Draft Black Country Plan

Comment

Representation ID: 22171

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

The Club have previously submitted representations to the Black Country Call for Sites Consultation. These representations proposed the removal of a parcel of land at the entrance to Druids Heath Golf from the Green Belt and its allocation for residential development. The site has not, however, been identified as a proposed residential allocation in the Regulation 18 consultation document.

The land in the Club’s control that that was subject to the previous Call for Sites representations constitutes site SA-0063-WAL – Land at Druids Heath Golf Club, Stonnall Road, in the Black Country Plan Site Assessment Report (“BCSAR”). It is concluded that the site is unsuitable for development. In essence, and incorrectly, the BCSAR concludes that the vehicle movements and activities associated with a golf club are incompatible with residential development. It is suggested that the development would have an “awkward” relationship with the clubhouse and its associated carparking. As detailed in these representations this is clearly not the case, as golf clubs adjoining residential development are commonplace. Indeed, vehicles traveling to the Club have to pass along residential roads to gain access to the site. Furthermore, the emerging Plan is proposing residential development in this location on land immediately adjacent to this site (proposed allocations WAH253). This allocation has an almost identical relationship to the clubhouse and its car park. This approach is clearly inconsistent

In addition to site SA-0063-WAL the Club are requesting that additional land is allocated for development. The full extent of the land in the Club’s control that is being promoted for development is shown on the Plan attached at Appendix 1. It is suggested that site SA-0063-WAL should be extended to include the area of car parking to the east. This results in this site becoming part brownfield and part greenfield. If the car park is allocated for development the parking will be replaced elsewhere within the Golf Club. The construction of a new car park would constitute an “engineering operation” and would, therefore, fall within “certain other forms of development” that are not inappropriate development in the Green Belt as defined by paragraph 150 of the Framework. The second parcel of land is located to the east of the Stonnall Road, immediately to the north of proposed allocation WAH 253.

It should be noted that the Club are promoting the development of these sites in order to help generate funds that will be ploughed directly back into the Club. The Club have identified a range of projects that cannot currently be afforded. The sale of this land for residential development will generate funds that can be invested to improve club facilities and help retain and attract new members. Nationally golf club membership levels have fallen over the last 10 years with a large number of clubs closing. Additional investment in the Club will help ensure its long term future.

We have reviewed the draft plan in detail and give our observations and representations below. It is clear to us that, notwithstanding the undoubted work which has gone into preparing the plan, it is extremely unlikely that the plan as currently drafted will achieve the objectives for housing in the Black Country and further sites are required. The land owned by the golf club can only help in this regard and, for the reasons set out below, is more appropriate than the adjoining land which is in the draft plan. Also the provisional reasons for its non inclusion are not supportable when analysed in more detail.”

Comment

Representation ID: 22182

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

[Comments Form/ Consultation approach]

Attached to this letter at Appendix 2 are the consultation Comments Form with Sections 1 and 3 complete. The remainder of this letter sets out our response to Section 2 – Your Representation/Comments. This approach has been adopted as there is insufficient space within Section 2 of the Comments Form to provide a full response.

Comment

Representation ID: 22183

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

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. [see the other Representations that form part of this Submission]

Comment

Representation ID: 22184

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

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 Policy CSP1 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. There is, however, additional land that is suitable for allocation to help address the housing requirement, such as the land being promoted for development by the Club.

Comment

Representation ID: 22185

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Policies CSP1 and HOU1 of the draft Plan provides the overarching policy guidance on housing delivery over the course of the Plan Period. Part 1.(a) of policy CSP1 states that during the course of the Plan Period “at least” 47,837 net new homes will be provided in the Black Country. However, the housing target of 47,837 dwellings will not deliver the total number of houses that are required. Table 2 – Black Country Development Strategy 2020-2039, of the draft Plan identifies a need for the development of 76,076 dwellings. The residual requirement of 28,239 dwellings will be directed to other local authority areas through the Duty to Cooperate. This approach has been adopted due to a perceived lack of suitable additional sites to allocate for development within the Black Country.

