Draft Black Country Plan

Object

Representation ID: 43907

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

1. Introduction
1.1 These representations are submitted to the draft Black Country Plan (BCP) (July 2021)
consultation on behalf of Barratt West Midlands (referred to as ‘Barratt’ in these representations).
1.2 Barratt is actively promoting land at Pennwood, Wolverhampton (site ref: 10521 / SA-
0011-WOL) (‘the site’ or ‘land at Pennwood’) as a sustainable and deliverable opportunity for new market and affordable homes, with associated infrastructure on the edge of Wolverhampton. The entire site is in single ownership.
1.3 Barratt also have aspirations to meet the local communities’ ambitions through the
delivery of a landscape-led scheme providing significant open space and a new woodland park which would protect and enhance the existing environment and biodiversity, we discuss this further at Section 2.
1.4 Barratt is the nation’s largest housebuilder with a focus on acquiring land, obtaining
planning permission and building the highest quality homes in places people aspire to live. Their geographical reach and maximisation of development opportunities across the West Midlands is supported by experts in land, design and construction. Barratt contributed to the delivery of 17,856 new homes in 2019 across the UK in the private and affordable housing sectors.
Barratt has an exceptional track record of promoting sites through the Local Plan preparation process and working in close partnership with local planning authorities, landowners and local communities to deliver well designed and successful new residential development.
1.5 The site is available now and is developable. An application will be submitted following
the plans adoption, should the site be allocated for new homes, with development commencing immediately following planning permission.
1.6 The representations are structured as follows:
· Section 2: Provides a summary of the Site and the opportunity it presents.
· Section 3: Sets out our response to the draft BCP consultation.
· Section 4: Provides commentary on the site assessment.
· Section 5: Provides a conclusion to these representations. Appendices to these representations are summarised at Section 2.

2. The opportunity
Historic site promotion
2.1 We first made representations promoting the site (including a call for sites submission)
to the scope, issues and options consultation in September 2017. This was accompanied by an earlier Vision Document. This Vision Document, along with its masterplan, has now been superseded.
2.2 Since then we have made a further call for sites submission in September 2020, which
included the updated Turley Vision Document (enclosed at Appendix 3). Responding to the Council’s evidence base, as well as our site specific evidence base, the updated Vision Document proposes a reduced development area compared with the original Vision Document. As set out in our Vision Document, the design of our proposes has evolved as:
· Less land needs to be kept open around the southern perimeter of the Grade II listed Park Hall Hotel (as demonstrated by the Turley Initial Heritage Appraisal) (Appendix 6);
· A number of nature conservation designations, including Sites of Important Nature Conservation (SINC) and Sites of Local Important Nature Conservation (SLINC) are recommended within the site, which generally follow existing hedgerows and an area of scrubland along the northern boundary of the site; and
· A link between Park Coppice and Ashen Coppice could deliver significant ecological benefits, perform as part of the green infrastructure network, and provide landscape and visual screening. It could also provide a more defensible Green Belt boundary along the southern edge of the development area.
Current proposals
2.3 The proposals for land at Pennwood comprise the delivery of up to 600 new market
and affordable homes and approximately 18.7 ha of public open space, including a new woodland park. The potential development parcels have been located towards the north and eastern part of site, adjacent to the urban area including existing residential dwellings. The main vehicular access points are located via Jeremy Road to the north and Wolverhampton Road to the east.
2.4 The new woodland park is located to the south, which will create a natural buffer,
providing a strong and defensible boundary between the new development and the cornfields to the south. In addition to the new woodland park, pockets of open space are proposed at the site including play facilities and opportunities for further biodiversity enhancements. The park would be accessible to the public via new pedestrian and cycle links.

Benefits of our proposals
2.5 The proposals for land at Pennwood provide a number of benefits including:
· Delivery of up to 600 new homes to meet local needs and significantly help meet the wider housing needs within the Black County;
· Provision of a range of housing including a mix of sizes, types and tenures including affordable housing;
· Provision of new facilities, including public open space, landscape corridors, a new woodland park and buffer (representing over 50% of the site area) providing exceptional opportunities for recreation and biodiversity;
· Creation of new footpaths and cycle routes (circa 3,625m) which will enhance connectivity for both new and existing residents, promoting community interaction, social inclusion and equality; and
· Provision of new homes within walking and cycling distance of a range of employment opportunities.
Site specific evidence base
2.6 Throughout these representations we will make reference to a series of site specific
evidence base documents which have been prepared by Barratt’s consultant to support the promotion of the site and inform the preparation of the illustrative masterplan and vision document. The site specific evidence base is summarised below:
Report Consultant Appendix No.
Botanical Survey Tyler Grange 1
Report (July 2019)
Ecological Briefing Tyler Grange 2
Note (July 2019)
Vision Document Turley 3
(August 2020)
Site specific Green Belt Turley 4
Review (September
2021)
Transport Technical DTA 5
Note (September
2021)
Initial Heritage Turley 6
Appraisal (October
2021)
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Report Consultant Appendix No.

Technical Review of Housing Need and Supply in the Black Country (October 2021) Turley 7

3. Response to draft BCP consultation
3.1 We respond to each section and policy relevant to land at Pennwood, Wolverhampton,
below.
Vision for the Black Country and objectives
3.2 Barratt supports the overall Vision for the Black Country and its central aim of
“...creating a prosperous, stronger and sustainable Black Country”, in particular it needs to be flexible to allow the authorities to respond to future challenges. In achieving this the strategic priorities however need some further consideration.
3.3 As we explore further in these representations, the remaining unmet need for the
Black Country will be a significant issue. Strategic Priority 3 under the ‘housing that meets all our needs’ objective should therefore place greater emphasis on this matter and that all options will be explored to ensure the Black Country’s needs are met in full. We discuss the policies relevant to the strategic priority further below in terms of draft policies HOU1 and HOU2.
3.4 We note that Strategic Priority 7 under the ‘enabling a strong, stable and inclusive
economy’ objective seeks to provide a balanced portfolio of employment sites, as well to protect and enhance existing sustainable employment areas. It must be reflected on as to whether the plan’s current strategy of proposing to allocate active employment sites for new homes and a lack of policy protection for employment sites being lost to other uses would deliver this strategic priority, which we discuss further below in terms of draft policies HOU1 and DEL2.
3.5 We welcome Strategic Priority 15 under the ‘meeting our resource and infrastructure
needs’ objective as it seeks to ensure the necessary infrastructure is in place to support its existing and future growth. Barratt’s site is capable of delivering significant public open space (including a new woodland park, and new pedestrian and cycle routes) to meet the needs of existing and new residents.
Spatial strategy
3.6 Paragraph 3.2 confirms that the spatial strategy is structured around four key policies
within the draft BCP:
· CSP1 (development strategy)
· CSP2 (strategic centres and core regeneration areas)
· CSP3 (towns and neighbourhood areas and the Green Belt)
· CSP4 (achieving well-designed places)
3.7 We comment on each policy in turn below.

