Draft Black Country Plan

Object

Representation ID: 22367

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Vision for the Black Country
Paragraph 1.43 of the BCP identifies a series of key strategic challenges and objectives that have arisen since 2011 which the Plan Strategy, objectives and suite of policies and proposals seek to address. Paragraph 2.1 then continues by stating that ‘The Vision’ reflects what the Black Country will be like in the future if the needs and aspirations of those who live, work in or visit the area are to be met, whilst also ensuring that it retains the characteristics that make it attractive and distinctive. It also states that the Vision needs to be flexible, to allow authorities to respond to future challenges in a way that is right for the Black Country, its residents and businesses. Paragraph 2.2 then states that The Vision has been written in the context of national, regional and local policy frameworks.

Notwithstanding the broad range of challenges and objectives identified which the BCP needs to address over the Plan period, RSL consider the Vision itself to be far too brief and simplistic, and would benefit from greater elaboration to be more relevant to the uniqueness of the Black Country, thereby helping to frame a clearer vision of how the Plan area will have evolved and been shaped by 2039.

Support

Representation ID: 22368

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Objectives and Strategic Priorities
RSL fully support the 8 Objectives and 15 Strategic Priorities identified in Table 1, as these have been informed by the challenges that the Black Country Authorities (BCA) are likely to face over the Plan period, and provide a clear structure against which individual policies and proposals within the BCP can be developed, thereby helping to maximise their effectiveness.

Object

Representation ID: 22369

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Part 1 of Policy CSP1 – Development Strategy states that it will deliver sustainable economic and housing growth and ‘to meet strategic planning targets’ by, inter alia, delivering at least 47,837 net new homes and at least 355 hectares of employment land. The figures quoted in the policy appear to represent the BCP’s housing and employment needs for the Plan period, but this is not the case.

Whilst RSL appreciate why these figures have been included in Policy CSP1, we consider this could well mislead some readers as the actual levels of housing and employment needs required within the area during the Plan period are much higher. Whilst Table 2 that follows Policy CSP1 provides a summary of the distribution of growth, detailing a ‘Grand Total’ of 76,076 homes and 565 hectares of employment land, there is no explanation that these figures are the levels of housing and employment needed within the BCP area during the Plan period. It is not until the Duty to Co-operate section (paragraph 3.20 onwards) that some clarification is provided that the figures used within Policy CSP1 represent only 63% of both its housing and employment needs, leaving significant shortfalls of 28,239 homes and 210 hectares of employment land. The actual levels of housing and employment need are each then only referred to one further time within a Plan extending to 727 pages. As one of the most important strategic planning issues to be covered within the BCP, the challenges and implications in not meeting in full the area’s future housing and economic growth aspirations should be given greater coverage.

RSL consider that the BCP would therefore benefit from a clearer explanation earlier in the document in order for all to fully appreciate the circumstances within which the future development needs of the area are being addressed. This should set out more specifically the challenges of meeting the full housing and employment needs within the Plan area, the implications of this under the Duty to Co-operate and the risks if all of the identified shortfall cannot be accommodated by neighbouring authorities in terms of the legal compliance of the BCP.

Support

Representation ID: 22370

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

In terms of Policies CSP2 and CSP3, RSL fully supports their approach to the distribution of strategic growth to the most sustainable locations which are accessible to jobs and a range of services and facilities, whilst providing housing choice, underpinning the areas’ economic competitiveness and supporting the working population.

Support

Representation ID: 22371

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

In terms of Policies CSP2 and CSP3, RSL fully supports their approach to the distribution of strategic growth to the most sustainable locations which are accessible to jobs and a range of services and facilities, whilst providing housing choice, underpinning the areas’ economic competitiveness and supporting the working population.

Support

Representation ID: 22372

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

RSL also fully support the approach adopted by Policy GB1 – The Black Country Green Belt. Part 2 of the policy confirms that sites are to be removed from the Green Belt and allocated to meet housing, employment, or other needs. It continues by stating such proposals will be designed to ensure new green belt boundaries are defined in a readily recognisable and permanent way, and that compensatory improvements of the remaining green belt will be secured to offset the impact.

