice Guidance35 sets out a clear set of criteria local planning authorities should address in order to justify them, these being:

• need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed.
• viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where
a space standard is to be adopted.

• timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

21.7 With regard these criteria, we firstly note that no need evidence is provided to justify the policy requirement. The justification text to the policy suggests that the standard is generally met in most new build housing across the Black Country but no further information on this matter is provided and it does not appear to have been covered in the evidence base, so there is nothing to ratify this. With regard to viability, the BCP Viability Study states that the NDSS has been applied within the appraisals as the minimum standard. However, it is not clear whether the impact upon affordability has been considered.

21.8 The BCA’s policy approach should recognise that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Well-designed dwellings below NDSS can provide a good, functional home.


21.10 If the Council is able to provide sufficient evidence to justify the policy, Taylor Wimpey considers that a transitional period should be applied. It is not clear whether a large proportion of new dwellings currently meet the standard, and the cost of such provision may not therefore be factored into current and past land acquisitions. A reasonable transitional period following adoption of a new policy would help enable developers to factor the cost of space standards into
future land acquisitions.

Object

Representation ID: 44955

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CC2 - Energy Infrastructure

22.1 Taylor Wimpey recognises the importance of mitigating and adapting to climate change but objects to Policy CC2 for the following reasons.

22.2 Parts 1 to 3 of Policy CC2 relate to decentralised energy networks. The requirements of the policy are vague and the provision of such networks on small to medium scale sites (the policy identifies a minimum of 10 homes or more) is not likely to be practical given size constraints and the viability implications of such provision. The reliance on connection to off-site sources is not practical as this may require connections through land outside of the ownership of the applicant and over which they have no control. Off-site sources which have not yet become operational would be particularly problematic as it would be difficult to guarantee that they would be available to serve the site when required or that they would be delivered and available for connection at all.

22.3 At present, the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP). Meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. For the foreseeable future, it will remain uneconomic for most heat networks to install low-carbon technologies.

22.4 In addition, the information provided in the BCP Viability Study suggests that the provision of or connection to decentralised energy networks has not been factored into the viability assessment work. The viability implications of such provision have not therefore been adequately assessed.

22.5 We therefore consider that the policy requirements are not justified and suggest that the BCP Authorities consider whether Part 1 to 3 of the policy are necessary. The costs of the provision of or connection to decentralised energy networks will need to be properly considered in the Council’s viability evidence if this is to be pursued.

Object

Representation ID: 44956

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CC7 - Renewable and Low Carbon
Energy and BREEAM Standards

23.1Taylor Wimpey objects Policy CC7 which requires that major developments creating ten or more homes must:
a achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than that is required under new national planning policy or building regulations;
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.

23.2 It also requires assessment of the use of district heat and / or decentralised energy networks.

23.3 Taylor Wimpey recognises the benefits of reducing energy use and promoting renewable technologies and meets Part L on all sites and regularly seeks efficiencies above the recommended standard. However, we consider that no clear evidence has been provided in the Draft BCP to confirm why a 19% reduction has been identified and why it is justified.

23.4 In addition, the policy relates to a proposed reduction in Building Regulation targets. The control of emissions is controlled through Building Regulations and the application of a Local Plan policy which seeks a reduction below these targets is not appropriate. In order to ensure consistency with the Building Regulations, it is considered that any reduction in emissions should be informed by up to date Building Regulations targets rather than through the application of a local plan policy.

23.5 Taylor Wimpey also notes that no clear justification or evidence is provided for the 20% renewable or low carbon sources requirement in Part 3(b) of the policy. It appears that the BCP authorities have selected an arbitrary figure for this requirement which is based on policy aspiration only and is not supported by any evidence.

23.6 The justification text to the policy indicates that the 20% requirement should be applied to the residual energy demand of the development, after application of the 19% carbon reduction improvement required by policy CC7. The costs to developers of meeting these requirements would therefore be significant .

23.7 The Viability Study indicates that cost applied to meet these standards is £4,615 per unit which is the cost of Option 2 Part L Interim Uplift 2021. The cost of Future Homes Standard 2025 will be much higher and further extra-over costs should be included. We also note that the BCP Viability Study excludes any additional costs associated with compulsory connections to heat networks.