Policy CSP1 (development strategy)
3.8 As currently drafted the housing (47,837 homes) and employment (355ha) supplies are
identified in the emerging policy (we are of the view that the actual housing supply is much lower – we discuss this further in response to draft policy HOU1).
3.9 The actual policy should be clearer that this is the area’s proposed supply only and that
the actual overall needs for the Black Country are 76,076 homes and 565ha of employment land. The policy can then be clear on how much of the need is proposed to be exported to other authorities. The policy should also be clearer on the extent of the supply proposed on land to be released from the Green Belt.
3.10 Policy CSP1 provides the overarching strategy which is essentially made up of two elements:
· Delivering the majority of growth in the existing Urban Area / Growth Network (86% in total); and
· Delivering a limited number of Neighbourhood Growth Areas (NGA) outside of Growth Network (14%). The policy defines NGAs as “areas in highly sustainable locations on the edge of the Urban Area”. The supporting text to the policy provides further explanation – they are ‘large sites, or clusters of smaller sites, which have been released from the Green Belt in sustainable locations on the edge of the urban area”.
3.11 Given the existing Urban Area / Growth Network reflects the sites identified in the Councils’ Urban Capacity Study, it is presumed the above represents a hierarchical approach, with the existing Urban Area / Growth Network favoured over the NGAs. This point should be further clarified as part of the justification text to draft policy CSP1 to ensure it meets NPPF paragraph 20.
3.12 Paragraph 3.7 of the policy supporting text indicates the strategy has been developed “through a comprehensive assessment of a range of alternative options”. The preferred strategy reflects Spatial Option J, considered in the Sustainability Assessment (July 2021) (SA). To ensure the plan satisfies NPPF paragraph 35 further evidence will be necessary to provide clarity as to whether this optioneering exercise reflects the Councils’ assessment of reasonable alternatives, or whether this assessment is provided elsewhere in the SA.
3.13 The Black Country’s needs are based on a plan period of 2020-2039. NPPF paragraph 22 states that strategic policies should look ahead over a minimum 15 year period from adoption. To achieve this the plan would have to be adopted by 31 March 2024. The current schedule for the BCP is that the plan will be adopted in April 2024, on this basis the plan would not meet the requirements of NPPF paragraph 22. The plan period should therefore be extended to reflect this.
Policy CSP3 (Towns and Neighbourhood Areas and the Green Belt)
3.14 Policy CSP3 1 recognises the importance of providing a mix of good quality residential areas where people choose to live and recognising the inherent sustainability of directing new development through the allocation of a network of new NGAs. This is why NGAs are crucial to the success of this plan – as traditionally certain types and

sizes of housing are more readily delivered on urban brownfield sites due to factors such as viability and density. NGAs offer the opportunity to deliver a wider range of housing types to meet the area’s identified needs.
3.15 Barratt support that comprehensive masterplanning will be important to the success of the NGA’s. Paragraph 3.48 states that NGA’s should be master-planned together regardless of ownership. Land at Pennwood is under single ownership, enabling Barratt to take a streamlined master-planning process. In addition, it is stated that NGA’s generate need for new infrastructure, this is supported by Barratt as this provides an opportunity to deliver infrastructure for existing and new homes.
3.16 The allocation of NGAs allows for greater public access to the countryside which urban sites are not able to, so it is right parts e) and g) of the draft policy require integrated and where possible continuous networks of green infrastructure and easy access to the countryside. This would not be possible without NGAs and the need for this infrastructure is a central theme to the illustrative masterplan for land at Pennwood. As we will go onto demonstrate, land at Pennwood is a potential NGA offering significant benefits which can assist the Black Country authorities with reducing their unmet need further.
Policy CSP4 (Achieving well-designed places)
3.17 The NPPF was updated in July 2021 with a much greater emphasis placed on the delivery of high quality design. This saw significant amendments to chapter 12 of the NPPF and was supplemented by the publication of the National Design Guide (2021) and National Model Design Code (Parts 1 and 2) (2021). Together these documents confirm the Government’s intent to guide the delivery of well-designed places and demonstrating what ‘good design’ means in practice.
3.18 The NPPF now establishes a need for local planning authorities to ensure that visual tools such as design codes and guides are used to inform development proposals to provide maximum clarity about design expectations at an early stage to assist in providing a framework for creating high-quality places, with a consistent and high-quality standard of design to inform development proposals.
3.19 Barratt therefore consider that Policy CSP4 should be updated to reflect this change in
national guidance and instead of establishing prescriptive design criteria within a strategic policy, there is instead an opportunity for the principles identified within draft policy CSP4 to inform the future development of Local Design Codes for the Black Country.
3.20 In any event, throughout the masterplanning undertaken to date, Barratt has sought to ensure that the illustrative masterplan is grounded through high quality urban design and placemaking as evidenced through the Vision Document enclosed at Appendix 3.
3.21 The nature and distinctive qualities of the local landscape surrounding land at
Pennwood has been taken into account when developing the siting, scale, and design of new development. In addition, the masterplan has been informed by additional
technical work on heritage and ecology allowing the proposed layout to better