We have a number of concerns with the overall housing requirement identified in the Plan and the sources of housing land supply that have been identified to meet the target. This has consequential implications for the quantum of development that will be needed to be exported to other local authority areas unless additional allocations are made.

In the first instance, Table 2 of the draft Plan suggests that a total of 76,076 dwellings is required during the Plan Period. This is, however, less than the Standard Method housing requirement identified by the Black Country Housing Market Assessment 2021 (“BCHMA”), produced by the Black Country Authorities. At paragraph 4.13 of the BCHMA it is advised that “the final housing need in the Black Country, assessed using the revised Standard Method, is 4,019 per year”. The Plan period runs from 2020 to 2039. As such, the BCHMA concludes with a total of 76,361 dwellings is required during the course of the plan period (4,019 dpa x 19 years).

The National Planning Policy Framework (“the Framework”) advises at paragraph 61 that to determine the “minimum” number of homes needed strategic policies should be informed by a local housing needs assessment conducted using the Standard Method, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market signals. The draft Plan suggests a minimum housing figure below that identified by the BCHMA, and consequently fails to meet the requirement of the Framework. That being the case, as a very minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents.

Paragraph 4.14 of the BCHMA advises that whilst paragraph 010 of the PPG identifies a series of circumstances where it may be appropriate to pursue a higher housing needs figure than is indicated by the Standard Method “this assessment is carried out on the basis that the Standard Method figures set out above will apply”. That being the case, the BCHMA does not test whether the minimum Standard Method housing requirement figure should be increased, in accordance with the requirements of the PPG.

Paragraph ID:2a – 010 – 20201216, of the PPG advises that there will be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:

• Growth strategies for the area that are likely to be deliverable;
• Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• An authority agreeing to take on unmet need from neighbouring authorities.

We are not aware of any assessment to establish whether the minimum Standard Method housing requirement should be exceeded. It could be the case that the minimum Standard Method housing requirement is not sufficient to meet the housing needs of the Black Country.

In this regard we note that Table 5.1 of the BCHMA identifies that the percentage of people of working age in the Black Country will be less in 2039 than it is in 2020. In order to meet the emerging Plan’s economic growth aspirations it is necessary to ensure that a sufficient number of houses are provided to meet the jobs which will be created during the course of the Plan Period. An assessment should be undertaken to establish if the housing requirement needs to be uplifted to support economic growth.

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing would be via Section 106 agreements.

Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility and Self Build/Custom Build Housing, advises that 10% affordable housing will be sought on sites in lower value areas and brownfield sites in medium value zones. 20% affordable housing will be sought on greenfield sites and in medium value area. On all sites in higher value areas 30% affordable housing will be sought. This approach has been adopted for viability reasons. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing.

The draft Plan does not identify what proportion of the housing requirement is expected to take place in each of these zones. However, paragraph 6.4 of the Plan advises that 81% of the housing requirement is expected to be provided on brownfield land and 19% on greenfield land. That being the case the majority of the sites will provide either 10% or 20% affordable housing. This strongly suggests that the affordable housing policy within the Plan will be incapable of delivering a sufficient quantum of affordable housing to meet their identified need.

We are not aware of any assessment that seeks to establish the relationship between the quantum of affordable housing required by the BCHMA, and the likely level of affordable housing that it is expected Policy HOU3 of the Plan will deliver. This is a key piece of evidence that is missing from the emerging Plan. An increase to the minimum housing requirement may be required to ensure that a sufficiently supply of affordable housing is provided.

Drawing these matters together, it is our view that the housing requirement within the draft Plan is not justified given that it is below the minimum Standard Method requirement, and there appears to have been no supporting work undertaken to establish if there is a requirement for an uplift to the minimum Standard Method housing target on economic or affordability grounds.