23.8 Taylor Wimpey considers that the BCA should comply with the Government’s intention of achieving net zero carbon development through the Building Regulations. The proposed policy approach is unnecessary because of the higher levels of energy efficiency standards for new homes proposed in the 2021 Part L uplift and the Future Homes Standard 2025.

Support

Representation ID: 44957

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy WSA.2 - Land at Vicarage Road and Coronation Road, High Heath and land at Mob Lane, Pelsall

24.1 Taylor Wimpey fully supports the allocation of the Mob Lane site as part of Strategic Allocation WSA.2 (Land at Vicarage Road and Coronation Road, High Heath and land at Mob Lane, Pelsall).

24.2 The estimated capacity of the Strategic Allocation is 713 homes. Mixed tenure housing is considered to be suitable with higher densities of at least 35dph and affordable housing provision. The Strategic Allocation is identified as a Neighbourhood Growth Area in the BCP spatial strategy.

24.3 Policy WSA.2 sets out the following design principles:
• Deliver appropriate local facilities to support the new residents and to enhance the sustainability of the existing area, including a new primary school and local health centre.
• Investigation of and detailed proposals for the remediation of contaminated land.
• A transport strategy that includes improvements to Mob Lane and Green Lane.
• A site-wide Sustainable Drainage Strategy, to ensure that drainage requirements can be met on site and that is designed to deliver landscape, biodiversity and amenity benefits.
• A strategy for landscape and habitat creation that provides enhancement, retention and / or mitigation for established trees and hedges, to ensure there are no significant adverse impacts on visual amenity and character or on protected animal species.
• The site is in a MSA and requires prior extraction where practical and environmentally feasible. Where practical and environmentally feasible prior extraction for bedrock and superficial sand and gravel, shall take place.

24.4 The Mob Lane site itself is identified as Allocation WAH240 in Table 31 of the Draft Plan (Walsall Sites Allocated for Housing by Black Country Plan (Policy HOU1). WAH240 has an indicative capacity of 209 new homes at 35dph. The anticipated delivery timescale of site WAH240 is between 2027-2031. The remainder of the Strategic Allocation is identified as Allocation WAH238 (Land at Vicarage Road / Coronation Road, High Heath) which has an indicative capacity of 504 new homes at 35dph. The anticipated delivery timescale of site WAH238 is 400 by 2039.

24.5 Walsall Council has indicated that the full extent of the technical issues on the strategic allocation are still being investigated and we are keen to work with the Council and provide input into these matters where required.

24.6 In this regard, the transport impacts of the Mob Lane site have been assessed on behalf of Taylor Wimpey and there are no technical highways constraints preventing development of the site (please see the Transport Note submitted alongside these representations). The Site can be accessed from the existing road network, with a single vehicular access proposed within the existing constraints of the highway boundary and land ownership on Mob Lane. This access point represents a suitable location, and limits impact on existing residents and established hedgerows. Further work is to be undertaken to investigate the cumulative impact of the whole of Strategic Allocation WSA.2.

24.7 There is also potential to provide a pedestrian and cyclist only access onto Mob Lane at the southwestern corner of the Site, allowing for a continuous footway on the northern side of Mob Lane. This will maximise the permeability of the Site for active travel users, ensuring full integration with the existing active travel environment.

24.8 Taylor Wimpey supports the delivery of education and healthcare facilities on the Strategic Allocation in principle. However, as set out in our response to Policies HW2 and HOU5, we consider that the evidence required to justify the provision of these facilities needs to be produced as part of the preparation of the BCP in order that the requirement for theses facilities is transparent and the implications of this provision can be fully assessed.

24.9 The draft policy does not indicate where the new primary school and health centre are envisaged on the site and we understand that the BCP authorities have yet to determine where these facilities would go. Clarity should be provided on this matter in time for the next stage of consultation on the BCP in order to assist in the delivery of the site.

24.10 In terms of the delivery timescales identified for Mob Lane, we would emphasise that site is capable of delivery in advance of 2027. It is deliverable and is capable of coming forward for development shortly after the anticipated adoption of the BCP (i.e. 2024) and the BCP should be updated to reflect this position. The site is capable of early delivery as it is not reliant on the wider Strategic Allocation for access or any other technical reasons.