accommodate landscape and visual screening but also deliver significant ecological benefits through the green infrastructure network.
Green Belt
Policy GB1 (The Black Country Green Belt)
3.22 As identified at paragraphs 3.14-17 and 3.75, the draft BCP has identified exceptional circumstances for the removal of land from the Black Country Green Belt. The Council summarise their exceptional circumstances case further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).
3.23 Following national planning policy, the authorities are therefore justified in proposing
to amend the Green Belt boundary through the associated policies map. Indeed further land will be necessary to be released from the Green Belt if the Councils are to deliver the scale of supply proposed in the plan, let alone reducing the overall shortfall being exported to neighbouring authorities (as we discuss further in response to draft policy HOU1 below).
3.24 The policy however could do with refinement. As currently drafted part 2 applies to sites to be removed from the Green Belt (so at the point the plan is adopted will no longer be in the Green Belt), and the balance of the policy is to be applied to land remaining in the Green Belt. The policy would benefit from part 2 being deleted to provide greater clarity. Part 2)a. (the need for a defensible Green Belt boundary) is covered in draft policy CSP3, it may be that policy should also include reference to part 2)b. and the need for compensatory measures. Another solution could be making Part2)b. part of any site specific allocation for sites removed from the Green Belt.
3.25 In evolving the next version of the plan the Councils should provide further information
in a single document (perhaps as a topic paper) summarising the Green Belt compensatory measures on a Black Country wide basis to ensure there is clarity on how NPPF paragraph 142 is satisfied.
Infrastructure
3.26 At the current stage of draft BCP preparation it is acknowledged that the evidence base is still being prepared, and this is particularly true with regards to infrastructure.
3.27 Paragraph 4.9 states “Parts of the Black Country’s existing highway infrastructure, and the motorway network, suffer from congestion”. Development should therefore be located at the most sustainable and accessible locations. Land at Pennwood benefits from being located near to a variety of existing amenities and facilities that are within walking or cycling distance of the proposed development. Figure 2 ‘Facilities Plan’ of the accompanying Vision Document demonstrates this.
3.28 Paragraph 4.11 emphasises the need for infrastructure investment in order to support future development. Barratt are proposing to create extensive green infrastructure (over 50% of the total site area) within their site that is multi-functional through the delivery of biodiversity, amenity, aesthetic and drainage benefits. In addition, where development is planned between new areas of public open space and new woodland park, new footpaths, cycle routes and landscape corridors are proposed.

Policy DEL1 (infrastructure provision)
3.29 The Councils need to be cautious with their approach to viability given the scale of brownfield land in the proposed supply. The draft BCP is highly dependent upon development in the existing built-up area (40,117 dwellings) and brownfield sites (81%). The Black Country’s Viability & Delivery Study (September 2021) confirms that 65% of urban typologies tested are marginally viable (27%) or unviable (38%). The Councils must grapple with this matter as part of the plan and in identifying its proposed supply.
Policy DEL2 (balanced between employment land and housing)
3.30 This policy covers development of housing or employment on previously developed land ‘that is not allocated for this uses’, so would apply for any planning applications for residential development on existing employment sites. Both the housing and employment shortfalls are significant – circa 37% of the total need (notwithstanding that no evidence has been prepared to indicate whether the proposed component of the housing supply on existing employment sites has been factored into the employment land shortfall).
3.31 As set out in the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) there is limited evidence that there is any trend of housing sites coming forward for employment development in the urban area, where as there is evidence that employment sites are sometimes redeveloped for new homes. Examples of this are the Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated supply from this source going forward).
3.32 So it is anticipated this policy would mostly be applied to new housing on employment sites. Any further loss of employment land would only exacerbate the Council’s already significant employment land shortfall of 210ha, at a time when the Black Country’s economy is growing, with the employment rate growing faster than the average in England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft BCP).
3.33 Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that momentum”. Policy DEL2 should reflect this growth and ensure the employment land shortfall does not unnecessarily increase, it should therefore be seeking to provide greater protection of existing employment sites (no protections are provided in draft policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to the NPPF, which requires a sufficient supply of employment sites to be provided.
3.34 This can be done through requiring any application for residential development on an existing employment site to include evidence the site has been marketed for a certain period and that there is no reasonable interest. This is an approach taken by a number of authorities, including neighbours such as Lichfield District.
3.35 Rather than compromising its employment land supply further, the plan should be seeking to maximise locations for development outside of the urban area, and increasing the number of homes allocated on sites currently in the Green Belt. Land at Pennwood can assist in ensuring the Black Country’s housing land supply is robust (we set out the site’s benefits at Section 2 and discuss the Councils’ assessment of the site

further at Section 4) and does not compromise the plan’s ability to meet the area’s employment needs.
Health and wellbeing
3.36 Barratt is supportive of the Local Plan’s aspirations for health and wellbeing and
identifying opportunities through new development to support the creation of strong, vibrant and healthy communities. Health and wellbeing are core to the social objective of sustainable development as defined by the NPPF (paragraph 8).
3.37 At the heart of this is locating new development in the right locations and ensuring it delivers sufficient infrastructure to make better places for living. Land at Pennwood provides an opportunity to accommodate a sustainable community that integrates well with existing residents and provides access to open space including the new woodland park and play facilities within a safe and inclusive environment.
Policy HW1 (health and wellbeing)
3.38 As discussed in response to Policy DEL1, it is important that policies within the BCP do compromise the viability and deliverability of new developments, particularly in respect of the need for and delivery of onsite infrastructure. To ensure HW1 takes a consistent approach to viability with other policies in the plan, part j. of the policy would benefit from cross referencing draft policy DEL1 which sets out the tests for viability.
3.39 The proposals would create 153 jobs during construction, including 11 apprenticeships for every year of construction. Beyond this 215 indirect jobs would be created during construction.
Housing delivery
Policy HOU1 (delivering sustainable housing growth)
3.40 Firstly, similarly to our response to policy CSP1 above, the policy should be clear that
47,837 new homes is the proposed supply only and that the full need for the Black Country is 76,076 new homes. To ensure it is not ambiguous the policy should also clearly state the exact scale of the remaining unmet need so it is clear for any authority working with the Black Country on assisting with its unmet needs.
3.41 In terms of the overall need of 76,076 homes (4,004 dwellings per annum), the plan must be clear that this is a minimum. As set out at page 31 of Appendix 7, this represents a relatively small number of new homes compared to the size of the Black Country’s existing housing stock (501,464 homes as of 20201) and would only require growth at a rate which almost half of the thirty West Midlands region’s authorities have achieved since 2006 (0.7% per annum2).
3.42 Indeed the proposed housing need, which is based on the area’s standard method
need only, represents a benchmark of the minimum need for housing only. For
1 MHCLG (2020) Table 125: dwelling stock estimates by local authority district
2 Based on the outcome of the standard method as of August 2021, estimated for every local authority by Turley and aggregated to the West Midlands (21,829dpa) and England (297,619dpa)

