Sandwell Local Plan - Reg 19 Publication
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Sandwell Local Plan - Reg 19 Publication
4. Sandwell's Natural and Historic Environment
Representation ID: 1350
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
The SHE polices generally are welcome, but we suspect we detect a lacuna: there should be a policy that historic buildings that can no longer fulfil their original function should, as a first preference be found a new use and converted to that. This may be implicit in the policies, but we would like to see something more explicit. The current policies may depend on a building appearing on the Local List. Our experience is that such lists are often somewhat deficient.
The SHE polices generally are welcome, but we suspect we detect a lacuna: there should be a policy that historic buildings that can no longer fulfil their original function should, as a first preference be found a new use and converted to that. This may be implicit in the policies, but we would like to see something more explicit. The current policies may depend on a building appearing on the Local List. Our experience is that such lists are often somewhat deficient.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SDS7 – Sandwell's Green Belt
Representation ID: 1351
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SDS7 We would like to see as more specific provision that arrays of solar panels on Green Belt land are unacceptable. Alternatively, that might be added to the more specific policies on the Sandwell Valley and Rowley Hills.
SDS7 We would like to see as more specific provision that arrays of solar panels on Green Belt land are unacceptable. Alternatively, that might be added to the more specific policies on the Sandwell Valley and Rowley Hills.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SDS4 – Towns and Local Areas
Representation ID: 1352
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SDS4.1a The figure of 474 houses seems too precise. In the light of the Chilmark study of Bilston suggesting under-identification of housing capacity, we would suggest the figure should be “at least 470”, in the hope that detailed planning can deliver more.
SDS4.1a The figure of 474 houses seems too precise. In the light of the Chilmark study of Bilston suggesting under-identification of housing capacity, we would suggest the figure should be “at least 470”, in the hope that detailed planning can deliver more.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SDS7 – Sandwell's Green Belt
Representation ID: 1353
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SDS7.4 Sandwell’s Green Belt (our preferred capitalisation) is limited in extent, which makes its preservation all the more important. We are concerned that the qualification of what buildings are suitable for conversion or reuse should only be a footnote (57). We would prefer to see an explicit statement that buildings such as timber stables, and sheds (barns, etc) which are steel-framed and covered in metal or other sheeting are not regarded as of substantial construction.
SDS7.4 Sandwell’s Green Belt (our preferred capitalisation) is limited in extent, which makes its preservation all the more important. We are concerned that the qualification of what buildings are suitable for conversion or reuse should only be a footnote (57). We would prefer to see an explicit statement that buildings such as timber stables, and sheds (barns, etc) which are steel-framed and covered in metal or other sheeting are not regarded as of substantial construction.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SHO4 - Affordable Housing
Representation ID: 1354
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHO4
• As with SHO3.2-3 thresholds of 10 homes give undesirable perverse incentives to developers to develop sites of 9 houses.
• The targets for affordable housing are very low. Evidence was given by Birmingham Council about 15 years ago that they were achieving 40% affordable housing. Subsequent experience suggests that this may be a little high, with 35% more deliverable, as long as a proportion of these are shared ownership. It is claimed there is a housing crisis in this country, but really the shortage is of houses to rent. There may need to be a lower target for some difficult sites, for example where significant remediation of polluted land is required. A better policy would be 35% on all sites with the ability for developers to negotiate this down for sites which would be unviable at that level. A threshold of 10 houses would be appropriate where the target is 10% affordable, but where it is 25% affordable the appropriate threshold is four and for 35% affordable three. Paras 7.25-7 seek to justify this policy, but they seem to contradict the HMA requirement of about 33% affordable (of various tenures).
SHO4
• As with SHO3.2-3 thresholds of 10 homes give undesirable perverse incentives to developers to develop sites of 9 houses.
• The targets for affordable housing are very low. Evidence was given by Birmingham Council about 15 years ago that they were achieving 40% affordable housing. Subsequent experience suggests that this may be a little high, with 35% more deliverable, as long as a proportion of these are shared ownership. It is claimed there is a housing crisis in this country, but really the shortage is of houses to rent. There may need to be a lower target for some difficult sites, for example where significant remediation of polluted land is required. A better policy would be 35% on all sites with the ability for developers to negotiate this down for sites which would be unviable at that level. A threshold of 10 houses would be appropriate where the target is 10% affordable, but where it is 25% affordable the appropriate threshold is four and for 35% affordable three. Paras 7.25-7 seek to justify this policy, but they seem to contradict the HMA requirement of about 33% affordable (of various tenures).