24.11 Whilst not mentioned specifically in the policy, the draft proposals map identifies parts of the
Mob Lane site as a Site of Local Importance for Nature Conservation [SLINC]. The Birmingham
& Black Country Local Sites Assessment Report identifies the site as part of a wider area
referred to as ‘Land at Vicarage Road / Coronation Road, High Heath’. It provides the following
assessment:

“When assess against the Birmingham and Black Country Local Sites Criteria, Land at Vicarage Road / Coronation Road, High Heath scores mostly low to medium and medium for the ecological criteria. This ecological value is attributed specifically to the intact native hedgerows, woodland plantation and semi-improved neutral grassland.

In addition, the site provides an important ecological corridor through the site to the nearby protected sites. Therefore, these specified habitats above, meet the threshold for selection as a Site of Local Importance for Nature Conservation (SLINC).

The arable farmland, defunct hedgerows and improved grassland fields holds some ecological value for protected species such as ground nesting birds and local bat population, however, are limited in species and structural diversity, as such when assessed against the Birmingham & Black Country Local Sites Selection criteria, however, it fails to meet the criteria of Local Wildlife Site”.

24.12 We would request further clarification on any resultant implications for development in this part of the site in order to inform future development proposals.

24.13 For the reasons set out in the Green Belt Technical Report submitted with these representations we consider that the assessment of the site in the Council’s Green Belt evidence is not accurate as it has not been considered in isolation. We consider that the site does in fact make a lower contribution to the Green Belt purposes and provide more detail to justify this position in the Green Belt Technical Report.

24.14 The suitability of the site for Green Belt release has been established through its identification as a draft allocation and we consider that the evidence provided in our Technical Report further supports the allocation of the site.

Object

Representation ID: 44958

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Chester Road, Streetly

24.15 Taylor Wimpey notes that Land at Chester Road Streetly has not been allocated for residential development and objects to the Draft BCP on this basis.

24.16 For the reasons set out in these representations, it essential that further housing sites are allocated in the BCP. This will involve the release of additional Green Belt land as insufficient alternative land is available to meet housing needs.

24.17 A Delivery Statement, which sets out the reasons why the Chester Road site is suitable for allocation, has been submitted to the Council previously and also submitted alongside these representations. We have also provided a description of the site and the reasons why it is suitable for allocation below.

Site Description

24.18 The 25.6 ha site comprises agricultural fields which fall from south-east to north-west. The land is currently in use for arable and pasture. Overhead transmission and high voltage electricity cables cross the western part of the site in a north-south direction.

24.19 The site is dominated by arable fields delineated by hedgerows, with mature standard trees, areas of semi-improved grassland and a small copse of semi-natural broad-leaved woodland present within the site. Towers Covert ancient woodland site lies directly adjacent to the western boundary of the site.

24.20 The site is contained within defined boundaries. It is bounded to the:
• North predominantly by a hedgerow that demarks the edge of the site with agricultural fields beyond. To the far north east of the boundary is Water Works Farm which has been redeveloped for residential development.
• East by Chester Road and the residential properties fronting onto Chester Road and Leacliffe Way.
• South east by Chesterwood and the residential properties which front onto Chesterwood beyond which lies Little Hardwick Road. The south western boundary is bounded by Little Hardwick Road and the residential properties of Little Hardwick Road.
• West by Bourne Vale Road, areas of mature tree groups and hedgerows and the properties along Bourne Vale Road. Further to the north west of the site is Tower’s Covert, an area of ancient deciduous woodland.

Suitability of Chester Road for Green Belt Release
24.1 In the Green Belt Technical Report submitted with these representations we set out the reasons why land at Chester Road, Streetly is suitable for release from the Green Belt and why the findings of the BCGBS do not accurately assess its contribution.

24.2 In particular, we note that the site has not been considered in isolation in the BCP Green Belt Assessment and this has a resultant impact upon the ratings identified in the Assessment. In the Green Belt Technical Report, we have carried out our own assessment of the site in isolation as this is considered to be the most appropriate and transparent method of assessing its suitability for Green Belt release.

24.3 As detailed in our Technical Report, land at Chester Road, Streetly does not make a significant contribution to the purposes of the Green Belt and is suitable for release.