instance, it does not account for changing economic circumstances, such as the Councils’ assurances that there will be sufficient labour to meet the economic growth ambitions of the area (draft policy EMP1). This could be justification for increasing the Black Country’s housing needs.
3.43 This demonstrates that there is no evidence for lowering the Black Country’s total
housing needs, indeed it should be increased if it is to ensure sufficient labour is provided to meet the sub-region’s economic growth ambitions.
Table 3 (Black Country housing land supply and indicative phasing 2020-39)
3.44 The proposed supply of 47,837 new homes between 2020 and 2039 is the equivalent of 2,518 dwellings per annum. At demonstrated at page 9 of Appendix 7, this is less than what the authorities have delivered per annum for the last six years (2,863 dwellings per annum). Whilst the supply within the urban area may be more exhausted going forward than in those previous six years, this level of delivery demonstrates the scale of demand in the Black Country and that the market is capable of absorbing it.
3.45 The increased supply of homes has directly contributed to the area more effectively attracting and retaining people than it has historically. One benefit of this is that the Black Country’s working age population has grown3. The proposed supply in the draft BDP therefore risks this recent trend and ultimately will result in reducing the size of the working age population.
3.46 Notwithstanding the above, based on the findings of Turley’s Technical Review of Housing Need and Supply in the Black Country, we have significant concerns regarding the robustness of the Councils’ proposed supply, which we summarise below:
· There are a number of sources of the supply which are proposed on existing vacant or occupied employment land (6% of the total proposed supply). Similarly to the response to draft policy DEL2 above, this approach significantly risks the NPPF’s requirement for the plan to provide a sufficient supply of employment sites, as well as for housing supplies to only include land with a realistic prospect that it is available and could be viably developed. It also contradicts the plan’s objective to support economic growth.
· The above is not a new approach. The BCCS also allocated a total of 16,182 homes on occupied employment land. Based on the Urban Capacity Review Update (May 2021) only 679 (4.2%) of those homes have been delivered to date (with less than five years of the plan period remaining).
· The BCCS assumed a 10% non-implementation rate for sites under construction. The BCP plans to reduce this to 5%, based only on evidence from Wolverhampton City for the period 2001-20044. There is insufficient evidence at this stage to justify such a change in approach.
· 4,973 new homes are proposed on existing allocations (circa 10% of the total supply). The largest contributions to this are from Dudley (2,506 homes) and
3 ONS (2021) Mid-year population estimates, 2001 to 2020
4 Paragraph 2.1.14 of the Black Country Urban Capacity Review Update (May 2021)

Wolverhampton (2,248 homes). These sites are largely located in Strategic Centres and allocated in Area Action Plans which followed the BCCS. There is no new evidence to demonstrate their deliverability to support their continued allocation in the draft BCP, there is however evidence where the Councils concede a number of these sites are constrained given issues such as land ownership, viability, the need to relocate existing uses, or ground contamination5.
· No compelling evidence (as required by NPPF paragraph 71) has been provided to justify including 812 new homes (circa 2% of the supply) in Wolverhampton City Centre on upper floor conversions. There is no evidence in the SHLAA or any data on historic windfall delivery rates of this nature in the Black Country.
3.47 Making the appropriate reductions in supply based on the above reduces the Black Country’s housing supply by almost 10,000 homes, leaving a potential supply of only 38,266 homes (2,014 dwellings per annum).
3.48 This would see the shortfall grow to 37,810 homes, just under 50% of the area’s total housing needs. This is significant, especially given there are other sites which can make a contribution to ensuring the Councils’ housing supply is robust, such as land at Pennwood.
3.49 There is currently no evidence to demonstrate how the Black Country’s shortfall of circa 28,000 homes will be met, let alone the more likely scale of the shortfall – circa 38,000 homes. The plan refers to Lichfield, South Staffordshire and Shropshire contributing to the shortfall – this totals a maximum of 7,500 new homes6. So a 30,500 home shortfall remains based on Turley’s analysis if the supply.
3.50 Even if Wolverhampton City’s 35% standard method cities uplift was removed, the shortfall including contributions from other authorities would still stand at circa 16,000 based on the Black Country’s claimed supply, or circa 24,000 homes based on Turley’s analysis of the supply. There is reference to Telford potentially also assisting (and at the Solihull Local Plan examination reference was made to Stafford potentially contributing), but this is unlikely to be a significant contribution or anything close to ensure the unmet need is fully resolved.
3.51 The Black Country should therefore be examining its potential supply of greenfield sites to ensure its supply is robust and to further reduce the shortfall to be exported to neighbouring authorities. As set out at Section 4 below land at Pennwood has been unfairly scored in the Councils’ SA and Site Assessment scoring exercise. When reasonably and appropriately considered it is capable of delivering new homes which can assist in reducing the scale of the Black Country’s shortfall, whilst providing real benefits for existing and new residents.
5 Referenced at paragraph 7.7 of the Viability and Delivery Study (May 2021), paragraph 6.6 of the draft BCP, specific site commentary in the SHLAAs, and paragraph 3.1.24 of the Black Country Urban Capacity Review Update (May 2021)
6 Based on page 2 of the Black Country Authorities’ hearing statement to Matter 2 of the Solihull Local Plan examination

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Policy HOU2 (housing density, type and accessibility)
3.52 It is agreed that a range of types and sizes of accommodation are needed, this is reflected in the Councils’ Housing Market Assessment (March 2021). Notwithstanding this, any housing mix should be agreed based on the most recently available information at the point an application is determined, this is rightly acknowledged by the policy.
Policy HOU3 (delivering affordable housing)
3.53 At the current time the majority of the Councils’ proposed supply (though we dispute the scale of it) will be on brownfield land, which based on draft HOU3 will only deliver 10% affordable housing.
3.54 Any development on land which is currently in the Green Belt will be expected to deliver the higher 30% affordable housing requirement. Wolverhampton is only proposing 1,014 new homes on land currently in the Green Belt – 8% of Wolverhampton’s proposed supply and circa 5% of its total need.
3.55 It is absolutely necessary for Wolverhampton to be identifying sites which can make a more significant contribution to its affordable housing shortfall – such as Barratt’s site at land at Pennwood which proposes affordable housing provision.
Employment
3.56 Paragraph 7.34 states “Local Employment Areas are often vulnerable to pressure for redevelopment to other uses such as housing. However, the loss of too much local employment land will compromise the successful delivery of the BCP’s employment strategy”. This is contrary to draft policy DEL2 which allows for housing or employment development on previously developed land that accords with other BCP and local plan policies.
3.57 As mentioned at paragraph 3.27 of this document, the draft Local Plan does not currently include an employment protection policy or ‘test’ for applications for housing development or other types of development on employment sites. This could be incorporated in to draft policies HOU1, EMP1-EMP4, or alternatively a specific policy could be prepared.
Environmental transformation and climate change
Policy ENV1 (nature conservation)
3.58 Policy ENV1 of the BCP seeks to ensure that development is not detrimental to the
natural environment, and outlines a series of measures / tests to ensure that any development can have a measurable improvement to the natural environment.
Policy ENV3 (nature recovery network and biodiversity net gain)
3.59 Barratt is supportive of draft policy ENV3. Land at Pennwood has been designed to maximise the delivery of new habitat and biodiversity. The site therefore can contribute to principles identified by policy ENV3, as set out within paragraph 2.42 of the accompanying vision document which provides an overview of the ecological opportunities at the site.