The extensive and up to date evidence base which has informed the Plan-making process to date has fully demonstrated that the exceptional circumstances necessary to amend Green Belt boundaries exist. This is most evident in view of the fact that even with the removal of some, lower performing and less sensitive Green Belt land, there remains a significant shortfall in both the future housing and employment land requirements over the plan period.

Paragraph 140 of the NPPF confirms that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 141 continues that before concluding that exceptional circumstances exist, the relevant authority should demonstrate it has examined fully all other reasonable options for meeting its identified needs, including making the best use of brownfield land, optimising densities in towns and cities and other locations well served by public transport, and informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need.

The BCA’s evidence base includes the Urban Capacity Review Update 2021, a recent update to on-going studies to assess and quantify the potential capacity of land within urban areas, including brownfield land. The Review confirms that capacity within the urban area could deliver 39,257 homes and 205 hectares of employment land to 2039. This update has also incorporated assumptions about increasing densities where local character allows. This clearly demonstrates that all other reasonable options for accommodating the full housing and employment needs within the Plan area have been investigated, prior to considering Green Belt release.

On the basis of an identified shortfall of 36,819 homes and 360 hectares of employment land, Paragraph 3.24 of the BCP confirms that the BCA have worked constructively with neighbouring authorities to explore the ability for these shortfalls to be located elsewhere outside the Plan area. Notwithstanding, it is clear that whilst this will be an on-going exercise, the BCA recognise that this may only address a proportion of the shortfalls. Whilst the exact level of BCA unmet need is not confirmed within the BCP and will no doubt continue to be an evolving issue, the accompanying BCP Summary document indicates that at present, offers from neighbouring authorities suggest that between 8,000 to 9,500 homes and 102-173 hectares of employment land could be accommodated, albeit this will need to be tested by their respective Local Plan reviews.

In the circumstances, RSL consider the BCP and its associated evidence base clearly indicate there are exceptional circumstances justifying the release of Green Belt land within the BCP area. Associated Green Belt and Landscape Sensitivity Assessments have been undertaken and as confirmed at paragraph 3.16 of the BCP, have identified land that if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Grebe Belt boundaries. In respect of housing, even taking account of existing urban capacity, proposed Green Belt release and the current best-case scenario regarding the export of unmet needs to neighboring authorities, there is still a potential shortfall of some 18,739 homes. A similar scenario is likely in respect of employment land.

Support

Representation ID: 22373

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Policy HOU1 – Delivering Sustainable Housing Growth sets out minimum targets for future housing growth by each BCA up to 2039. RSL fully support this approach and acknowledge the important statement at Paragraph 6.4 which recognises that in the context of the Plan area and nature of its housing land supply, it is essential that a balanced range of sites is provided in terms of size, location and market attractiveness, as this will help maximise housing delivery over the Plan period.

Whilst RSL concur that it is useful for Tables 3 and 4 to provide details of the likely housing land supply components and their associated indicative phasing over the Plan period, all of which have been informed by reasonable assumptions, it is critical to ensuring a constant supply of housing is delivered throughout the Plan period that these targets are indicative as this provides sufficient flexibility, particularly in view of the nature of a large proportion of the supply within the urban area which typically suffers from multiple delivery constraints. Realistic assumptions and ensuring a portfolio of sites are allocated will be essential in ensuring a steady supply of land for housing is brought forward from the outset following adoption of the BCP to ensure the housing trajectory remains on target. As detailed within Appendix 17 of the BCP, even based on delivering only 63% of the Plan area’s housing need, annual housing delivery will need to achieve a significant uplift from that which has been achieved in recent years.