Deliverability of Chester Road

24.4 The Chester Road site is entirely deliverable and would make a valuable contribution to meeting future housing needs. The proposed allocation and development of the site:

• Will make a valuable contribution towards meeting the quantitative and qualitative needs of the community for market and affordable housing. It could deliver up to approximately 505 high quality family houses.
• Is being promoted by a national housebuilder, Taylor Wimpey who can deliver the proposed residential scheme. Taylor Wimpey is seeking to develop the site as soon as it is allocated.
• Is not subject to any known constraints that would impede deliverability. There are no legal impediments, need for land in third party ownership. The site is therefore is fully deliverable
• Streetly is identified as a vibrant Local Centre. Therefore, the provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider Black Country is important.
• The land has strong boundaries and it is considered that its allocation and future development is unlikely to have a detrimental impact on the form and character of the settlement.
• Taylor Wimpey has undertaken an evaluation of the technical and environmental constraints that could prevent or restrict the development of the land. This work has identified that there is no overriding constraint that will impede its delivery.
• Taylor Wimpey confirms that the development of the site is economically viable and is confident that residential development can be achieved within the first five years of the plan period.

Sustainability of Chester Road

24.5 Streetly is identified as a Local Centre in the emerging BCP. Therefore, the provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider Black Country is important. The development of the site would contribute to retention of a good level of access to local convenience and comparison retail, services, community facilities and other amenities.

24.6 The site is sustainably located being situated the edge of the settlement in close proximity to a number of services. Public transport services operate to the south of the site and are within walking distance.

24.7 It will provide a range of open market and affordable housing in various types, sizes and tenures to help meet local needs.

24.8 The site is currently in agricultural use and has limited ecological value. Suitable ecological mitigation will be incorporated within the site. Where possible existing hedgerows and trees will be retained and incorporated within the proposed development.

Masterplan for Chester Road

24.9 The vision for the site is to create an attractive housing development with distinctive local character offering a choice of high-quality new homes to meet local needs. The proposed masterplan is designed to:
• Create a development that complements the character of the surrounding area through appropriate development densities, street scenes, housing types and retaining the existing landscape structure.
• Create a Public Open Space network that improves pedestrian and cycle connectivity from the site and Bourne Vale to the centre of Streetly via attractive routes set within green corridors.
• Provide a local park that is easily accessible via the public open space network. This park would provide opportunities for informal recreation, children’s play, habitat creation and improved surface water drainage through the integration of SuDS attenuation basins, swales and wetland areas. As well as a Locally Equipped Area for Play, there is the potential to accommodate a junior sports pitch and a series of Local Area’s for Play throughout the development to ensure residents have access to a variety of informal recreation and play opportunities.
• Create a high-quality residential scheme within the site with a coherent landscape structure, which conserves the natural assets present on the site, as well as improving the local recreational and children’s play opportunities and connectivity within Streetly.

BCP Site Assessment Report

24.10 The Chester Road site has been considered in the Council’s Site Assessment Report [Site Reference SA-0037-WAL]. The Assessment Report concludes the following on the site:

“The site is part of a larger area which is characterised by its openness and helps to define
Streetly's semirural character. Although it is recognised that wider visual amenity impacts
are limited due to the development to the South and East, this land forms part of the transition between the urban and the rural so any development here would erode that having a significant visual amenity impact. Employment uses would have more significant character impacts”.

24.11 We do not agree with this assessment. Any site on the edge of the urban area forms part of the transition between urban and rural and the site would not have a significant visual amenity impact. It is well enclosed by existing residential uses to the east and south, with the western boundary enclosed by the Bourne Vale residential development, which obscures views from the west. The northern boundary is currently defined by an existing hedgerow and individual trees, and a new housing development, introducing urban features in this location. Suitable landscape planting to the boundaries of the site, including enhancing the northern boundary with new woodland planting, would ensure that the visual impact of the development is minimised.

24.12 These built and natural features serve to separate the site from the wider open countryside and the site would essentially provide an ‘infill’ plot between the existing built development to the east, south and west (and partially to the north).

24.13 We therefore consider that the findings in the assessment are inaccurate and for the reasons we have identified in these representations, the site is suitable for removal from the Green Belt and allocation for residential development.

Alternative Masterplan

24.14 Taylor Wimpey have worked collaboratively with St Philips (adjacent landowner to the north) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached at Appendix 6). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the Draft BCP at present and would allow for the inclusion of significant community infrastructure.

Conclusions
24.15 It is essential that further housing sites are allocated in the BCP in order to meet housing needs.
This will involve the release of additional Green Belt land as insufficient alternative land is available to meet housing needs.