Policy ENV5 (historic character and local distinctiveness of the Black Country)
3.60 Barratt is supportive of the Council’s ambition to protect historic character and local distinctiveness where it is evidenced.
3.61 Turley’s Preliminary Heritage Assessment demonstrates that the significance of Park Hall Hotel is principally invested in its historic interest as an early 18th century country house, its later conversion into a Roman Catholic School and its associations with notable individuals. Its significance is also attributed to its architectural interest, principally the exterior of the principal house and the historic extensions to a lesser extent. The significance of the building has been diminished by widespread alterations to the interior and substantial extensions, to the extent that the legibility of the building as a former house is diminished and its legibility as a former school is very limited. The immediate setting is altered and appears to yield no evidence of the historic domestic or educational use of the building and site.
3.62 The character of the wider setting of the building has also changed and is now characterised in large part by modern residential development. We have found no evidence that the countryside setting of the building was instrumental to the decision to establish a school at Sedgley Park. It is however acknowledged that the land to the south does make a degree of contribution as a remaining part of the rural and countryside setting of the former country house. This has been considered as part of the masterplan presented in the accompanying Vision Document for land at Pennwood, including the retention of a view corridor to the south.
3.63
Policy ENV8 (open space, sport and recreation)
3.64 As expressed throughout these representations, there is a need for policy
requirements to be fully evidence and justified. Barratt therefore support using the most up to date local open space, sport and recreation standards and these should be evidenced accordingly by each local authority and inform further development of the plan.
3.65 Barratt support draft policy ENV8 which sets out the aim for expanding community use of open space, sport and play, and moving towards most ‘up to date’ local open space, sport and recreation standards. Open space evidence identifies deficit around land at Pennwood. As such, the masterplan comprises a large amount of open space including a new woodland park and play facilities.
3.66 Wolverhampton’s most up to date evidence is the Open Space Strategy and Action Plan (2018). This report finds that:
· There is a decrease in the quantity standards of open space provided in Wolverhampton from 4.43ha per 1,000 population in 2012 to 4.38ha per 1,000 population. This is due to the reduction in the total amount of open space and increase in population.
· The ‘Central and South’ area (which land at Pennwood is located within) represents the second most significant decrease in open space – 0.76ha per 1,000 population. This includes a 0.18ha per 1,000 population loss of parks. The

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loss has seen the need for children and young person’s provision not being met in the area.
· In terms of accessibility to district parks, a large proportion of Sedgley to the north of land at Pennwood is not within a 20 minute walk of a district park.
· The overall summary for the ‘Central and South’ area is that “there are low levels of open space provision” (page 25) and that “there is little potential to create new open space through development”.
3.67 Land at Pennwood’s significant benefit of public open space representing more than 50% of the proposals, including a woodland park and play areas will make a substantial contribution to the deficits identified in Wolverhampton’s most up to date open space, sport and recreation evidence.
Policy ENV9 (design quality)
3.68 Policy ENV9 appears to be a duplication of the criteria contained in draft policy CSP4 and can be most appropriately dealt with by way of the production of a Local Design Guide for the Black Country aligning with the Governments’ recent amendments to the NPPF. As such it is not necessary.

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Criteria Score Response Turley
Corrected Score
Therefore, while the site is greenfield and currently located within the Green Belt, given the pressing housing need, the Council have identified exceptional circumstances to justify greenfield land being developed.
Agricultural land Amber MAGIC maps indicates that the majority of the Black Country’s agricultural land is Best and Most Versatile. The proposals at Land at Pennwood, Wolverhampton would represent a very insignificant loss to this wider area. Land at Pennwood should therefore score green. Green
Tree Preservation Order / mature trees of value on site or significantly affecting boundaries Amber All TPOs within the site and ancient woodland adjacent to the site would be fully retained.
Our proposals incorporate existing trees, including significant copses and woodland, as part of public open space and to provide new green corridors throughout the site. Green
Biodiversity Amber All ecological features subject to SLINC and SINC designations are to be retained and enhanced where possible.
Minimum 15m buffers will be provided between development and the SLINCs and new biodiversity links are to be created, as well as a woodland park, which will deliver a net gain in biodiversity. Green
Heritage assets on site or significantly affecting boundaries Red Turley’s Heritage Technical Note (Appendix 6) demonstrates that:
· The significance of Park Hall Hotel is principally invested in its historic interest as an early 18th century country house, its later conversion into a Roman Catholic School and its associations with notable individuals. However, the significance of the building has been diminished by widespread alterations to the interior and substantial extensions. Therefore the immediate setting is altered and appears to yield no evidence of its former use.
· There is no evidence that the countryside setting of the building was instrumental to the decision to establish a school at Sedgley Park albeit land to the south is Amber


17



Criteria Score Response Turley
Corrected Score
Infrastructure constraints on / under site Amber All Public Rights of Way and bridleways referred to in the Site Assessment have been incorporated into the design of both proposed development options and form part of a wider Green Infrastructure network which will open up land not currently accessible to the public. This is a significant benefit. Green
Highways access and
transportation Amber DTA’s Transport Technical Note demonstrates adequate access to the site can be achieved through a primary new access on the A459 (Wolverhampton Road). Green
Impact on the wider road network Amber DTA’s Transport Technical Note demonstrates that any increase in movements on the surrounding road network would not be significant and would have no material impact on the safe operation of the local and wider network with the proposals providing safe and suitable access for all. Green
Primary school Amber DTA’s Transport Technical Note demonstrates that the nearest primary school is within a 5 minute walking distance or 2 minute cycle time, this is acceptable based on IHT guidance. This is within the Council’s ‘high accessibility’ category for school accessibility, there is no higher accessibility category. Green
Secondary school Amber The nearest secondary school is Colton Hills Community School, 600m from the site. This would be a 7 minute walk from the site.
This is within the Council’s ‘high accessibility’ category for school accessibility, there is no higher accessibility category. Green
GP / heath centre / walk in Amber DTA’s Transport Technical Note demonstrates that in terms of access to health provision, the closest Surgery is Parkfield Medical Centre located 1km to the north-east from the centre of the site. Penn surgery is located 1.5km to the north-west of the site. Green
Centre /
foodstore Amber There are a number of convenience stores within close proximity to the site where residents will be able to buy to day to day products. An Aldi superstore is located 780m to the north of the site, with other retail parks (Mitre and Green


19

Criteria Score Response Turley Corrected Score
Springvale) being located between 2.4 – 2.6km away. In addition, the city centre is located
2.7km to the north of the site.
Connections to local cycle route networks Amber The proposals seek to enhance cycling connectivity in the area, indeed there are currently no cycling routes through the site. Amber
These will link in with the wider cycling network.

