Sandwell Local Plan - Reg 19 Publication

Policy SDS1 (and SHO1) plan only for at least 10,434 net dwellings, which is far short of Sandwell's need by a massive 15,916 dwellings. We have not investigated the underlying data to these figures but are shocked by them. The implication is that Sandwell needs to export 15,916 dwellings beyond its boundary, but there is no obvious local destination for these exports:
* Dudley has recently launched a reg.19 consultation, claiming to have housing need 766 in excess of its capacity.
* South Staffordshire equally lacks capacity, and transport links from there to Sandwell are poor.
* Wolverhampton's last consultation similarly showed a deficit.
* The situation is no better in Worcestershire.
On the other hand, there may be scope for exporting housing demand to Telfo9rd or Shropshire, but these are not close to the Black Country

The remainder of this objection is concerned with showing that Bromsgrove district is not an appropriate destination for exported housing (or employment land) need:
Green Belt
Substantially the whole of the undeveloped land in Bromsgrove district is Green Belt. It serves to keep Birmingham and the Black Country separate from the town of Bromsgrove and from the large commuter villages within Bromsgrove District, particularly Hagley, Catshill, Barnt Green, Alvechurch and Wythall, all of which have populations great enough for them to be classified as market towns in more rural regions. The two remaining larger settlements within Bromsgrove District (Cofton Hackett and Rubery) are contiguous to Birmingham and so have no Green Belt gap between them and Birmingham.

Regional Park
National Trust are developing the concept of a Seven Hills Regional Park, stretching from Wychbury Hill in Hagley to Weatheroak Hill in Alvechurch. I am led to believe that this is supported by Bromsgrove District Council and so expected it to be referred to in their plan, which I now expect to be consulted on in the autumn. This is an area of valued landscape. Part (at least) of it was formerly designated as a Landscape Protection Area (or such like) under planning policy of the 1990s. I therefore anticipate that the emerging Bromsgrove Plan will make some provision for its protection.

Landscape
CPRE Worcestershire commissioned research into part of the area (Clent and Lickey Hills), which provided recommendations for areas suitable to be designated as protected landscapes and additional areas to be designated as buffers to protect these. A full version of the report can be downloaded from https://www.dropbox.com/sh/cu97th78lzka8oy/AAB8UK4FAaeXU-Ttjpic0C7la?dl=0
Observed from the south, this is a range of hills, but from the north, the elevation above the surrounding area is rather less, because Birmingham and the Black Country occupy a plateau. It is nevertheless undesirable that Birmingham should expand to penetrate the range of hills.
Land supply

Bromsgrove’s last plan was adopted with an explicit policy for a Green Belt Review to provide more land to meet its own housing land supply need. Such a review has not been completed, partly due to difficulties in obtaining evidence on subjects for which Worcestershire County Council was responsible and partly because Redditch’s plan (examined and adopted at the same time) estimated a housing need considerably in excess of the need estimated under the Standard Methodology. This meant that land on the edge of Redditch released by Bromsgrove from its Green Belt for the alleged needs of Redditch was not needed for them and could instead supply Bromsgrove’s own needs. It nevertheless remains the case that Bromsgrove has scope to meet part of Birmingham’s land deficit.

4.86 It would be useful if the date of the West Midlands Structure Plan that designated RHSOS could be inserted, as this would add to the clarity of the paragraph. That this has been a longstanding designation adds weight to its importance. Its origin was clearly before 1988, making this an unusually old designation.

We welcome the target being expressed as “at least” 10,064 houses in SDS.1a. CPRE strongly supports the urban regeneration and the reuse of brownfield sites for housing, such as redundant employment sites, and more mixed-use developments with housing included. This is the most sustainable option and provides houses where they are needed for the people who need them most. This includes windfall sites, which result from the development ‘churn’ in large urban areas, which is often under-estimated. We do not have the capacity to examine the housing supply figures in detail but we suspect that there is more capacity that can be found from redundant space in town centres and by the release of redundant small industrial sites for housing, particularly in areas where this is a non-conforming use.

