Draft Black Country Plan

Comment

Representation ID: 21269

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain
This Policy requires development to deliver the Local Nature Recovery Network Strategy and development is expected to deliver benefits appropriate to the zone they are located. However, the Black Country Strategy is not listed as a key evidence document and although a plan is provided at Appendix 18, it is unclear what development will be required to do in order to meet the requirements of Policy ENV3. Further clarity is sought on the requirements for ‘Core Expansion Zones’.

The Policy requires sites to achieve a biodiversity net gain of 10%. Any proposed uplift requested by the Council needs to accord with national policy unless evidence is provided to justify a different figure. As the Environment Bill has not yet been passed, the Council will need to monitor its position and amend the uplift requirement accordingly.

We consider that Point 7 should refer to “where viable” in regards to providing compensation prior to development.

Comment

Representation ID: 21270

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows
Point 3 of the Policy states that there is a presumption against the removal of trees unless there are sound arboricultural reasons to support their removal. We assume that ‘arboricultural reasons’ will include tree categorisations (Categories A, B, C and U). The NPPF only places a presumption in favour of protecting Ancient Woodland and Veteran Trees (paragraph 180). We therefore consider that this policy should not seek to protect all trees on a site and lower quality trees (Category C and U) should not be afforded the same weight as a veteran or Category A tree. Additionally, we consider that site constraints / layout should also be noted as potential reason for removal subject to replacement planting.

Point 10 should state where possible in regards to designing a scheme to incorporate existing trees already present on site.

Point 11 states that mature / ancient / veteran trees should be retained on site. In order to comply with national policy, we consider that the policy should state “subject to wholly exceptional reasons and a suitable compensation strategy” (NPPF paragraph 180d).

Point 12 states that new developments should use ‘large canopied species’ and street trees will be pursued. The PPG sets out guidance on what should be considered when assessing tree proposals and “the selection of street trees needs to consider which species will best suit the highway environment in the long term, including associated infrastructure and utilities” (Reference ID: 8-029-20190721). We consider that these considerations are important to the delivery of a site and should be added as a consideration within Policy ENV4. Further confirmation is also sought as to whether the cost of the Highways Authority maintaining tree lined streets has been factored into the viability appraisal as from Savills’ experience elsewhere in the country it could be as much as £30,000 per tree.

Point 13 states that 20-30% tree canopy cover will be sought on site. We object to this requirement for a number of reasons. Firstly, it is unclear how canopy cover will be calculated across the site and how this can be deliverable for residential sites which will include private gardens where there is limited / no control on what is planted or removed unless the site is within a Conservation Area. Additionally, we consider that this requirement, in combination with others proposed in the plan (e.g. 10% net gain, national requirement for tree lined streets and 3 to 1 replacement tree planting) will have serious implications on the net developable area of the site and as the BCA cannot currently meet its housing needs, this may result in an even greater shortfall and additional sites will be required to meet this shortfall.

Point 18 states that a ratio of at least 3 to 1 for tree planting will be sought. It is unclear how this requirement will work with Point 13 which seeks to require large canopy trees which you would expect would limit the number of trees that could be delivered across a site. We consider that trees which have been assessed as low quality (Category C and U) should not be afforded the same weight as higher quality trees and similarly, should not be required to be mitigated by a ratio of 3 to 1. Additionally, this is a significant replanting figure and we consider it will have implications of the net developable area of a site which in turn could impact on the potential yield of strategic allocations.

Comment

Representation ID: 21271

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV8 – Open Space, Sport and Recreation
Point 2 of this policy states that development that would increase the overall value of open space will be supported particularly in areas of proven deficiency. NPPF Paragraph 31 states that plans need to be supported by up to date evidence. The BCA need to undertake updated open space assessments to identify potential deficits and confirm the likely public open space requirements which may be required on strategic sites.

Comment

Representation ID: 21272

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV9 – Design Quality
The Policy states that all new residential development should meet Nationally Described Space Standards. The Planning Practice Guidance states that Local Planning Authorities should provide justification for requiring internal space standards “where a need for internal space standards is identified” (Reference ID: 56-020-20150327). We do not consider that the BCP or the Council’s evidence base has justified the requirement for NDSS.

