Preferred Options November 2021

Object

Representation ID: 1408

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

The Council should review the documents to ensure that they have been produced in line with, and make appropriate reference to NPPF (2021).

Duty to Cooperate Paper (2021)
South Staffs should take a greater share of the Birmingham and Black Countries unmet housing need. Recommending a contribution of 8,212 based on their analysis. SoCGs should be drafted now and updated regularly. Greater Birmingham HMA shortfall is likely to be larger than that stated by the evidence base.

Green Belt Review
Disagree with the findings presented by the Green Belt Review (2019) in relation to Lawnswood Road (site 654). Their own assessment shows that undertaken by FPCR concludes the site is between low and moderate harm.

Object

Representation ID: 1409

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

2b - Reference is made on page 12 of the IDP to the need for the Council to set out Green Belt loss compensatory measures including improvements to the environmental quality and accessibility of remaining Green Belt land. To provide certainty to developers the scope of requirements for compensatory enhancements should be set out clearly in the Infrastructure Delivery Plan and viability
appraisal.

Object

Representation ID: 1410

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support policy DS1 – Green Belt and in particular reference is made in the supporting text at paragraph 4.4 of the Local Plan to securing compensatory improvements following Green Belt release which relate to environmental quality and accessibility of remaining Green Belt.
The facilities should be identified and planned for and then included in an Infrastructure Delivery Plan. By providing a range of examples, the PPG is clear that these improvements could be wide ranging, and as such do not all need to relate to both environmental quality and accessibility of remaining Green Belt. PPG (Reference ID: 64-002-20190722).

Object

Representation ID: 1413

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support the policy approach in Policy DS3. Paragraph 4.16 of the supporting text to policy DS3 states that the spatial strategy has been amended since the last consultation in December 2019 to reduce the amount of growth allocated to the western edge of the Black Country, reflecting the relatively limited unmet need arising from Dudley. However, having reviewed the Black Country Local Plan evidence base, it is clear that the majority of Dudley’s Green Belt that is not proposed to be released for development has constraints present on it that prevents development, such as historic landscape designations. there is shortfall between the 4,000
figure stated to be provided to the GBHMA , and the 2,958 dwellings that are planned to be located adjacent to the Black Country. The allocation of more sites adjoining the Black Country, such as Lawnswood Road (site 654) would aid this. The spatial strategy should therefore be amended to place more emphasis on the delivery of dwellings adjoining the Black Country.

Object

Representation ID: 1414

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support the housing allocations in policy SA5 and consider that this policy should be amended to include land at Lawnswood Road (site 654). In Green Belt terms, the site should score “moderate” to “low / moderate”. The SA score for education should be changed to reflect that a primary school would be provided on site. The development could provide 600 - 700 homes. Taking all of this evidence into consideration, we conclude that land at Lawnswood Road is a suitable site to allocate and should be done so as it performs comparably as well as other sites.

Object

Representation ID: 1415

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support all of the proposed policy approaches set out in chapter 6. Further comments below:
HC1 - Housing Mix
Any figures for housing mixes should be quoted
in supporting text only, and not within the policy. The findings of the latest SHMA should be consider as indicative only, and housing mix considered on a site-by-site basis.
HC3 - Affordable Housing
We disagree with the proposed requirement for 50% of the affordable housing to be delivered in the
form of social rent. Paragraph 8.11 of the SHMA, clearly sets out a 50% requirement of the affordable housing provision to be both affordable rented and social rented. A distinction needs to be made between affordable and social rent, and this should be reflected in the policy.
HC9 - Design requirement
Disagree with the proposed requirement of Policy HC9 for all developments to incorporate tree lined streets. The wording should be that tree lined streets should be provided, unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate.
HC13 - Health and Wellbeing
To ensure that this requirement is not unduly onerous the Council should be clear what the basis of this requirement.
NB2 – Biodiversity
Until this requirement is formally enacted through secondary legislation, the chosen target would need to
be appropriately evidenced.
NB6
Any requirements above the Building Regulation standard would need to be robustly justified.

Support

Representation ID: 1416

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

HC7 - Self & Custom Build Housing
In general, we support the Council’s approach to self & custom build housing. As set out in our responses to previous consultation stages, we do not support self and custom build housing being required on allocated sites as a proportion of overall housing requirement.
C17 - Open Space
In relation to policy HC17, the consultation document propose to make it clear that small incidental
green infrastructure will not be counted towards on-site open space. This may be justified, but the Council should not overlook the benefits of such areas if appropriately planted and maintained can have for biodiversity.
EC10 - Developer contributions
Any contribution requests should be open to negotiation and based on CIL reg 122 (2) tests.
NB1 - Protecting, enhancing and expanding natural assets
There should be a clear hierarchy of land that the Council will consider for such uses. Land in the ownership of a willing landowner should be considered before other land where ownership issues are unresolved.