Table 3 – Black Country Housing Land Supply Indicative Phasing 2020-2039, identifies the various sources of housing land supply. We have a number of concerns with the sources of supply, including:

• Sites with Other Commitment – The sites in this category are expected to deliver 3,802 dwellings during the course of the Plan period. It is understood from the Black Country authorities SHLAAs that an “other commitment” is a site with a resolution to grant planning permission but the Section 106 has not been signed. This source of supply is discounted by 10% in order to allow for non-delivery. It is not clear from the draft Plan how the 10% discount rate has been calculated. However, it is noted that the SHLAAs (eg. Walsall SHLAA 2019 paragraph 17) advise that Other Commitments are discounted by 10% as the adopted Black Country Core Strategy (“BCCS”) applied a discount rate of 10% to commitments. It is advised that a discount rate that is based on past trends may not be an appropriate way of establishing future delivery rates. Housing delivery in the Black Country has been affected by the 2008 recession and a number of government initiatives for improving future delivery, such as help to buy and ISA for first time buyers.

Whilst this may be the case, we would also suggest that it is equally unreliable to take a discount rate from the adopted BCCS, which was published in 2011. The BCCS is in excess of ten years old, and its supporting evidence documents even older. At the very least, a past trends based analysis should be undertaken in order to see if the discount rate is robust for the Other Commitments category. Furthermore, it is not clear whether there are sites with a resolution to grant planning permission, but the S.106 has not been signed, where the resolutions are several years old. If the resolution to grant planning permission is more than 6 months old the site should not be included as a source of supply.

• Existing Housing Allocations in Strategic Centres – These sites are expected to provide 4,973 dwellings. This is excluding those sites within the Strategic Centres that already have the benefit of planning permission, a resolution to grant planning permission, or are completed. The Walsall Site Allocations Document was adopted in 2019. The Dudley Borough Development Strategy was adopted in February 2017 and other various Dudley MBC AAPs were adopted between 2011 and 2017. The Sandwell Site Allocations and Delivery DPD was adopted in December 2012. The Wolverhampton Area Action Plans were adopted between 2014 and 2016. There has, therefore, been a significant period of time for the sites allocated for development in the Strategic Centre to come forward for development. The fact that these sites have not delivered despite the benefit of a positive planning framework suggests that there may be problems with their delivery. That being the case, the 10% discount rate suggested for these sites is entirely unrealistic.

• Occupied Employment Land - Occupied employment land is expected to deliver 3,091 dwellings towards the total housing requirement. This should not be included as a source of supply. There is no guarantee if or when such sites will come forward for development. Landowner’s intentions may change during the course of the Plan period. In addition, we have frequently found that industrial values outweigh residential values in large parts of the Black Country. As a consequence, it simply may not be economic to bring sites of this nature forward for residential development.

Furthermore, there is a significant shortfall of employment land within the Black Country, and the conurbation as a whole. Whilst new employment allocations are proposed by the Plan these will be new build estates where rents will be significantly greater than second hand stock. It is unlikely that businesses that are located on the poorer quality employment sites will be able to afford to rent or buy a new premises on these sites. Secondary, and lower cost stock, plays a vital role in the West Midlands economy. Losing land of this type to residential use may result in businesses closing. We are, therefore, extremely concerned that this source of supply is not only undeliverable but could also have a detrimental effect on the supply of employment land through the Plan area. If occupied employment sites come forward for development during the course of the Plan Period they should simply be treated as part of the proposed windfall allowance.
• Green Belt sites - No discount is applied to Green Belt land release sites as it is assumed they are readily deliverable. This is inappropriate. By way of example, Birmingham City Council have removed land from the Green Belt and allocated it for development in the adopted Birmingham Development Plan (“BDP”). This site is known as the Langley Strategic Urban Extension. The Langley Strategic Urban Extension is the largest allocation within the BDP and is expected to deliver a total of 6,000 dwellings.

