Draft Black Country Plan

Support

Representation ID: 23422

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

Draft Policy HOU3 (Delivering Affordable, Wheelchair Accessible and Self Build/Custom Build Housing) states that all developments of ten homes or more should provide a proportion of affordable housing, where this is financially viable. The minimum proportion of affordable housing that should be provided is 20% affordable housing on greenfield sites in medium value zones (where the Site is located). Further, Part 3 of Draft Policy HOU3 advises that the tenure and type of affordable homes sought will be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support this policy and the collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.

7.12 With regard to National Wheelchair Accessibility Standards, Part 4 of Draft Policy HOU3 requires 15% of homes on greenbelt sites in medium or higher value zones to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings. L&Q Estates are supportive of this approach and consider that such requirements can be met on the Yieldfields site.

7.13 With regard to Self-Build and Custom Build plots, Part 6 of Draft Policy HOU3 states that on developments of 100 homes or more, where there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located, at least 5% of plots should be made available for self-build or custom build, or sufficient to match the current number on the register if lower. We support this policy, which aligns with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. Further, Part 6 goes on to state that any plots that have not been sold after 12 months of appropriate marketing will revert to the developer to build. L&Q Estates consider that Yieldfields can deliver 5% self-build and custom build plots. However, we strongly support the fall-back option of reverting any unsold self-build plots to the developer to build should any of these plots not be sold

Support

Representation ID: 23423

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

7.14 Draft Policy HOU5 states that where a housing development of ten or more homes would increase the need for education facilities to the extent that new or improved facilities would be required to meet this need, planning obligations or Community Infrastructure Levy will be secured sufficient to meet the need, where this is financially viable. For strategic allocations, the likely requirement for on-site provision of new schools is set out in Chapter 13. Accordingly, Draft Policy WSA4 (Yieldfields Farm) (contained in Chapter 13) sets out that Yieldfields could deliver a new on-site primary school, in addition to a contribution to improvements for secondary school provision in North Bloxwich.

7.15 We support Draft Policy HOU5 and consider that Yieldfields could deliver a primary school to be positioned centrally within the site. The Vision Document demonstrates that the Site could also provide a significant amount of open space to include informal sports provision and children’s play areas.

7.16 In addition, the development would also make a financial contribution towards other local infrastructure, such as transport and secondary school provision. Therefore, we also support of Part 2 of Draft Policy HOU5, which states that where land is provided for a new school as part of a housing development, the financial contribution made by that development towards education facilities will be reduced accordingly.

7.17 Draft Part 4 of Policy HOU5 advises that new and redeveloped education facilities should include provision for wider community use of sports and other facilities where appropriate. Whilst we support the general requirements and intentions of Draft Part 4 of Policy HOU5, clarification is required in relation to whether this policy would apply if strategic allocations include provision for community use of sports and other facilities elsewhere within the site, but not necessarily as part of education facilities

Support

Representation ID: 23424

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

8.2 We are supportive of Draft Policy TRAN3 (Managing Transport Impacts of New Development), which is consistent with NPPF Paragraph 113, emphasising that Transport Assessments and Travel Plans produced by developers are essential to demonstrate that an acceptable level of accessibility and safety can be achieved using all modes of transport to, from and through the development.

Support

Representation ID: 23425

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

8.3 Draft Policy TRAN5 (Creating Coherent Networks for Cycling and Walking) also encourages new developments to create an environment that encourages sustainable travel via safe and direct links that connect to existing walking and cycling networks, in addition to public transport nodes and interchanges. We are supportive of this policy, as it accords with the requirements of Paragraph 110 of the NPPF, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users.

Comment

Representation ID: 23426

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

8.4 Draft Policy TRAN7 (Parking Management) identifies that the Black Country Authorities will ensure a consistent approach to maximum parking standards is enforced in new developments, as set out in supplementary planning documents. We are supportive of this policy in principle, however, the current parking standards in Walsall are set out within the Walsall Council Parking Strategy (which was adopted in 2008), and thus it is considered that this SPD should be updated to accord with the requirements of NPPF Paragraph 107 in terms of setting local parking standards. In addition, we consider that new parking standards should set out specific requirements for the provision for charging infrastructure for electric vehicles as part of developments. Draft Policy TRAN8 (Planning for Low Emission Vehicles) lacks clarity in this regard. Consequently, L&Q Estates seek clarification that new parking standards are being developed which will replace the Walsall Council Parking Strategy (2008) and would welcome the opportunity to consult on this, where appropriate.

