Sandwell Local Plan - Reg 19 Publication
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Sandwell Local Plan - Reg 19 Publication
Policy SHO6 - Protecting Family Housing (Use Class C3)
Representation ID: 1360
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SHO6 The target of this policy is unclear: it appears to be about the division of houses into self-contained apartments; conversion to HMOs is dealt with in SHO7 and all provisions as to houses becoming HMOs should appear there.
• There will be family homes occupying large plots where demolition and redevelopment with a greater density is desirable, as a means of meeting the shortfall in housing land supply. Such developments will probably constitute windfalls.
• SHO6.1c may allow this but is expressed in a convoluted and obscure manner. It would be better if the policy were explicitly that a family home can be lost if the site is intended for redevelopment to provide a greater number of homes, of types and tenures provided for by other policies.
SHO6 The target of this policy is unclear: it appears to be about the division of houses into self-contained apartments; conversion to HMOs is dealt with in SHO7 and all provisions as to houses becoming HMOs should appear there.
• There will be family homes occupying large plots where demolition and redevelopment with a greater density is desirable, as a means of meeting the shortfall in housing land supply. Such developments will probably constitute windfalls.
• SHO6.1c may allow this but is expressed in a convoluted and obscure manner. It would be better if the policy were explicitly that a family home can be lost if the site is intended for redevelopment to provide a greater number of homes, of types and tenures provided for by other policies.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SNE6 – Canals
Representation ID: 1361
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SNE6.4-6 The thrust of this policy is welcome, but we wonder if it is so wide-ranging as to be over-restrictive on developers. Some factories formerly had a private canal arm, providing access from it to the canal network. These have often been filled in or otherwise removed, long since during previous redevelopment. We wonder if such need preservation, rather than being archaeologically recorded under SHE1.6 (as a non-designated heritage asset) during the development process.
SNE6.4-6 The thrust of this policy is welcome, but we wonder if it is so wide-ranging as to be over-restrictive on developers. Some factories formerly had a private canal arm, providing access from it to the canal network. These have often been filled in or otherwise removed, long since during previous redevelopment. We wonder if such need preservation, rather than being archaeologically recorded under SHE1.6 (as a non-designated heritage asset) during the development process.
In some cases, a term will be defined in the document, in which case the glossary can refer to the policy or paragraph defining it, rather than repeating the definition. In others, the definition may be in NPPF or elsewhere, in which case the definition should probably be copied, but giving a cross-reference to the source.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SNE1 – Nature Conservation
Representation ID: 1362
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SNE1.5 The policy should be amended to require enhancements to wildlife corridors, for example by improving their connectivity, rather than merely prohibiting development from impeding them. This may be limited to sites lying in proximity to wildlife corridors and other such sites.
SNE1.5 The policy should be amended to require enhancements to wildlife corridors, for example by improving their connectivity, rather than merely prohibiting development from impeding them. This may be limited to sites lying in proximity to wildlife corridors and other such sites.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SMI2 - Managing the Effects of Mineral Development
Representation ID: 1363
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SMI2.3 The “consideration zones around Coneygre and Blackham mines” appears to be an unexplained term. We suspect this refers to underground limestone workings. We heard many years ago of a case of subsidence which was due to the failure of 5 pillars in one of these mines, but the policy at present seems to lack justification within the Plan and an appropriate explanation is needed, together with a definition or explanation of the Consideration Zone. We note the name Blackham appears nowhere else in the Plan and Coneygre only in one other place, referring to an industrial estate, possibly the one where the pillars failed. If what we suspect is correct, this is a case of unstable land, which might be better dealt with as part of SCO3.
The solution to this issue is probably to cite some external document (which should be included in supporting evidence), explaining the issue. This is no doubt familiar to Sandwell planners and the current landowner, but probably not to the public generally.
SMI2.3 The “consideration zones around Coneygre and Blackham mines” appears to be an unexplained term. We suspect this refers to underground limestone workings. We heard many years ago of a case of subsidence which was due to the failure of 5 pillars in one of these mines, but the policy at present seems to lack justification within the Plan and an appropriate explanation is needed, together with a definition or explanation of the Consideration Zone. We note the name Blackham appears nowhere else in the Plan and Coneygre only in one other place, referring to an industrial estate, possibly the one where the pillars failed. If what we suspect is correct, this is a case of unstable land, which might be better dealt with as part of SCO3.
The solution to this issue is probably to cite some external document (which should be included in supporting evidence), explaining the issue. This is no doubt familiar to Sandwell planners and the current landowner, but probably not to the public generally.
Comment
Sandwell Local Plan - Reg 19 Publication
Policy SMI1 - Minerals Safeguarding
Representation ID: 1364
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
SMI1 is fine in theory, but there are no mineral extraction sites. Unless some new economically important mineral is discovered, it seems unlikely that any will take place in future. This reflects the extent to which coal, iron ore and fireclay were worked up to the 20th century, with mines in the core of the coalfield being abandoned in about 1905 when the South Staffordshire Mine Drainage Commission was unable to keep the mines free of water. This means that the requirement of a mineral safeguarding statement for sites over 5 ha is a piece of pointless bureaucracy. There have been cases where extracting pillars of thick coal by open cast mining and then refilling the resultant hole were economically viable, but with the move away from coal as an energy source and the quashing of the planning permission for the West Cumbria Coal Mine, the possibility of working any remaining coal seems remote. Accordingly, we would question the requirement for mineral safeguarding statements for any site.
SMI1 is fine in theory, but there are no mineral extraction sites. Unless some new economically important mineral is discovered, it seems unlikely that any will take place in future. This reflects the extent to which coal, iron ore and fireclay were worked up to the 20th century, with mines in the core of the coalfield being abandoned in about 1905 when the South Staffordshire Mine Drainage Commission was unable to keep the mines free of water. This means that the requirement of a mineral safeguarding statement for sites over 5 ha is a piece of pointless bureaucracy. There have been cases where extracting pillars of thick coal by open cast mining and then refilling the resultant hole were economically viable, but with the move away from coal as an energy source and the quashing of the planning permission for the West Cumbria Coal Mine, the possibility of working any remaining coal seems remote. Accordingly, we would question the requirement for mineral safeguarding statements for any site.
Comment
Sandwell Local Plan - Reg 19 Publication
APPENDIX O – Glossary
Representation ID: 1367
Received: 05/11/2024
Respondent: Campaign to Protect Rural England West Midlands Group
The Plan lacks the glossary, usually found in such plans. In the course of the Plan many technical planning terms are used. Some derive from the Plan itself; others from NPPF or wider planning practice. The Plan is intended to be usable by those of the general public who wish to make or object to planning applications. It is therefore important that the Plan should contain a glossary, so that members of the public can understand the terms used.
In some cases, a term will be defined in the document, in which case the glossary can refer to the policy or paragraph defining it, rather than repeating the definition. In others, the definition may be in NPPF or elsewhere, in which case the definition should probably be copied, but giving a cross-reference to the source.
The Plan lacks the glossary, usually found in such plans. In the course of the Plan many technical planning terms are used. Some derive from the Plan itself; others from NPPF or wider planning practice. The Plan is intended to be usable by those of the general public who wish to make or object to planning applications. It is therefore important that the Plan should contain a glossary, so that members of the public can understand the terms used.
In some cases, a term will be defined in the document, in which case the glossary can refer to the policy or paragraph defining it, rather than repeating the definition. In others, the definition may be in NPPF or elsewhere, in which case the definition should probably be copied, but giving a cross-reference to the source.