24.16 In summary, land at Chester Road, Streetly is considered suitable for allocation for residential development because:
• It does not make a significant contribution to the purposes of the Green Belt and is suitable for release.
• There is no overriding constraint that will impede the delivery of the site.
• It would provide a local park that is easily accessible via the public open space network
• It is entirely deliverable and would make a valuable contribution to meeting future housing needs, including affordable housing, within the first five years of the plan period

Object

Representation ID: 44961

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Clent View Road, Stourbridge

24.17 Land at Clent View Road, Stourbridge has not been allocated for residential development and
Taylor Wimpey objects to the Draft BCP on this basis.

24.18 Insufficient land is available within the Black Country and South Staffordshire on non-Green Belt land to meet the unmet housing needs of present and future generations and the release of Green Belt land is required. For the reasons identified in these representations, it is essential that further housing sites are allocated in the BCP. This will involve the release of additional Green Belt land. Exceptional circumstances therefore exist to remove land from the Green Belt.

24.19 A Delivery Statement has been prepared to support the allocation of the site and is submitted alongside these representations. We have also provided a brief description of the site and the reasons why it is considered suitable for allocation below.

24.20 The site will deliver up to 400 high quality homes suitable to the needs of the local community with a varied mix of house type, tenure and size, including affordable housing.

Clent View Road Site Description

24.21 The site is located on the western edge of Stourbridge and is bordered by Clent View Road to the east. The site is located primarily within the local authority boundary of South Staffordshire District Council [SSDC] but is also partially within the authority boundary of Dudley Metropolitan Borough Council [DMBC].

24.22 The Site comprises 19.6ha of improved grassland (16.5ha in South Staffordshire and 3.1ha in
Dudley) currently used as equestrian paddocks.

24.23 The site is situated approximately 2.5km south-west of the centre of Stourbridge and immediately abuts the established residential suburb of Stourbridge to the east, which is located within DMBC.

24.24 The Site is contained within well defined existing boundaries. It is bounded to the north by a public bridleway beyond which is dense woodland and agricultural land. To the east there is a permissive footpath named ‘Roman Road’, Clent View Road and the urban area of Stourbridge. This footpath is separated from the Site and Clent View Road by hedgerows. To the south there is a Public Right of Way and a line of mature trees, beyond which lies agricultural land; and to the south-west is a heavily wooded area (Bunkers Hill Wood). To the west, a line of trees extending from the northern boundary of the site to Frog Hall Cottages, bound the site towards the centre west. The site is further bounded to the west by a heavily wooded area, and a further line of trees which joins the wooded area to the south-west of the site, beyond which lies agricultural land.

Suitability of Clent View Road for Green Belt Release

24.25 We note that the site has not been considered in isolation in the BCGBS and this has a resultant impact upon the ratings identified in the Assessment.

24.26 In the Green Belt Technical Report submitted with these representations we have carried out our own assessment of the site in isolation as this is considered to be the most appropriate and transparent method of assessing its suitability for Green Belt release. The Technical Report sets out the reasons why land at Clent View Road, Stourbridge is suitable for release from the Green Belt.

Deliverability of Clent View Road

24.27 The site is being promoted by a national housebuilder, Taylor Wimpey, who can deliver the proposed residential scheme. Taylor Wimpey is seeking to commence development as soon as the Site is allocated.

24.28 It could deliver a up to 400 high quality family houses and will make a valuable contribution towards meeting the quantitative and qualitative needs of the community for market and affordable housing.

24.29 The site is not subject to any known constraints that would impede deliverability. There are no legal impediments, or any need for land in third party ownership.

24.30 Taylor Wimpey has reviewed the economic viability of the proposals in terms of the land value, attractiveness of the locality, level of potential market demand and projected rate of sales; as well as the cost factors associated with the Site including site preparation costs and site constraints. The site is economically viable and Taylor Wimpey is confident that residential development can be achieved within the first five years of the plan period

24.31 The land also benefits from clear, well-defined boundaries and it is considered that its allocation and future development will not have a detrimental impact on the form and character of the settlement. The allocation and development of the Site provides an opportunity to create a long term defensible boundary to Stourbridge and the provision of housing development for South Staffordshire and Dudley.