The BDP was adopted in January 2017. Despite the Plan now being adopted close to five years there has been no delivery from the Langley Strategic Urban Extension. Indeed, a planning application has not been submitted proposing the development of the site. Whilst Birmingham City Council initially expected the site to start to deliver housing within the first five years of the plan period this has now been discounted, and Birmingham City do not expect any delivery from this site for several years. This is a prime example that Green Belt sites can have development difficulties. The statement in paragraph 6.7 of the emerging Plan, that Green Belt sites will not generally be affected by delivery constraints, is not justified.

• Other Allocations - The “Other” allocations within the plan have a 10% discount rate applied. It is not clear how this discount rate has been calculated. However, given the significant proportion of the allocations in the draft Plan that are not Green Belt are brownfield sites they are likely to have delivery constraints. A 10% discount rate is inadequate.
• Additional Site Capacity in Strategic Centres - The sites in this category are due to be identified and allocated through subsequent Local Plans produced later into the Plan period. We are concerned that the housing figures identified for these areas are not robust, and ultimately the plan making process will find that there is not the capacity to deliver this level of development within future Local Plans. A substantial discount rates should, therefore, be applied to sites in this category.

Furthermore, as detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. The emerging plan seeks to adopt a NDSS policy which will increase dwelling sizes impacting upon density. It is not unusual, in our experience, for brownfield sites within the Black Country to have constraints that adversely affect density, such as mineshafts or due to their relationship to surrounding uses. In addition, Table 5.10 of the BCHMA, advises that 54% of the housing requirement should be delivered as three or more bedroom properties, with over 25% of the properties required as four bed plus. Larger dwellings take up more space. This will drive down the density that can be achieved.

It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will need to be reduced accordingly.

In conclusion, we are concerned that the identified sources of housing land supply will be incapable of meeting the housing requirement identified by the Plan. In addition, given the housing requirement should be a minimum there is clearly a distinct advantage in erring on the side of caution, and applying robust and realistic lapse rates to the various sources of supply as if additional housing does come forward this will be of no detriment to the Plan. However, a housing delivery shortfall has the potential to be extremely problematic, causing five year housing land supply issues, the LPA’s failing the Housing Delivery Test and preventing the provision of much needed market and affordable housing within the Black Country.

Comment

Representation ID: 22186

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Policies CSP1 and HOU1 of the draft Plan provides the overarching policy guidance on housing delivery over the course of the Plan Period. Part 1.(a) of policy CSP1 states that during the course of the Plan Period “at least” 47,837 net new homes will be provided in the Black Country. However, the housing target of 47,837 dwellings will not deliver the total number of houses that are required. Table 2 – Black Country Development Strategy 2020-2039, of the draft Plan identifies a need for the development of 76,076 dwellings. The residual requirement of 28,239 dwellings will be directed to other local authority areas through the Duty to Cooperate. This approach has been adopted due to a perceived lack of suitable additional sites to allocate for development within the Black Country.

We have a number of concerns with the overall housing requirement identified in the Plan and the sources of housing land supply that have been identified to meet the target. This has consequential implications for the quantum of development that will be needed to be exported to other local authority areas unless additional allocations are made.

In the first instance, Table 2 of the draft Plan suggests that a total of 76,076 dwellings is required during the Plan Period. This is, however, less than the Standard Method housing requirement identified by the Black Country Housing Market Assessment 2021 (“BCHMA”), produced by the Black Country Authorities. At paragraph 4.13 of the BCHMA it is advised that “the final housing need in the Black Country, assessed using the revised Standard Method, is 4,019 per year”. The Plan period runs from 2020 to 2039. As such, the BCHMA concludes with a total of 76,361 dwellings is required during the course of the plan period (4,019 dpa x 19 years).

