Draft Black Country Plan

Comment

Representation ID: 46203

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The requirements of policy W5 in respect of minimising waste in new development, re-use of materials following redevelopment and/or remediation and use of alternatives to primary aggregates in construction are couched in terms of as far as possible and wherever possible. Paragraph 16 of the Framework is clear that development plans should contain policies that are clearly written and unambiguous. Draft policy W5 should be redrafted with clear targets and the requirements of applicants providing justification for the approaches to waste management and the use construction materials in any given development project.

Support

Representation ID: 46204

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The inclusion of Brades Road, Oldbury as a proposed site allocation (site reference: SAH229) is fully supported Vulcan Property II Limited for the reasons set out in the 4 August 2020 call for sites submission.

Vulcan Property II Limited also fully supports the inclusion of adjoining land on Dudley Road East (site reference: SAH227) for the same reasons.

There is potential for Brades Road to come forward earlier in the plan period than 2032-2033 and justification for it being identified for delivery earlier in the housing trajectory. The significant shortfall in housing provision over the plan period and the uncertainty over housing numbers to be provided out of area through ‘Duty to Co-operate’ suggests very strongly that sites that are suitable and available should be identified as coming forward earlier in the housing trajectory, where there is potential for this to happen. There is good reason to expect that delivery out of area will be skewed to the latter stages of the Black Country Plan period, given that those neighbouring authorities will justifiably prioritise meeting their own housing requirements. This suggests that there is good reason to front-load the proportion of new homes delivered within the Black Country Plan area, where there is evidence that sites are available and deliverable.

Brades Road is potentially available in the shorter-term, and earlier delivery than 2032-2033 is possible.