Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
Representation ID: 377
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.
No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.
Object
Black Country Core Strategy Issue and Option Report
Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
Representation ID: 378
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.
We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.
Support
Black Country Core Strategy Issue and Option Report
Question 43a - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
Representation ID: 379
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.
Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.
Support
Black Country Core Strategy Issue and Option Report
Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any Further comments.
Representation ID: 380
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
Yes, we agree that the figure should be retained at 25%, subject to viability.
Yes, we agree that the figure should be retained at 25%, subject to viability.
Object
Black Country Core Strategy Issue and Option Report
Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
Representation ID: 381
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.
The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.
Object
Black Country Core Strategy Issue and Option Report
Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing devel
Representation ID: 382
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. I
We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investment market ready to provide the product. It does not need to be funded from contributions from residential development.
Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.
In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.
Object
Black Country Core Strategy Issue and Option Report
Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
Representation ID: 383
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.
We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.
Support
Black Country Core Strategy Issue and Option Report
Question 50a - Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
Representation ID: 384
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.
We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.
Object
Black Country Core Strategy Issue and Option Report
Question 55 - Do you agree with the proposal to retain Policy EMP5? Yes/No; If no please explain why.
Representation ID: 385
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.
Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.
Object
Black Country Core Strategy Issue and Option Report
Question 94 - Do you support the proposed changes relating to environmental infrastructure and place-making? Yes/No; If you think that any other changes should be made to Policies CSP3 or CSP4, please
Representation ID: 386
Received: 07/09/2017
Respondent: Clowes Developments
Agent: Harris Lamb
We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.
We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.