4.3 We provide a comparison of land at Pennwood’s site assessment with other proposed allocations in Wolverhampton at Appendix 8. This demonstrates that land at Pennwood scores similar, or better than the proposed allocations on land to be removed from the Green Belt in Wolverhampton.
4.4 Section 3 of the site selection methodology relevant to Green Belt sites states the criteria for filtering our sites include where development would cause ‘Very High’ harm to the Green Belt and ‘Moderate-High’ harm to landscape sensitivity, and where there is one or more significant planning constraint which cannot be mitigated. Our evidence demonstrates that had a reasonable and appropriate assessment of land at Pennwood been undertaken, including assessing the area of the site proposed for development only, the site would satisfy this criteria, so should be a proposed allocation,
4.5 In summary, our evidence demonstrates that the role land at Pennwood could play in delivering new homes sustainably in Wolverhampton has been underplayed by the Site Assessment and SA. We have shown that land at Pennwood scores similar to other proposed allocated sites. It should therefore be a proposed allocation in the plan, not least because of its range of benefits, including the provision of over 50% public open space in an area with an identified open space deficit (as we discuss at Section 3).

20

5. Summary
5.1 Since 2017 Barratt has actively promoted land at Pennwood, Wolverhampton (site ref:
SA-011-WOL) (‘the site’) as a sustainable and deliverable opportunity for new homes and associated infrastructure. The entire site is in single ownership and in the control of Barratt.
5.2 Firstly, there is a pressing need for the Black Country Plan to propose the removal of
additional land from the Green Belt for residential development:
· The Black Country authorities’ supply is not realistic and include sites which do not meet the requirements of planning policy and guidance. Following our review a more realistic assumed supply is 38,266 homes (a reduction of almost 10,000 homes). This would equate to a substantial shortfall of circa 38,000 homes, just under 50% of the area’s total housing needs. This includes deducting the existing vacant, occupied employment land and Wolverhampton upper floor conversations, and existing Black Country Core Strategy (2011) allocations components of the supply, and using appropriate and evidenced non-implementation rates.
· There is currently no evidence to demonstrate how the Black Country’s shortfall of circa 28,000 homes will be met, let alone the more likely scale of the shortfall – circa 38,000 homes. The plan refers to Lichfield, South Staffordshire and Shropshire contributing to the shortfall – this totals a maximum of 7,500 new homes7. So a 30,500 home shortfall remains based on Turley’s analysis of the supply.
· Even if Wolverhampton City’s 35% standard method cities uplift were to be removed the shortfall would still stand at circa 24,000 homes (based on Turley’s analysis of the supply). There is reference to Telford potentially also assisting (and at the Solihull Local Plan examination reference was made to Stafford potentially contributing), but this is unlikely to be a significant contribution or anything close to ensure the unmet need is fully resolved.
· At the same time the Black Country Councils are indicating an employment land shortfall of 210ha (circa 37% of the total need). There is no policy protection proposed for the Councils’ existing employment supply – this supply is necessary to provide employment for the area’s working age population. Without this they risk exacerbating their employment shortfall.
5.3 Therefore the Black Country authorities must identify further sites to be allocated for
new housing to ensure their supply is robust and the shortfall is minimised. Land at Pennwood is a sustainable opportunity for contributing to this remaining shortfall, it can provide the following benefits:
7 Based on page 2 of the Black Country Authorities’ hearing statement to Matter 2 of the Solihull Local Plan examination

· Delivery of up to 600 new homes to meet local needs and significantly help meet the wider housing needs within the Black County;
· Provision of a range of housing including a mix of sizes, types and tenures including affordable housing;
· Provision of new facilities, including public open space, landscape corridors, a new woodland park and buffer (representing over 50% of the site area) in an area with an identified public open space deficit; providing exceptional opportunities for recreation and biodiversity;
· Creation of new footpaths and cycle routes (circa 3,625m) which will enhance connectivity for both new and existing residents, promoting community interaction, social inclusion and equality; and
· Provision of new homes within walking and cycling distance of a range of employment opportunities.
5.4 As we set out at Section 4, our evidence demonstrates that the role land at Pennwood
could play in delivering new homes sustainably in Wolverhampton has been underplayed by the Site Assessment and Sustainability Appraisal (September 2021). We have shown that had a reasonable and appropriate assessment of land at Pennwood been undertaken, including assessing the area of the site proposed for development only, not only would it score similarly or better than the other proposed allocations in Wolverhampton, the site would satisfy the Council’s site selection criteria for proposing land in the Green Belt for allocation as residential development.
5.5 Based on the pressing need to identify further land for new homes in the Black Country
given the scale of its housing shortfall and applying a reasonable and appropriate site assessment, land at Pennwood should be a proposed allocation in the Black Country Plan. Beyond this it offers a range of benefits, including the provision of over 50% public open space in an area with an identified open space deficit (as we discuss at Section 3).
5.6 We would welcome the opportunity to discuss further with officers the site’s potential
to assist the Black Country Plan’s proposed supply.

