Draft Black Country Plan

Object

Representation ID: 23374

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy HOU2
CPRE supports the policy on densities in terms of the Minimum Density Standards. However, we would add a further sentence to the Policy requiring developers to provide evidence that they have sought to maximize the efficient use of land, both in terms of the houses themselves but also in terms of the overall layout of the site. We particularly support an approach which encourages permeable sites, so that walking and cycling in particular are attractive, and do not require lengthy travel round complex road networks.

Object

Representation ID: 23376

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy EMP1
We object to this policy. In line with our comments on CSP1 we would reduce the allocations in Walsall by 15 hectares because of the impact of WAE409 and WAE410 on the Green Belt. Otherwise, we generally support the policy although the level of employment land which will be needed and which will come forward on existing sites needs to be reviewed prior to the Submission Draft publication (the Regulation 19 Consultation). That is because of uncertainties created particularly by the COVID Pandemic in relation to employment land, most particularly offices.

We object to Para 7.10. The level of additional land which needs to be found elsewhere may need to be reduced and further work should be done prior to the Regulation 19 Consultation. The work we commissioned at the time of the first Urban Capacity Study (which seems to remain reasonable) with some small changes of figures in the update, raised the issues of double-counting of employment land need, particularly on proposed sites adjacent to the Black Country in South Staffordshire where the sites would be serving the Black Country but are included as meeting need in South Staffordshire.
Moreover, we have significant concerns about the recent Strategic Employment Site Study which was based on pre-pandemic assumptions.
For both these reasons we consider the figure of 210 hectares of overspill employment need to be likely to be exaggerated.

Support

Representation ID: 23378

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CEN1
CPRE supports the emphasis on Centres and welcomes the inclusion of residential within the CEN1 (7). As well as meeting housing need and protecting the countryside such an approach will help to ensure the vibrancy of those centres. Particular consideration should be given to widening the socio-economic base of the Black Country, and designing schemes which capitalize on the transport links to the centres, such as access to the Chase Line at Walsall and the West Coast Main Line at Wolverhampton.

Object

Representation ID: 23379

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

However, we believe the policy needs to be more dynamic. In some cases, the best option for centres may be to contract in terms of retail to provide a more balanced and sustainable centre. While the impact of the increased contraction of retail and offices post-COVID remains uncertain, work towards the Regulation 19 consultations should directly address this.
Such an assessment may also specifically lead to a review of Policies CEN2-4 in terms of the balance of development and where any retail contraction is most likely to need to be managed and how. We are not commenting at this stage on that balance.

Support

Representation ID: 23383

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy TRAN1
CPRE supports the aspiration to improve transport across the sub-region. Priority for spending should be on public transport schemes.

Comment

Representation ID: 23384

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Expensive road projects, such as The M6 Toll- M54 link road should not be prioritized. We would also strongly oppose any return of the Western Strategic Route (previously called the Western Orbital Route), which was until recently supported by Midlands Connect.

Object

Representation ID: 23386

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy TRAN3
We generally support the aspiration of this policy. However, mitigation should aim not only to address access by sustainable modes but to prioritize it.

Object

Representation ID: 23388

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy TRAN5
We generally support the aspiration of this policy. However, the aim should be to prioritize walking and cycling modes with a specific goal of removing barriers which might prevent use of those modes

Object

Representation ID: 23389

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CC1
The policy on Climate Change is in our view inadequate. The policy deals entirely with how developments will individually be designed with climate change in mind. The policy does not seek to influence where development happens. Climate Change needs to be a core element of the plan including a target for reaching Net-Zero in line with the Councils position terms of the Climate Emergency. It also needs to influence which sites are included in the plan and their transport impact in terms of car-dependency.
Such a policy should be at the core of meeting the Climate Challenge in the Borough. It should also be included as a Core Strategic Policies.

Object

Representation ID: 23391

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

WAM242 (WSA 7) Walsall Next to Arboretum
This site is immediately adjacent to the Walsall Arboretum Extension bounded also by Fernleigh Road the Aldridge Road and the Calderfields Golf Club. As well as intruding into the Green Belt it would be highly visible from the Arboretum, sloping upwards from the Arbore- tum. It is unlikely that planting could mitigate the impact of such a development on the Park. It would significantly increase the developed land around the park impacting on its character in a way that is considered entirely unacceptable. While there is a bus service on the Aldridge Road, the distance to that route would be off- putting making it a largely car-based development. An application to develop this site in 2014 (14/0927/FL) was refused. The reasons for refusal highlight the significant harm to the green belt and the visual impact on the Arboretum. These considerations have not changed. The site is also considered inconsistent with Policy ENV8.
Green Belt assessment in Land Use Consultants’ 2019 Green Belt Study – High