The National Planning Policy Framework (“the Framework”) advises at paragraph 61 that to determine the “minimum” number of homes needed strategic policies should be informed by a local housing needs assessment conducted using the Standard Method, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market signals. The draft Plan suggests a minimum housing figure below that identified by the BCHMA, and consequently fails to meet the requirement of the Framework. That being the case, as a very minimum the overall housing requirement needs to be uplifted by 285 dwellings to be consistent with the Council’s evidenced based documents.

Paragraph 4.14 of the BCHMA advises that whilst paragraph 010 of the PPG identifies a series of circumstances where it may be appropriate to pursue a higher housing needs figure than is indicated by the Standard Method “this assessment is carried out on the basis that the Standard Method figures set out above will apply”. That being the case, the BCHMA does not test whether the minimum Standard Method housing requirement figure should be increased, in accordance with the requirements of the PPG.

Paragraph ID:2a – 010 – 20201216, of the PPG advises that there will be circumstances where it is appropriate to consider whether the actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:

• Growth strategies for the area that are likely to be deliverable;
• Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• An authority agreeing to take on unmet need from neighbouring authorities.

We are not aware of any assessment to establish whether the minimum Standard Method housing requirement should be exceeded. It could be the case that the minimum Standard Method housing requirement is not sufficient to meet the housing needs of the Black Country.

In this regard we note that Table 5.1 of the BCHMA identifies that the percentage of people of working age in the Black Country will be less in 2039 than it is in 2020. In order to meet the emerging Plan’s economic growth aspirations it is necessary to ensure that a sufficient number of houses are provided to meet the jobs which will be created during the course of the Plan Period. An assessment should be undertaken to establish if the housing requirement needs to be uplifted to support economic growth.

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing would be via Section 106 agreements.

Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility and Self Build/Custom Build Housing, advises that 10% affordable housing will be sought on sites in lower value areas and brownfield sites in medium value zones. 20% affordable housing will be sought on greenfield sites and in medium value area. On all sites in higher value areas 30% affordable housing will be sought. This approach has been adopted for viability reasons. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing.

The draft Plan does not identify what proportion of the housing requirement is expected to take place in each of these zones. However, paragraph 6.4 of the Plan advises that 81% of the housing requirement is expected to be provided on brownfield land and 19% on greenfield land. That being the case the majority of the sites will provide either 10% or 20% affordable housing. This strongly suggests that the affordable housing policy within the Plan will be incapable of delivering a sufficient quantum of affordable housing to meet their identified need.

We are not aware of any assessment that seeks to establish the relationship between the quantum of affordable housing required by the BCHMA, and the likely level of affordable housing that it is expected Policy HOU3 of the Plan will deliver. This is a key piece of evidence that is missing from the emerging Plan. An increase to the minimum housing requirement may be required to ensure that a sufficiently supply of affordable housing is provided.

Drawing these matters together, it is our view that the housing requirement within the draft Plan is not justified given that it is below the minimum Standard Method requirement, and there appears to have been no supporting work undertaken to establish if there is a requirement for an uplift to the minimum Standard Method housing target on economic or affordability grounds.

Table 3 – Black Country Housing Land Supply Indicative Phasing 2020-2039, identifies the various sources of housing land supply. We have a number of concerns with the sources of supply, including:

• Sites with Other Commitment – The sites in this category are expected to deliver 3,802 dwellings during the course of the Plan period. It is understood from the Black Country authorities SHLAAs that an “other commitment” is a site with a resolution to grant planning permission but the Section 106 has not been signed. This source of supply is discounted by 10% in order to allow for non-delivery. It is not clear from the draft Plan how the 10% discount rate has been calculated. However, it is noted that the SHLAAs (eg. Walsall SHLAA 2019 paragraph 17) advise that Other Commitments are discounted by 10% as the adopted Black Country Core Strategy (“BCCS”) applied a discount rate of 10% to commitments. It is advised that a discount rate that is based on past trends may not be an appropriate way of establishing future delivery rates. Housing delivery in the Black Country has been affected by the 2008 recession and a number of government initiatives for improving future delivery, such as help to buy and ISA for first time buyers.