24.32 For the above reasons the site is fully deliverable.

Sustainability of Clent View Road

24.33 Stourbridge is identified within the adopted BCJCS and the emerging BCP as a Town Centre, which provides for convenience shopping as well local comparison shopping opportunities, local services and local leisure facilities. It is a key area in the settlement hierarchy below Strategic Centres. The provision of housing to maintain Stourbridge’s role in the settlement hierarchy of Dudley and the wider Black Country is therefore of importance. The delivery of high-quality housing in the locality will contribute to ensuring that population growth is focused in an area close to employment opportunities, which can be easily accessed via a sustainable transport network

24.34 The Site is located to the west of the residential area of Stourbridge in close proximity to a number of services and facilities in Stourbridge. Schools, shops, residential communities, and leisure facilities are all accessible by a choice of means of transport, including walking and cycling.

24.35 Stourbridge Town Centre is approximately 30 minutes walking distance from the northwest of the site where access to Stourbridge Town railway station is also available. Stourbridge Junction rail station is located approximately 3km from the proposed site and provides regular services to nearby and well-connected stations including Birmingham New Street, Kidderminster, Solihull, Worcester Shrub Hill, and Stratford-Upon-Avon.

24.36 The site is situated is situated 0.4km from Shenstone Avenue bus stop, which provides regular services to the centre of Stourbridge and Dudley.

24.37 The site is therefore located in an accessible location and would contribute to supporting existing services and facilities in the area including Stourbridge Town Centre.

24.38 The development of the site would provide a suitable range of dwellings in various types, sizes and tenures, including affordable housing, to meet the needs of the local population, and establish a mixed and sustainable community.

24.39 As detailed in the Delivery Statement for the site, the proposal will bring a number of economic and fiscal benefits in terms of job creation, additional monies to the Local Authority and increased expenditure in the economy.

24.40 No environmental constraints have been identified that would inhibit the future allocation and development of the site. It is currently in agricultural use and is considered to be of limited ecological value. The proposals will provide numerous compensatory improvements, and seek to retain, enhance or mitigate the existing ecological and environmental features of value on the Site.

24.41 Existing hedgerows and trees will be retained and incorporated where possible within the proposed development supplemented with further woodland planting to help screen the site and integrate it with surrounding assets such as Iverley Heath and Bunkers Hill Woods. The site extent allows the opportunity to provide wide-ranging enhancements to demonstrate a
‘biodiversity net gain’.

Masterplan for Clent View Road

24.42 The proposed masterplan is designed to:
• Create a development which is specific to Stourbridge by sensitively responding to the unique attributes and characteristics of the Site and its wider context.
• To provide safe and convenient access for both new and existing residents to local amenities and facilities through the delivery of public open space and pedestrian connections to Clent View Road, Roman Road, the public footpath adjacent to the Site leading to Iverley Heath and Bunkers Woods, and the adjacent public bridleway ‘Westwood Avenue’ to allow for opportunities to access nearby recreation assets, including Little Iverley Covert woodland.
• To provide a central area of greenspace to create a sense of place and provide recreational opportunities within the site through the provision of facilities such as LEAPs and MUGAs, and the use of sustainable links through the site incorporating existing assets such as the
Roman Road.
• To provide green gateways into the site along the main accesses, with the opportunity to create tree lined streets to contribute to the character and quality of the development and help mitigate and adapt to climate change.
• To provide a development of suitable scale, form and appearance which meets both the needs of the local community in a sustainable way, whilst also being sensitive to the character of the surrounding townscape and landscape setting.
• To retain, enhance and embrace the Site’s natural assets through the inclusion of naturalised green infrastructure including wetland attenuation basins, managed wild grasslands and the planting of native shrubs/trees to contribute to a well-designed and beautiful place in accordance with the Framework.

Alternative Masterplan

24.43 Taylor Wimpey is currently investigating the potential to include additional areas of land within the proposed masterplan for Clent View Road. The Alternative Masterplan includes these additional areas. As these areas would effectively provide development in areas surrounded by the land being promoted, or between this land and the existing urban area, they are not considered to perform any significant additional Green Belt role and are therefore suitable for release. The Alternative Masterplan is included in the Delivery Statement for Clent View Road which has been submitted alongside these representations.