Object

Representation ID: 43908

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.2 Barratt supports the overall Vision for the Black Country and its central aim of
“...creating a prosperous, stronger and sustainable Black Country”, in particular it needs to be flexible to allow the authorities to respond to future challenges. In achieving this the strategic priorities however need some further consideration.
3.3 As we explore further in these representations, the remaining unmet need for the
Black Country will be a significant issue. Strategic Priority 3 under the ‘housing that meets all our needs’ objective should therefore place greater emphasis on this matter and that all options will be explored to ensure the Black Country’s needs are met in full. We discuss the policies relevant to the strategic priority further below in terms of draft policies HOU1 and HOU2.
3.4 We note that Strategic Priority 7 under the ‘enabling a strong, stable and inclusive
economy’ objective seeks to provide a balanced portfolio of employment sites, as well to protect and enhance existing sustainable employment areas. It must be reflected on as to whether the plan’s current strategy of proposing to allocate active employment sites for new homes and a lack of policy protection for employment sites being lost to other uses would deliver this strategic priority, which we discuss further below in terms of draft policies HOU1 and DEL2.
3.5 We welcome Strategic Priority 15 under the ‘meeting our resource and infrastructure
needs’ objective as it seeks to ensure the necessary infrastructure is in place to support its existing and future growth. Barratt’s site is capable of delivering significant public open space (including a new woodland park, and new pedestrian and cycle routes) to meet the needs of existing and new residents.

Object

Representation ID: 43909

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.8 As currently drafted the housing (47,837 homes) and employment (355ha) supplies are
identified in the emerging policy (we are of the view that the actual housing supply is much lower – we discuss this further in response to draft policy HOU1).
3.9 The actual policy should be clearer that this is the area’s proposed supply only and that
the actual overall needs for the Black Country are 76,076 homes and 565ha of employment land. The policy can then be clear on how much of the need is proposed to be exported to other authorities. The policy should also be clearer on the extent of the supply proposed on land to be released from the Green Belt.
3.10 Policy CSP1 provides the overarching strategy which is essentially made up of two elements:
· Delivering the majority of growth in the existing Urban Area / Growth Network (86% in total); and
· Delivering a limited number of Neighbourhood Growth Areas (NGA) outside of Growth Network (14%). The policy defines NGAs as “areas in highly sustainable locations on the edge of the Urban Area”. The supporting text to the policy provides further explanation – they are ‘large sites, or clusters of smaller sites, which have been released from the Green Belt in sustainable locations on the edge of the urban area”.
3.11 Given the existing Urban Area / Growth Network reflects the sites identified in the Councils’ Urban Capacity Study, it is presumed the above represents a hierarchical approach, with the existing Urban Area / Growth Network favoured over the NGAs. This point should be further clarified as part of the justification text to draft policy CSP1 to ensure it meets NPPF paragraph 20.
3.12 Paragraph 3.7 of the policy supporting text indicates the strategy has been developed “through a comprehensive assessment of a range of alternative options”. The preferred strategy reflects Spatial Option J, considered in the Sustainability Assessment (July 2021) (SA). To ensure the plan satisfies NPPF paragraph 35 further evidence will be necessary to provide clarity as to whether this optioneering exercise reflects the Councils’ assessment of reasonable alternatives, or whether this assessment is provided elsewhere in the SA.
3.13 The Black Country’s needs are based on a plan period of 2020-2039. NPPF paragraph 22 states that strategic policies should look ahead over a minimum 15 year period from adoption. To achieve this the plan would have to be adopted by 31 March 2024. The current schedule for the BCP is that the plan will be adopted in April 2024, on this basis the plan would not meet the requirements of NPPF paragraph 22. The plan period should therefore be extended to reflect this.

Support

Representation ID: 43910

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.14 Policy CSP3 1 recognises the importance of providing a mix of good quality residential areas where people choose to live and recognising the inherent sustainability of directing new development through the allocation of a network of new NGAs. This is why NGAs are crucial to the success of this plan – as traditionally certain types and sizes of housing are more readily delivered on urban brownfield sites due to factors such as viability and density. NGAs offer the opportunity to deliver a wider range of housing types to meet the area’s identified needs.
3.15 Barratt support that comprehensive masterplanning will be important to the success of the NGA’s. Paragraph 3.48 states that NGA’s should be master-planned together regardless of ownership. Land at Pennwood is under single ownership, enabling Barratt to take a streamlined master-planning process. In addition, it is stated that NGA’s generate need for new infrastructure, this is supported by Barratt as this provides an opportunity to deliver infrastructure for existing and new homes.
3.16 The allocation of NGAs allows for greater public access to the countryside which urban sites are not able to, so it is right parts e) and g) of the draft policy require integrated and where possible continuous networks of green infrastructure and easy access to the countryside. This would not be possible without NGAs and the need for this infrastructure is a central theme to the illustrative masterplan for land at Pennwood. As we will go onto demonstrate, land at Pennwood is a potential NGA offering significant benefits which can assist the Black Country authorities with reducing their unmet need further.

Object

Representation ID: 43911

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.17 The NPPF was updated in July 2021 with a much greater emphasis placed on the delivery of high quality design. This saw significant amendments to chapter 12 of the NPPF and was supplemented by the publication of the National Design Guide (2021) and National Model Design Code (Parts 1 and 2) (2021). Together these documents confirm the Government’s intent to guide the delivery of well-designed places and demonstrating what ‘good design’ means in practice.
3.18 The NPPF now establishes a need for local planning authorities to ensure that visual tools such as design codes and guides are used to inform development proposals to provide maximum clarity about design expectations at an early stage to assist in providing a framework for creating high-quality places, with a consistent and high-quality standard of design to inform development proposals.
3.19 Barratt therefore consider that Policy CSP4 should be updated to reflect this change in
national guidance and instead of establishing prescriptive design criteria within a strategic policy, there is instead an opportunity for the principles identified within draft policy CSP4 to inform the future development of Local Design Codes for the Black Country.
3.20 In any event, throughout the masterplanning undertaken to date, Barratt has sought to ensure that the illustrative masterplan is grounded through high quality urban design and placemaking as evidenced through the Vision Document enclosed at Appendix 3.
3.21 The nature and distinctive qualities of the local landscape surrounding land at
Pennwood has been taken into account when developing the siting, scale, and design of new development. In addition, the masterplan has been informed by additional
technical work on heritage and ecology allowing the proposed layout to better accommodate landscape and visual screening but also deliver significant ecological benefits through the green infrastructure network.
Green Belt