Whilst this may be the case, we would also suggest that it is equally unreliable to take a discount rate from the adopted BCCS, which was published in 2011. The BCCS is in excess of ten years old, and its supporting evidence documents even older. At the very least, a past trends based analysis should be undertaken in order to see if the discount rate is robust for the Other Commitments category. Furthermore, it is not clear whether there are sites with a resolution to grant planning permission, but the S.106 has not been signed, where the resolutions are several years old. If the resolution to grant planning permission is more than 6 months old the site should not be included as a source of supply.

• Existing Housing Allocations in Strategic Centres – These sites are expected to provide 4,973 dwellings. This is excluding those sites within the Strategic Centres that already have the benefit of planning permission, a resolution to grant planning permission, or are completed. The Walsall Site Allocations Document was adopted in 2019. The Dudley Borough Development Strategy was adopted in February 2017 and other various Dudley MBC AAPs were adopted between 2011 and 2017. The Sandwell Site Allocations and Delivery DPD was adopted in December 2012. The Wolverhampton Area Action Plans were adopted between 2014 and 2016. There has, therefore, been a significant period of time for the sites allocated for development in the Strategic Centre to come forward for development. The fact that these sites have not delivered despite the benefit of a positive planning framework suggests that there may be problems with their delivery. That being the case, the 10% discount rate suggested for these sites is entirely unrealistic.

• Occupied Employment Land - Occupied employment land is expected to deliver 3,091 dwellings towards the total housing requirement. This should not be included as a source of supply. There is no guarantee if or when such sites will come forward for development. Landowner’s intentions may change during the course of the Plan period. In addition, we have frequently found that industrial values outweigh residential values in large parts of the Black Country. As a consequence, it simply may not be economic to bring sites of this nature forward for residential development.

Furthermore, there is a significant shortfall of employment land within the Black Country, and the conurbation as a whole. Whilst new employment allocations are proposed by the Plan these will be new build estates where rents will be significantly greater than second hand stock. It is unlikely that businesses that are located on the poorer quality employment sites will be able to afford to rent or buy a new premises on these sites. Secondary, and lower cost stock, plays a vital role in the West Midlands economy. Losing land of this type to residential use may result in businesses closing. We are, therefore, extremely concerned that this source of supply is not only undeliverable but could also have a detrimental effect on the supply of employment land through the Plan area. If occupied employment sites come forward for development during the course of the Plan Period they should simply be treated as part of the proposed windfall allowance.
• Green Belt sites - No discount is applied to Green Belt land release sites as it is assumed they are readily deliverable. This is inappropriate. By way of example, Birmingham City Council have removed land from the Green Belt and allocated it for development in the adopted Birmingham Development Plan (“BDP”). This site is known as the Langley Strategic Urban Extension. The Langley Strategic Urban Extension is the largest allocation within the BDP and is expected to deliver a total of 6,000 dwellings.

The BDP was adopted in January 2017. Despite the Plan now being adopted close to five years there has been no delivery from the Langley Strategic Urban Extension. Indeed, a planning application has not been submitted proposing the development of the site. Whilst Birmingham City Council initially expected the site to start to deliver housing within the first five years of the plan period this has now been discounted, and Birmingham City do not expect any delivery from this site for several years. This is a prime example that Green Belt sites can have development difficulties. The statement in paragraph 6.7 of the emerging Plan, that Green Belt sites will not generally be affected by delivery constraints, is not justified.