Support
Sandwell Local Plan - Reg 19 Publication
Policy SHO3 - Housing Density, Type and Accessibility
Representation ID: 1355
Received: 04/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHO3.5 is welcome. There needs to be scope for permitting some larger houses in modest numbers to meet the needs of large families, but this is probably covered by the inclusion of the word "disproportionate".
SHO3.5 is welcome. There needs to be scope for permitting some larger houses in modest numbers to meet the needs of large families, but this is probably covered by the inclusion of the word "disproportionate".
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SID2 – Digital Infrastructure
Representation ID: 1356
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SID2 High speed internet access is highly necessary for almost all premises. A mere statement of what will be available at first occupation should be inadequate. Proposals intending not to provide state-of-the-art access should be required to provide robust justification for not doing so, though there will be some buildings where this is obviously unnecessary. It is generally cheaper to provide this as part of construction than to retrofit it subsequently.
SID2 High speed internet access is highly necessary for almost all premises. A mere statement of what will be available at first occupation should be inadequate. Proposals intending not to provide state-of-the-art access should be required to provide robust justification for not doing so, though there will be some buildings where this is obviously unnecessary. It is generally cheaper to provide this as part of construction than to retrofit it subsequently.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SHW6 - Allotments
Representation ID: 1357
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHW6.2 In many urban areas, there are waiting lists for allotments. We do not know if this applies to Sandwell. We are therefore suspicious of the potential of paying a contribution in lieu of actual provision, which is liable to lead to the erosion of the area available for use as allotments.
SHW6.2 In many urban areas, there are waiting lists for allotments. We do not know if this applies to Sandwell. We are therefore suspicious of the potential of paying a contribution in lieu of actual provision, which is liable to lead to the erosion of the area available for use as allotments.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SHW4 – Open Space and Recreation
Representation ID: 1358
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHW4 We welcome the reference to unrestricted open space. However further provisions are desirable:
• Wherever possible open space should be land that can be used for some kind of recreation. Thus, land at road junctions that cannot be used because it is too close to roads is probably not suitable.
• We have come across cases where a developer of a large estate provides open space restricted to the residents of that estate, who are charged for its maintenance through a service charge. This should be unacceptable, because the residents will be paying twice of open space provision, both through their Council Tax and a service charge.
SHW4 We welcome the reference to unrestricted open space. However further provisions are desirable:
• Wherever possible open space should be land that can be used for some kind of recreation. Thus, land at road junctions that cannot be used because it is too close to roads is probably not suitable.
• We have come across cases where a developer of a large estate provides open space restricted to the residents of that estate, who are charged for its maintenance through a service charge. This should be unacceptable, because the residents will be paying twice of open space provision, both through their Council Tax and a service charge.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SHO9 – Accommodation for Gypsies, Travellers and Travelling Showpeople
Representation ID: 1359
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHO9 It is our view that Travellers (of all kinds) have as much right to a settled home as the settled community, no greater and no less. We have periodically been concerned in cases where the needs of a traveller are set against other policies such as Green Belt to imply that the Traveller is in a different (better) position to claim to be able to set up a home in the Green Belt. It is accordingly desirable that the principle of equality of right should be explicitly stated. This is necessary because new Travellers’ sites often start as development undertaken in breach of planning control, sometimes with development taking place over a long holiday weekend.
Para 7.77 refers to Table 9. We think Table 11 is meant.
SHO9 It is our view that Travellers (of all kinds) have as much right to a settled home as the settled community, no greater and no less. We have periodically been concerned in cases where the needs of a traveller are set against other policies such as Green Belt to imply that the Traveller is in a different (better) position to claim to be able to set up a home in the Green Belt. It is accordingly desirable that the principle of equality of right should be explicitly stated. This is necessary because new Travellers’ sites often start as development undertaken in breach of planning control, sometimes with development taking place over a long holiday weekend.
Para 7.77 refers to Table 9. We think Table 11 is meant.
