Draft Black Country Plan

Object

Representation ID: 44985

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

23.0 Policy CC7 - Renewable and Low Carbon
Energy and BREEAM Standards
23.1 Taylor 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.
23.9 Policy CC7 is considered to be contrary to the Framework [§35] as it is not justified and based on
proportionate evidence. In order to ensure that the Policy is sound Taylor Wimpey considers
that Parts 3, 4 and 5 of Policy CC7 should be deleted.

Object

Representation ID: 44986

Received: 09/03/2022

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: 45874

Received: 09/03/2022

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 Plan period or be identified as Safeguarded Land to meet needs beyond the plan
period.
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 crossboundary
strategic needs.

Comment

Representation ID: 45875

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

24.0 Sub Areas and Site Allocations – Walsall
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.

Comment

Representation ID: 45876

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

6.0 Policy DEL1 - Infrastructure Provision
6.1 Taylor Wimpey objects to Part 3 of Policy DEL1. Whilst the need to bring forward sufficient
infrastructure to support new development is recognised, the proposed approach set out in the
policy is considered to be flawed as it fails to clearly identify what the infrastructure
requirements will be to deliver and fund the allocations.
6.2 The Financial Viability Assessment Report (May 2021) claims that it is a full viability
assessment of the draft policies and proposed site allocations in the emerging Black Country
Plan (BCP) (which will replace the Black Country Core Strategy (BCCS)). It states that the
viability assessment is also sufficiently robust to be able to be used as the basis for a review of
the Community Infrastructure Levy (CIL) within each of the BCA areas with a view to future
alignment (§1.6).
6.3 Part 3 of the policy states that:
“The BCA will set out in Development Plan Documents, Infrastructure Delivery Plans,
Supplementary Planning Documents, and where appropriate, masterplans:
a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure
provision”.
6.4 Taylor Wimpey considers that all of the above information and the associated costs need to be
provided in the BCP at this stage. This is the only way to provide certainty on what is required
and for the requirements to be tested through the viability evidence accompanying the plan to
ensure that development within the plan area will be deliverable, in accordance with the
Framework. It is also noted that a key requirement of the Framework [§11 a] requires that
growth and infrastructure are aligned. As currently drafted the Plan fails to identify the
infrastructure needed to deliver the plan and the funding mechanisms that will deliver them.
This needs to be provided to ensure that the Plan can be found sound as it progresses. We are
concerned that the CIL and any required financial contributions in combination could lead to
developments being unviable. Certainty needs to be provided as to what will be provided
through the Infrastructure Funding Statement so there is no double counting.