• Other Allocations - The “Other” allocations within the plan have a 10% discount rate applied. It is not clear how this discount rate has been calculated. However, given the significant proportion of the allocations in the draft Plan that are not Green Belt are brownfield sites they are likely to have delivery constraints. A 10% discount rate is inadequate.
• Additional Site Capacity in Strategic Centres - The sites in this category are due to be identified and allocated through subsequent Local Plans produced later into the Plan period. We are concerned that the housing figures identified for these areas are not robust, and ultimately the plan making process will find that there is not the capacity to deliver this level of development within future Local Plans. A substantial discount rates should, therefore, be applied to sites in this category.

Furthermore, as detailed in our response to policy HOU2, we are concerned that the density requirements identified are unrealistic. The emerging plan seeks to adopt a NDSS policy which will increase dwelling sizes impacting upon density. It is not unusual, in our experience, for brownfield sites within the Black Country to have constraints that adversely affect density, such as mineshafts or due to their relationship to surrounding uses. In addition, Table 5.10 of the BCHMA, advises that 54% of the housing requirement should be delivered as three or more bedroom properties, with over 25% of the properties required as four bed plus. Larger dwellings take up more space. This will drive down the density that can be achieved.

It is, therefore, our view that the density policies are over ambitious and unrealistic, and the densities suggested will not be achieved. This in turn suggests that the capacity of the allocations has been over estimated and housing delivery will need to be reduced accordingly.

In conclusion, we are concerned that the identified sources of housing land supply will be incapable of meeting the housing requirement identified by the Plan. In addition, given the housing requirement should be a minimum there is clearly a distinct advantage in erring on the side of caution, and applying robust and realistic lapse rates to the various sources of supply as if additional housing does come forward this will be of no detriment to the Plan. However, a housing delivery shortfall has the potential to be extremely problematic, causing five year housing land supply issues, the LPA’s failing the Housing Delivery Test and preventing the provision of much needed market and affordable housing within the Black Country.

Comment

Representation ID: 22187

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities. The Strategic Centres and Core Growth Regeneration Areas are suitable for higher density development where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

As of yet the neighbouring authorities have not agreed an approach to the distribution of the housing shortfall or identified allocations in their emerging Plans that could meet this shortfall, in combination with the shortfall arising from Birmingham City. There is no certainty that the housing shortfall can be met on sustainable and deliverable sites. It is, therefore, essential that the emerging Black Country Plan allocates as many sustainable and sustainable sites for development to help ensure that the overall housing requirement is met. As detailed in these representations, the Club has surplus land in its control that should be allocated for development to meet the housing requirement.

Comment

Representation ID: 22188

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

We support the recognition in Policy CSP3 that exceptional circumstances exist to release land from the Green Belt and allocated it for development. It is clear that the housing requirement cannot be met without significant Green Belt release. Hoin response to Policy CSP2, it is our view that all suitable and sustainable sites within the Green Belt should be allocated for development given the significant housing shortfall. This includes the surplus land in the Club’s control.

Comment

Representation ID: 22189

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

The general approach in Policy CSP4 is welcomed. Paragraph 127 of the Framework states that “Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.” We consider that the proposed policy is appropriate and provides sufficient clarity as to what will be expected and what would be acceptable.

Reference is made within the policy to achieving high levels of sustainability and use of sustainable modern technologies. The approach taken in the policy is welcomed in that it does not try and conflate the dual roles of the planning process with Building Regulations, as we consider that Building Regulations are a far more efficient and effective way of securing sustainable building design and energy reduction than the planning system is.

Comment

Representation ID: 22190

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. Indeed, it is imperative if the housing requirement is to be met. Policy GB1 advises Green Belt release sites will need to include physical features that define the Green Belt boundary and that compensatory improvements to the environmental quality, biodiversity and accessibility will be required to offset the impact of removing the land from the Green Belt.

As detailed in these representations the surplus land in the Club’s control fulfils this brief. It has strong defensible Green Belt boundaries. The site can be developed to preserve and enhance biological interesting features, such as hedgerows, with built development located on the paddock land. Public access will be created to Green Belt land that it is currently inaccessible.