It is noted that at paragraph 6.12, some respondents at the Issues and Options stage suggested that a sequential approach that prioritised sites in the urban area should be adopted. Conversely, it is also acknowledged that given the scale of housing need within the Black Country, phasing of sites outside the urban area might not be possible. RSL support the approach taken in the BCP of only providing indicative phasing and minimum targets which has been fully informed by a detailed analysis of individual sites. Any form of restriction on the delivery of housing sites is more than likely to have the effect of significantly reducing the scale of housing delivery, particularly in the early years of the Plan period.

Comment

Representation ID: 22374

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Policy HOU2 – Housing Density, Type and Accessibility details the approach to a range of matters including housing density. Whilst RSL fully support the objective of making the most efficient use of land, we consider some clarity is required regarding the densities expected to be achieved on allocated sites. Part (1) of the policy correctly identifies the 3 key factors that should inform an appropriate density for an individual site, taking account of the need to provide a range of house types and sizes, the site’s level of accessibility to sustainable transport; and the need to achieve high-quality design and minimize amenity impacts. Part (4) of the policy then sets out 3 density ranges depending on accessibility standards as detailed at Table 5, which are applicable to all developments of 10 dwellings or more. Part (5) of the policy then refers to Chapter 13 of the BCP which details the appropriate density to be sought on each housing allocation site.

RSL consider Parts (4) and (5) appear to therefore contradict each other. Chapter 13 comprises detailed guidance for each allocated site and provides an assumption of the appropriate density, presumably informed by the specific circumstances relevant to the site, which must have taken account of the 3 key factors detailed at Part (1) of the policy. It is notable that some of the proposed allocations are for densities below 40dph, the lowest of the 3 density ranges at Part (4) of the policy. RSL therefore consider that this contradiction should be rectified to ensure appropriate minimum net densities are clear for each site.

Comment

Representation ID: 22375

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Policy TRAN1 – Priorities for the Development of the Transport Network includes reference at Part (1) to safeguarding land needed for the implementation of priority transport projects to allow for their future delivery. Part (4) also lists a number of key transport priorities identified for delivery during the lifetime of the BCP in respect of road, rail and rapid transit infrastructure.

RSL fully support the content of this policy as this will support the clear objective for a step change in public transport provision within the Black Country, which can help serve and link centres, improve sustainable transport facilities, improve connectivity to national networks and improve the efficiency of strategic highway networks. These are essential as part of a package of measures to address the climate change crisis, whilst also key to helping support both proposed housing and economic growth.

However, RSL are unclear as to how land is to be safeguarded within the BCP and consider that the policy and/or the wider Transport Section of the BCP would benefit from additional detail, particularly in regard to specific projects that are key to securing the required step change to ensure these are not compromised. It is also of relevance to make reference to the recent WMCA Board approval of the bid to the Government’s City Region Sustainable Transport Settlement (CRSTS) fund in September 2021, which covers a wide range of projects that would be funded within the Black Country, including extensions to the Metro network, a new railway station at Aldridge and development of key interchanges such as Dudley Port.

Support

Representation ID: 22376

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

RSL interests relate to Site Ref. WAH237, which we are promoting on behalf of the landowners and is proposed as a Strategic Allocation for approximately 363 new homes under Policy WSA3, being land north of Stonnall Road, Aldridge. RSL fully supports the proposed allocation of this site for residential purposes and re-confirm it is available, viable and suitable, and is deliverable within the first 5 years following the expected adoption of the BCP.

The context for the allocation is detailed within the General Spatial Strategy for Walsall, as detailed at Paragraphs C.17 to C.29. This recognises that the existing growth network does not have the capacity to accommodate all of the area’s need for new homes and jobs and as such, proposes a number of Neighbourhood Growth Areas (NGA) in highly sustainable locations close to the existing urban area that have good access to services. District Centres such as Aldridge, are identified as having a key role in helping drive forward the growth and regeneration of the borough outside of the strategic centres, whilst also accommodating housing growth to improve the vibrancy and health of these centres.