Object

Representation ID: 43912

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.22 As identified at paragraphs 3.14-17 and 3.75, the draft BCP has identified exceptional circumstances for the removal of land from the Black Country Green Belt. The Council summarise their exceptional circumstances case further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).
3.23 Following national planning policy, the authorities are therefore justified in proposing
to amend the Green Belt boundary through the associated policies map. Indeed further land will be necessary to be released from the Green Belt if the Councils are to deliver the scale of supply proposed in the plan, let alone reducing the overall shortfall being exported to neighbouring authorities (as we discuss further in response to draft policy HOU1 below).
3.24 The policy however could do with refinement. As currently drafted part 2 applies to sites to be removed from the Green Belt (so at the point the plan is adopted will no longer be in the Green Belt), and the balance of the policy is to be applied to land remaining in the Green Belt. The policy would benefit from part 2 being deleted to provide greater clarity. Part 2)a. (the need for a defensible Green Belt boundary) is covered in draft policy CSP3, it may be that policy should also include reference to part 2)b. and the need for compensatory measures. Another solution could be making Part2)b. part of any site specific allocation for sites removed from the Green Belt.
3.25 In evolving the next version of the plan the Councils should provide further information
in a single document (perhaps as a topic paper) summarising the Green Belt compensatory measures on a Black Country wide basis to ensure there is clarity on how NPPF paragraph 142 is satisfied.
Infrastructure
3.26 At the current stage of draft BCP preparation it is acknowledged that the evidence base is still being prepared, and this is particularly true with regards to infrastructure.
3.27 Paragraph 4.9 states “Parts of the Black Country’s existing highway infrastructure, and the motorway network, suffer from congestion”. Development should therefore be located at the most sustainable and accessible locations. Land at Pennwood benefits from being located near to a variety of existing amenities and facilities that are within walking or cycling distance of the proposed development. Figure 2 ‘Facilities Plan’ of the accompanying Vision Document demonstrates this.
3.28 Paragraph 4.11 emphasises the need for infrastructure investment in order to support future development. Barratt are proposing to create extensive green infrastructure (over 50% of the total site area) within their site that is multi-functional through the delivery of biodiversity, amenity, aesthetic and drainage benefits. In addition, where development is planned between new areas of public open space and new woodland park, new footpaths, cycle routes and landscape corridors are proposed.

Comment

Representation ID: 43913

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

Infrastructure
3.26 At the current stage of draft BCP preparation it is acknowledged that the evidence base is still being prepared, and this is particularly true with regards to infrastructure.
3.27 Paragraph 4.9 states “Parts of the Black Country’s existing highway infrastructure, and the motorway network, suffer from congestion”. Development should therefore be located at the most sustainable and accessible locations. Land at Pennwood benefits from being located near to a variety of existing amenities and facilities that are within walking or cycling distance of the proposed development. Figure 2 ‘Facilities Plan’ of the accompanying Vision Document demonstrates this.
3.28 Paragraph 4.11 emphasises the need for infrastructure investment in order to support future development. Barratt are proposing to create extensive green infrastructure (over 50% of the total site area) within their site that is multi-functional through the delivery of biodiversity, amenity, aesthetic and drainage benefits. In addition, where development is planned between new areas of public open space and new woodland park, new footpaths, cycle routes and landscape corridors are proposed.

Policy DEL1 (infrastructure provision)
3.29 The Councils need to be cautious with their approach to viability given the scale of brownfield land in the proposed supply. The draft BCP is highly dependent upon development in the existing built-up area (40,117 dwellings) and brownfield sites (81%). The Black Country’s Viability & Delivery Study (September 2021) confirms that 65% of urban typologies tested are marginally viable (27%) or unviable (38%). The Councils must grapple with this matter as part of the plan and in identifying its proposed supply.

Object

Representation ID: 43914

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.30 This policy covers development of housing or employment on previously developed land ‘that is not allocated for this uses’, so would apply for any planning applications for residential development on existing employment sites. Both the housing and employment shortfalls are significant – circa 37% of the total need (notwithstanding that no evidence has been prepared to indicate whether the proposed component of the housing supply on existing employment sites has been factored into the employment land shortfall).
3.31 As set out in the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) there is limited evidence that there is any trend of housing sites coming forward for employment development in the urban area, where as there is evidence that employment sites are sometimes redeveloped for new homes. Examples of this are the Bilston Urban Village site in Wolverhampton and the former Cerro EMS Ltd site on Goscote Lane in Walsall (though we do dispute the scale of the Council’s anticipated supply from this source going forward).
3.32 So it is anticipated this policy would mostly be applied to new housing on employment sites. Any further loss of employment land would only exacerbate the Council’s already significant employment land shortfall of 210ha, at a time when the Black Country’s economy is growing, with the employment rate growing faster than the average in England (3.5% growth compared to an average of 0.9%) (paragraph 1.29 of the draft BCP).
3.33 Indeed, it clearly states at paragraph 1.30 that “the challenge is to keep that momentum”. Policy DEL2 should reflect this growth and ensure the employment land shortfall does not unnecessarily increase, it should therefore be seeking to provide greater protection of existing employment sites (no protections are provided in draft policies HOU1 or EMP1-EMP4). This would also ensure the policy and plan conforms to the NPPF, which requires a sufficient supply of employment sites to be provided.
3.34 This can be done through requiring any application for residential development on an existing employment site to include evidence the site has been marketed for a certain period and that there is no reasonable interest. This is an approach taken by a number of authorities, including neighbours such as Lichfield District.
3.35 Rather than compromising its employment land supply further, the plan should be seeking to maximise locations for development outside of the urban area, and increasing the number of homes allocated on sites currently in the Green Belt. Land at Pennwood can assist in ensuring the Black Country’s housing land supply is robust (we set out the site’s benefits at Section 2 and discuss the Councils’ assessment of the site
further at Section 4) and does not compromise the plan’s ability to meet the area’s employment needs.

Support

Representation ID: 43915

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.36 Barratt is supportive of the Local Plan’s aspirations for health and wellbeing and
identifying opportunities through new development to support the creation of strong, vibrant and healthy communities. Health and wellbeing are core to the social objective of sustainable development as defined by the NPPF (paragraph 8).
3.37 At the heart of this is locating new development in the right locations and ensuring it delivers sufficient infrastructure to make better places for living. Land at Pennwood provides an opportunity to accommodate a sustainable community that integrates well with existing residents and provides access to open space including the new woodland park and play facilities within a safe and inclusive environment.

Object

Representation ID: 43916

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.38 As discussed in response to Policy DEL1, it is important that policies within the BCP do compromise the viability and deliverability of new developments, particularly in respect of the need for and delivery of onsite infrastructure. To ensure HW1 takes a consistent approach to viability with other policies in the plan, part j. of the policy would benefit from cross referencing draft policy DEL1 which sets out the tests for viability.
3.39 The proposals would create 153 jobs during construction, including 11 apprenticeships for every year of construction. Beyond this 215 indirect jobs would be created during construction.