24.44 These additional pieces of land would provide approximately 150 additional dwellings within a network of high-quality greens, routes and open spaces which would integrate with and connect to the wider development area. Existing tree belts and hedgerows to boundaries would be retained and enhanced to further improve containment and mitigate visual impact and would provide a well-connected and comprehensive greenspace network as part of the overall scheme. The additional open space brought forward in these areas would provide further recreational and placemaking opportunities within the site.

24.45 The Alternative Masterplan also identifies a ‘Potential Expansion Site’ to the west of the masterplanned area which measures 24ha in area. The potential to acquire and develop this land is also being investigated by Taylor Wimpey.

24.46 This land is well contained by existing permanent defensible boundaries which are capable of preventing urban sprawl and preventing encroachment into the wider countryside. An access road lined by established boundary hedgerows runs to the north and a thick belt of woodland planting at Bunkers Hill Woods to the west and south. The land would be contained by development on the Clent View Road site to the east. The future development of the site would not result in merging of settlements. It would retain a significant gap of approximately 2.3km between Stourbridge and Kinver and a gap of approximately 4.9km between Stourbridge and Kidderminster. This land does not affect the setting and special character of a historic town and therefore does not contravene this purpose. The release of this land from the Green Belt would not prevent the recycling of derelict land and other urban land within South Staffordshire or Dudley, as insufficient previously developed land and land in the urban area is available to meet future housing requirements.

24.47 It is considered that this land would form a logical future phase of development once the masterplanned area is completed and could potentially come forward for release towards the end of the BCP Site Assessment Report

24.48 The Clent View Road site is identified as Site Reference SA-0105-DUD in the Council’s Site
Assessment Report. The Assessment Report concludes the following on the site:

“The western boundary of the submitted site follows the borough boundary with South Staffordshire at the northern end and then expands to form a cross boundary ‘call for sites’ submission. The land within Dudley MBC is long and narrow.

The Green Belt and Landscape Sensitivity Assessment considers the landscape to have a
‘Moderate’ overall sensitivity to residential development, as the majority of the criteria score moderate and no criteria overrides that judgement. It rates harm to the Green Belt from release as ‘Moderate to High’ noting that the sub-parcel makes a strong contribution to preventing sprawl of the West Midlands conurbation to the east of the suburbs of Stourbridge, and to preventing encroachment on the countryside, and a moderate contribution to maintaining the separation of Stourbridge and Kidderminster (via intervening settlements). It goes on to say that the area, to the south of Westwood Avenue has an urban edge that is bounded by the well-treed hedgerow along Roman Road. Indeed, Sandy Lane acts as a strong defensible boundary to the Green Belt at this point.

If development were to be allowed on this site it would effectively allow the conurbation to expand into open countryside. Furthermore, the borough boundary cuts though the centre of the grazed fields and the consequent new boundary to the built-up area would be very weak. This makes this site a poor choice for the receipt of new development.

There is a high-pressure gas pipeline running north south along the Roman Road, the zone of influence of which effectively covers the majority of the site. This creates a physical constraint”.

24.49 For the reasons set out in the Green Belt Technical Report submitted with these representations, we consider that the BCGBS does not accurately assess the contribution of the site to the Green Belt and its contribution is lower than recorded.

24.50 Whilst the allocation of the site would involve the expansion of the conurbation into the open countryside, this would be the case for any site on the edge of the existing conurbation (many of which have been allocated in the draft BCP) so we do not consider that this is a valid reason to discount the site.

24.51 The assessment that the borough boundary cuts though the centre of the grazed fields and the consequent new boundary to the built-up area would be very weak, is also flawed as the site would not be delivered on this basis. The site is being promoted as a cross boundary site which extends into South Staffordshire and would be defined by well established boundaries, including existing field boundaries. As a result, the new boundary to the built up area would be strong.

24.52 Taylor Wimpey is aware of the gas pipeline running along Roman Road and the scheme would be designed to ensure that it would not impact upon the zone of influence. The pipeline does not therefore create a physical constraint which would preclude the development of the site.

24.53 For the above reasons, the conclusions in the BCP Site Assessment Report are considered to be unfounded and the site is suitable for removal from the Green Belt and allocation for residential development.

Conclusions

24.54 Land at Clent View Road, Stourbridge is considered suitable for allocation for residential development because:

• It is entirely deliverable and would make a valuable contribution to meeting future housing needs, including affordable housing within the first five years of the plan period.
• There is no overriding constraint that will impede the delivery of the site.
• It does not make a significant contribution to the purposes of the Green Belt and is suitable for release.
• The site should be identified as it will meet the needs of both South Staffordshire and
Dudley where there are clear issues with regards to the duty to cooperate and meeting cross- boundary strategic needs.