The associated Site Assessment for land north of Stonnall Road, Aldridge concludes that the site has few constraints and limited visual impact due to surrounding land uses and topography. RSL would concur with this overall assessment and agree that issues regarding improved infrastructure (e.g. drainage and highways) are not considered to be significant or otherwise unusual for a site of this scale and can be fully accommodated as part of the proposed development.

In respect of the associated Sustainability Assessment, the overall performance of the site is generally positive with major or minor positive impacts identified in respect of Housing, Health, Economy and Education and a neutral impact on Cultural Heritage, Climate Change Adaptation, Pollution and Equality. Mixed positive/negative impacts have been identified regarding Biodiversity, Climate Change Mitigation and Transport. Minor negative impacts are identified in respect of Natural Resources and Waste, with only a major negative impact identified for Landscape.

These findings are understood to have informed the Design Principles for Policy WSA3 in order to help further mitigate any potential adverse effects, and each of these are considered in further detail below:

1. Improvements to local facilities to support residents and enhance the sustainability of the existing area, in particular improved capacity at the primary school and local health centre – RSL confirm that financial contributions towards the upgrade of local facilities which are necessary to mitigate the impact of the proposed development of the site are agreeable in principle;

2. Investigation of and detailed proposals for remediation of contaminated land – whilst the available evidence does not indicate any former use other than agricultural that would give rise to any significant contamination issues, it is noted that the Site Assessment suggests previous agricultural uses may be an issue due to ‘fertilizer use, sewage sludge presence of heavy metals’. This is not considered to be particularly onerous and unlikely to raise any issues that cannot be addressed through appropriate assessment at the Development Management stage.

3. A transport strategy that includes widening to Stonnall Road for the extent of the site allocation and improves pedestrian access – RSL confirm this is deliverable as the full extent of the site frontage lies adjacent to the public highway and there is scope to widen the carriageway and provide a pedestrian footway that can tie in to the existing pedestrian footway along the northern side of Stonnall Road to the west.

4. Develop a site-wide Sustainable Drainage Strategy to ensure that drainage requirements can be met on site and are designed to deliver landscape, biodiversity and amenity benefits – whilst a detailed drainage strategy has yet to be progressed, the Concept Framework Plan (as enclosed with these representations) has been developed to incorporate a sustainable drainage strategy that works with the site topography and in combination with the proposed structural landscaping along the north eastern boundary of the site, which will help mitigate landscape impact, whilst maximising biodiversity net gain and amenity space for the benefit of both existing and future residents.

5. Develop a strategy for landscape and habitat creation that provides enhancement, retention and mitigation for established trees and hedges, to ensure there is no significant adverse impact on visual amenity and character or on protected animal species – as above, with reference to the accompanying Concept Framework Plan prepared by Define Urban Design and Landscape Architects, the vision for the site is to create a new rural edge to this part of Aldridge. This will comprise a significant structural landscape fringe to the north eastern boundary of the site, with tree planting and retention and management of existing hedges, alongside fingers of green space to break up areas of built form into smaller neighborhoods set within a rural setting. This will help to assimilate the development into the landscape and secure a softer settlement edge on the entrance to the town from the east. Such measures will also provide the opportunity to enhance the biodiversity credentials of the site, compared to the current intensively farmed landscape.

6. The site is in a MSA and requires prior extraction where practical and environmentally feasible. Where practical and environmentally feasible prior extraction for bedrock and superficial sand and gravel, shall take place – this issue effects the majority of sites within the borough and were this to be a precluding factor, it would significantly impact on the ability for the area to achieve its future housing and economic growth aspirations so should be seen in this context. Notwithstanding, this does not necessarily mean that any potential mineral resources that may exist at this specific site cannot be extracted prior to development and this requirement is a pragmatic solution and is an issue that can therefore be dealt with at the Development Management stage. In principle therefore, RSL accept this requirement and agree to an assessment being undertaken at the appropriate time to investigate the potential for such minerals to be present, and the practicality or otherwise of prior extraction in light of all environmental considerations.