We are however concerned at the enormous amount of housing and employment land that Sandwell plans to export to other areas. It is difficult to see where such need might be met. Birmingham appears to have about enough land for its own needs; Dudley not quite enough. Wolverhampton and Walsall also have difficulties in meeting their own needs. South Staffordshire has submitted a plan that provides very limited amounts of land for others' needs, and the parts of that district near the Black Country are all within the Green Belt (other than built up areas). Similarly undeveloped land in the nearest Worcestershire districts are within the Green Belt. On the other hand, Shropshire and Telford seem to be planning for considerably more housing than their Objectively Assessed Need, but this is all a long way from Sandwell.

This can be corrected by substituting “Foundry” for “Factory” and 1795-8 for 1761.

There is a factual inaccuracy in paragraph 37 (p.17). This confuses the Soho Factory (1761) in Handsworth (now in Birmingham) with the Soho Foundry (and engine manufactory) at Smethwick, built in 1795-8, when the patents under which Boulton and Watt operated were on the point of expiring: see G. Demidowicz, "The Soho Manufactory, Mint and Foundry: where Boulton, Watt, and Murdoch made history" (English Heritage 2022). This can be corrected by substituting “Foundry” for “Factory” and 1795-8 for 1761. When this is referred to again at 3.50, the nomenclature is correct.

Paragraph 7.45 quotes data from the housing register, but this dataset has a bias towards those seeking smaller rented properties to avoid the so-called “bedroom tax”. This is probably not a representative sample of the whole population. This bias should be explained in the supporting text, so that excessive reliance is not placed on data from an unrepresentative sample.

We welcome the retention of the current Green Belt (SDS.1h and
SDS7). Sandwell has very small amounts of this, but it is important to preserve what little there is preserved. The Sandwell valley keeps separate the towns of West Bromwich and Wednesbury from Handsworth and Hamstead, mostly in Birmingham. Other areas of Green Belt are hill summits, which inevitably have an important landscape function. Others are used as Nature Reserves or for sporting facilities, whose preservation is important for other reasons, including geological interest. We note that there are more specific policies as to the Sandwell Valley and Rowley Hills later in the plan: a cross-reference to these would be useful.

SCC1 is expressed in general terms, which probably encompass the following, but specific encouragement for the use of rooftop photovoltaic cells, ground source heat pumps and such like would be welcome, perhaps in the accompanying narrative, rather than in the policy itself. This also applies to SCC2 and SCC3.

SDS6.6b We are a little concerned that this may open the door to some undesirable proposals that would lose valuable cultural facilities (such as churches and community centres). If they are indeed redundant, they should be redeveloped, but if they are or can be used for their existing purpose or a similar one, this should be supported in preference to (say) redevelopment for housing, which some developer might argue to provide community benefit in dealing with the housing shortage. We would hope that the other paragraphs of SDS6.6 would provide a means of refusing inappropriate proposals, but remain worried and would prefer to see something more explicit.

SCE Policies
• SCE1/Table 12 The inclusion of a Hagley Road West (at Hollybush), Abbey Road as local centres is justified, but since these appear to be newly identified, there should be a paragraph justifying this.
• It would also be helpful if there were detailed plans showing the boundaries of the various tier 3 centres, not just tiers 1 and 2.
• We support the objectives of paragraphs 9.20-21. We have probably reached peak in-person retail, as on-line becomes more important. The time for LPAs to plan for increased retail areas has therefore ended. If anything, the Council should be planning for retail decline and ensuring that vacant space can be used for alternative purposes.
• We are concerned that the Centres uses (except at West Bromwich) do not seem to include the possibility of residential development above or behind premises with Class E or other centres uses. A study (Chilmark) for another part of the Black Country suggested that there was significant potential capacity for residential use within centres, without compromising their primary role, also where retail decline leads to vacant space.

SCC5.6a.iii The word easement is being misused. The word refers to a right over another person’s ground for a way, to lay a pipe, etc. What seems to be intended is that there should be a suitable margin alongside the culvert. The subject matter seems to be culverted natural watercourse which run as a matter of right, not by virtue of any person having an easement.