The intention of the ‘flexible’ policy SEC4 is welcome, but the stringent conditions controlling housing or other developments in Clause 1b will prevent desirable redevelopment in many cases. In contrast employment development (Clause 1a) will be supported without specific controls. This will perpetuate unsatisfactory employment uses in residential areas, while preventing housing or other developments that may improve residential amenity, reduce traffic problems etc. There is a need for low cost premises, but a journey through the Borough presents a dispiriting picture of marginal businesses in tatty premises which does not fit with the bold aims set out in the Local Plan’s vision for 2041.
An example is Castle St, High St Tipton (site 2942). This highly visible site on a busy through route generates pavement parking; parking would be an issue for the proposed cycle routes on High Street and Castle Street. The site comprises an unsightly, complex, mix of poor-quality units: some vacant, in different ownerships and let to a changing array of occupiers. Non-industrial units include a taxi firm, gym, snooker club, playcentre and the occasional cannabis farm. Redevelopment could improve the amenity of neighbouring housing, improve the setting of a listed building, and address parking problems. The conditions listed in clause 2 make it unlikely that a private investor will risk the complex, costly and long-term process of land assembly. In reality, nothing is likely to happen on complex sites without a public sector programme of comprehensive redevelopments as mentioned in Policy SEC1.4
The policy should contain a clause favouring developments (1a and 1b) which demonstrate a positive impact on the wider local environment, economy and climate change mitigation..

Policy SDS1/Para 3.13.

West Midlands CPRE objects to the housing supply figure give in Policy SDS 1, 1a. We consider the figure to be too low.

We consider further work should be undertaken to ensure the Regulation 19 Plan includes takes account of higher potential brownfield capacity.

In particular we consider the level of windfall development should be higher. This includes at least 484 more small windfalls and a calculation of large windfall sites, consistent with the evidence both quantitative and qualitative that supports this.

This approach should take account in particular of both the potential for additional housing in centres through redevelopment or mixed development (as supported by Policy SCE1 Para 6) as well as the expectation that some further industrial land will come forward on sites which are currently unavailable (As envisaged in Policy SEC4). The windfall approach is suitable because these opportunities cannot be exactly predicted.

Policy SDS6

WM CPRE support the Policy to protect the Green Belt within Sandwell, including the very important asset of the Sandwell Valley.

Policy SDS7

The policy should be strengthened to exclude solar arrays and other energy related developments on any Green Belt or other agricultural land or other green space. The only right place for solar panels is on roofs and brownfield land, such as above car parks. See CPRE report on this subject (attached).

WM CPRE support the Policy to protect Green and Blue infrastructure, including the very important asset of the Sandwell Valley and the key wildlife, nature and amenity assets which stretch out and link with the countryside in Walsall, Birmingham and further afield. We are not in a position to comment in detail on the SNE policies to protect nature and heritage in the Borough but generally consider that protection should be of the highest order.

Policy SHO1

Policy SHO1 set outs the current supply of housing and this should be reviewed in line with our objections to Policy SDS 1.

We attach the report we commissioned on housing calculations to support this objection.

Policy SHO2

WM CPRE generally support Policy SHO2 on Windfall sites. However, it should refer to both large and small windfall sites.

Policy SHO3

WM CPRE generally support Policy SHO3 on Densities, and consider the standards set out in Para 3 appropriate. We think the Policy should also require developers to show that they have sought to make the most efficient use of land within a sustainable design approach, as some densities may comfortably be higher than these minima.

Policy SHO4

While it is in accordance with the current government guidance, the threshold of 10 houses before affordable provision is required is too low. With a 25% affordable target, a development of 12 houses will provide 3 affordable ones, but one of 8 or 9 will provide zero. This provides a perverse incentive for developers to bring forward developments of 9 dwellings, even if the land has capacity for (say 11).

Furthermore, a target of 25% is low. About 15 years ago Birmingham gave evidence at the Longbridge Area Action Plan EiP that they were achieving 40% affordable, as long as a proportion were of intermediate tenures. Most neighbouring councils have a higher target, often 35%, but with the ability to accept a lower proportion where a brownfield site requires high expenditure on site preparation.

Policy SEC4

WM CPRE generally supports the reallocation of employment land for housing where the land is not needed for employment use and there is a good case for doing so.

Policy SCE1

WM CPRE supports the aspiration for more mixed used / redevelopment for housing in town centres.

The lack of any policy in the plan on energy

We have failed to find any policy in the plan on energy generation, particularly where it is (and is not) appropriate to locate large solar arrays. It is our view that the right place for this is on rooftops and brownfield land, not on green field and certainly not on Green Belt land. The plan should contain a policy to this effect. See CPRE Rooftop Revolution Report (attached) on this subject.

Proposed development sites crossed or in close proximity to NGET assets:

Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to NGET assets. Details of the sites affecting NGET assets are provided below.

Development Plan Document Site Reference
SEC1-9 Roway Lane, Oldbury - VT ROUTE TWR (019 - 036): 400Kv Overhead Transmission Line route: KITWELL - OCKER HILL

SEC1-7 Site of Bilport Lane, Wednesbury - VT ROUTE TWR (001A - 016): 400Kv

SM2 (SA-199) Lion Farm, Oldbury - YJ ROUTE: 275Kv Overhead Transmission Line route: KITWELL - OCKER HILL 275Kv Underground Cable route: KITWELL 275KV S/S

70-74 Crankhall Lane - VT ROUTE TWR (001A - 016): 400Kv Overhead Transmission Line route: BERKSWELL - OCKER HILL

A plan showing details of the site locations and details of NGET assets is attached to this letter. Please note that this plan is illustrative only.

Without appropriate acknowledgement of the NGET assets present within the site, these policies should not be considered effective as they cannot be delivered as proposed; unencumbered by the constraints posed by the presence of NGET infrastructure.

We propose modifications to the above site allocations and/or policies to include wording to the following effect:

SEC1-9 Roway Lane, Oldbury
“The development will be developed with the following site-specific criteria.

A strategy for responding to the NGET overhead transmission lines present within the site which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”

Please see attached information outlining further guidance on development close to NGET assets.

NGET also provides information in relation to its assets at the website below.

• https://www.nationalgrid.com/electricity-transmission/network-and-infrastructure/network-route-maps

Utilities Design Guidance

The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET infrastructure.

NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.

Therefore, to ensure that Policy SDS1 Development Strategy is consistent with national policy we would request the inclusion of a policy strand such as:

“p. take a comprehensive and co-ordinated approach to development including respecting existing site constraints including utilities situated within sites.”

Further Advice

NGET is happy to provide advice and guidance to the Council concerning their networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.