Support

Representation ID: 23427

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.1 Policy ENV1 (Nature Conservation) emphasises that development within the Black Country will safeguard nature conservation by ensuring that locally designated nature conservation sites (Sites of Local Importance for Nature Conservation), important habitats and geological features are protected from development proposals that could negatively affect them. The Black Country Authorities have undertaken ecological surveys and Local Sites Assessment Reports for the strategic allocations, including Yieldfields. In addition, Aspect Ecology undertook an ecological survey of Yieldfields in 2019 (included at Appendix 6) and have undertaken a high-level review of the Local Sites Assessment survey. It should be noted that the Local Sites Assessment survey was undertaken just four months following the Aspect Ecology survey in 2019 and covers the southern-most part of the red line boundary surveyed by Aspect Ecology

1.1 Therefore, L&Q Estates are supportive of Policy ENV1 and consider that locally designated nature conservation sites and important habitats can be protected from the development proposals for Yieldfields, in accordance with the policy.

Support

Representation ID: 23428

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.5 L&Q Estates are supportive of Draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain), which requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information

Support

Representation ID: 23429

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.6 L&Q Estates are supportive of Draft Policy ENV4 for the provision, retention and protection of trees, woodlands and hedgerows. Part 3 of Draft Policy ENV4 advises that where removal of trees is unavoidable, replacement trees should be provided to compensate for their loss, on a minimum basis of three for one.

9.7 Part 6 of Draft Policy ENV4 states that all available data on extant tree cover and associated habitat will be considered when making decisions on the proposed loss of trees and woodland to accommodate infrastructure and other development proposals. In areas where evidence demonstrates that current levels of tree cover are low, proposals that incorporate additional tree planting, to increase existing levels of habitat and canopy cover, will be considered positively, as part of the wider contribution to biodiversity net gain. We are supportive of this pragmatic approach to loss of trees in the context of biodiversity net gain. However, it is considered that Part 6 of Draft Policy ENV4 conflicts with the aims of Part 3 within the same policy, which specifically requires replacement tree planting to compensate for any trees removed, as opposed to assessing the wider opportunities for biodiversity net gain. Therefore, further clarification is required in relation to which part of Draft Policy ENV4 would be applicable to strategic allocations, including the Site (Draft Policy WSA4).
9.8 Part 12 of Draft Policy ENV4 requires new tree planting to be included in all new residential developments, as street trees or as part of landscaping schemes. We support this requirement and can confirm that the development of Site would provide significant tree planting.

9.9 Part 13 of Draft Policy ENV4 requires new developments to make a minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site. Whilst it is important to ensure that development proposals include new tree planting, this cannot result in schemes becoming unviable. We would therefore recommend that Part 13 of Draft Policy ENV4 is amended to confirm that this contribution can be reduced subject to viability considerations or confirm that the Black Country Authorities would accept tree planting in an appropriate off-site location.

9.10 Part 24 of Draft Policy ENV4 identifies that there will be a presumption against the wholesale removal of hedgerows for development purposes, especially where ecological surveys have identified them to be species-rich and where they exist on previously undeveloped land. Whilst L&Q Estates appreciate the aims of this policy, it should be noted that some developments will require the loss of some hedgerows to gain access. As set out in the Vision Document (Appendix 2), access to the Site will be taken from the A34 Stafford Road. Map 3 of the Birmingham & Black Country Local Sites Assessment Report for the Site identifies that the Site’s western boundary along the A34 comprises hedgerow with trees. Where access to the Site and the associated visibility splays are required, some of this hedgerow will need to be removed. Given the access would not result in the wholesale removal of the hedgerow, it is considered that this would be in accordance with Part 24 of Draft Policy ENV4

Support

Representation ID: 23430

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.11 Draft Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) states that development proposals that would potentially have an impact on the significance of any designated heritage assets, including any contribution made by their setting, should be supported by evidence that the historic character and distinctiveness of the locality has been fully assessed and used to inform proposals. Clear and convincing justification should be provided, either in Design and Access Statements, Statements of Heritage Significance, or other appropriate reports. In some instances, local planning authorities will require developers to provide detailed Heritage Statements and/or Archaeological Desk-based Assessments to support their proposals.

9.12 We are supportive of Draft Policy ENV5, which accords with Paragraph 194 of the NPPF.

Support

Representation ID: 23431

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.17 Draft Policy ENV8 (Open Space, Sport and Recreation) advises that each local authority will set out, in their Local Plans and on Policies Maps, proposals for specific open space, sport and recreation facilities and planning requirements for open space, sport and recreation. We support this policy