Comment

Representation ID: 21273

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC2 – Energy Infrastructure
This policy requires major development sites to include opportunities for decentralised energy provision site – subject to viability and practicality. Savills has worked on numerous strategic residential schemes where this approach has been suggested at the policy making stage. However, to date we have not found any examples that have been delivered viably by house builders. Further clarity is sought from the Council on the practicality of delivering decentralized energy provision on sites in conjunction with other policy requirements proposed.

Comment

Representation ID: 21274

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC4 – Air Quality
New development is expected to be ‘air quality neutral’ within Policy CC4. Further clarity is sought as to whether this includes mitigation.

Comment

Representation ID: 21275

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC5 – Flood Risk
We support the allocation of Site WSA2. The south western corner of the site is included within Flood Zones 2 and 3. Further technical work will be undertaken in dialogue with Walsall Council to demonstrate that built development can be suitably delivered on the site without increase the risk of flooding elsewhere.

Comment

Representation ID: 21276

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC7 – Renewable and Low
The Policy requires that major developments should achieve a 19% carbon reduction improvement and incorporate renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion. These requirements are considered to be over and above the requirements of PPG which states that Local Plans “can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes” (Reference ID: 6-012-20190315).

The PPG also states that if a Council is “considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development” (Reference ID: 6-009-20150327). The Viability and Delivery Study (May 2021) has assumed £4,615 per unit for this policy. We consider that this is a significant amount of money per dwelling just to meet energy requirements without any of the other requirements being sought in the plan to be taken into account e.g. affordable housing, specialist housing, accessible dwellings, Green – Belt compensation and other S106 contributions and CIL monies that will be sought by the Council and statutory consultees.

In relation to developments providing at least 20% of energy from renewables, consideration should be given to the capital cost and land take involved to achieve this requirement which we do not consider has been undertaken in the Council’s evidence base. Furthermore, it should be noted that it is now the case that sourcing energy from the National Grid can actually, in some cases be more sustainable than small scale renewable energy production as each year they are sourcing more of their energy from renewable sources.
We consider that the policy should be amended to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimize carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage.

Support

Representation ID: 21277

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy WSA2 – Land at Vicarage Road and Coronation Road, High Heath and land at Mob Lane, Pelsall
We support the allocation of our client’s land as part of Site Allocation WSA9. Redrow Homes is a leading housebuilder and pride themselves on building high quality homes through an innovative placemaking framework based on the following key principles:
1. Listen to learn - Connecting with local communities and stakeholders.
2. Keeping it local - Designing sites which sensitively fit into the local area.
3. Easy to get around - Creating new or improved connections between developments and existing communities.
4. Places to go & things to do - Providing opportunities for residents to meet and socialize on site.
5. Nature for people - Improving biodiversity on site for the benefits of wildlife and the physical and mental health of residents.
6. Streets for life - Recognising the essential part streets make to creating safe, attractive and friendly places to live.
7. Homes for all – creating robust, balanced and resilient communities
8. Built to impress – creating inviting, memorable entrances and building beautiful, distinctive homes.

In dialogue with the Council, Redrow Homes is intending to undertake technical work in order to further assess the impact of development on this site and the surrounding area. We welcome further discussion with the Council to discuss their approach to SLINCs and the level of infrastructure which will be required to support the allocation.

Comment

Representation ID: 23287

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

Vision for the Black Country

This Vision is succinct and to the point, which is welcomed. We are, however, concerned that whilst the Vision for the Plan is to create a strong and sustainable Black Country the policies within the Plan will not achieve this objective, as detailed below.

Objectives and Strategic Priorities

We welcome the inclusion of ‘Housing that meets all our needs’ as a Strategic Priority. In order for this priority to be met it is imperative that the housing delivery strategy within the emerging Plan is robust and based on an appropriate evidence base. However, as detailed in our response to Policies CSP1 and HOU1 below, we are concerned that the housing requirement in the Plan is insufficient to meet the Black Country’s growth requirements. In addition, the sources of housing supply that have been identified will not deliver the quantum of housing that is suggested.