Comment

Representation ID: 44962

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

INTRODUCTION
This report has been prepared by Lichfields on behalf of Taylor Wimpey UK Limited LTaylor
Wimpeyl. It forms Taylor Wimpey's response to the Draft Black Country plan IBCPI
(Regulation 18) consultation and is submitted for consideration in the formulation of the Plan.
These representations are submitted in the context Of Taylor Wimpey's land interests on the
following sites:
1 Land at Mob Lane, Pelsall (LPA: Walsall)
2 Land at Chester Road, Streetly (LPA: Wal sall)
3 Land at Cle nt View Road, Stourbridge (LPA: Dudley/ South Staffordshire)
Taylor Wimpey is seeking the alloeation Of all the sites for residential development in the BCE
Plans showing the locations of these sites are attached at Appendices 1 to 3.
Land at Mob Lane, Pelsall has been identified as part of a larger Strategic Allocation in the Draft
BCP (Policy WSA.2 - Land at Vicarage Road and Coronation Road, High Heath and land at Mob
Lane, Pelsall).
The Chester Road and Clent View Road sites have not been Identified as draft allocations and
are currently identified as Green Belt. Taylor Wimpey in these æpresentations sets out the
reasons why these two sites should also be identified for residential development to meet the
BCA housing needs.
Taylor Wimpey is part of a wider consortium of house builders being represented by Turley.
Turley has been instructed by the consortium to take stock of the position relating to housing
need and land supply across the Greater Birmingham and Black Country Housing Market Area
IGBBCHMAI in order to quantify the true scale of unmet need to 2031, and beyond, mindful
that emerging local plans are seeking to deliver growth into the late 2030s or, in several cases,
beyond 2040. A copy of the Turley report' prepared on behalf of the consortium is attached at
Appendix 4.
The following documents also accompany these representations:
2
3
4
5
6
7
Bruton Knowles Viability Review — Appendix 5
Chester Road Streetly. Alternative Masterplan — Appendix 6
Green Belt Technical Report (supplied as a separate document)
Mob Lane, pelsall Delivery Statement (supplied as a separate document)
Mob Lane, pelsall Transport Note (supplied as a separate document)
Chester Road, Streetly Delivery Statement (supplied as a separate document)
Clent View Road, Stourbridge Delivery Statement (supplied as a separate document)
Structure
This report provides detailed representations in relation to the following matters relating to the
Draft BCP:
1 Policy CSPI - Developm ent Stratew
2 Policy CSP3 - Towns and Neighbourhood Areas and the Green Belt
3
4
5
6
7
8
9
10
12
13
14
15
16
17
18
19
20
21
22
23
24
Policy CSP4 - Achieving well-designed places
Policy GBI - The Black Country Green Belt
Policy DELI
Infrastructure Provision
policy DEL3
promotion Of Fibre to the premises and 5G Networks
policy
- Health and Wellbeing
policy HW2
Healthcare Infrastructure
policy HW3
Health Impact Assessments
policy CENI
The Black Country Centres
policy HOUI
- Delivering Sustainable Housing Growth
policy HOU2
- Housing Density, Type and Accessibility
policy HOU3
Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build
Housing
Policy HOU5
Education Facilities
Policy TRAN8 - Planning for Low Emission Vehicles
Policy ENVI - Nature Conservation
Policy ENV2 - Development Affecting Special Areas of Conservation (SACs)
Policy ENV3 - Nature Recovery Network and Biodiversity Net Gain
Policy ENV4 — Provision, retention and protection of twes, woodlands and hedgerows
Policy ENV9 Design Qual ity
Policy CC2 - Energy Infrastructure
Policy CC7 - Renewable and Low Carbon Enerv and BREFAM Standards
Sub Areas and Site Allocations — Dudley
Sub Areas and Site Allocations - Walsall
The National planning policy Framework (the Framework) was revised on 20th July 2021. As
the BCP and associated documents were approved for consultation before this date we note that
they do not take account of the revised Framework and this will be considered as part of the next
Stage Of plan preparation. Any references to the Framework in these representations relate to
the July 2021 Framework unless otherwise stated.