Draft Regulation 18 Sandwell Local Plan

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Draft Regulation 18 Sandwell Local Plan

1. Sandwell 2041: Spatial Vision, Priorities and Objectives

Representation ID: 828

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

2.0 Objective 7 of the Housing that meets all our needs priority, is to ensure that communities in Sandwell are safe and resilient. This objective is supported.

Comment

Draft Regulation 18 Sandwell Local Plan

1. Sandwell 2041: Spatial Vision, Priorities and Objectives

Representation ID: 829

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

2.0 Objective 6 as part of the Housing that meets all our needs priority, seeks to address Sandwell’s identified and wide-ranging housing need by supporting the provision of high-quality new homes with a wide mix of housing types and tenure that: meet the needs of current and future residents; provide sufficient internal and external space; and support climate change adaption through good design. Objective 6 needs to be explicit that for the achievement of this objective clear housing requirements needs to be articulated, to set a baseline for the housing need that it is planned to be met over the plan period.

2.1 The local authority should have a clear understanding of the land available within their area through the preparation of a strategic housing land availability assessment. Planning policies should then identify a sufficient supple and mix of sites, considering their availability, suitability, and likely economic viability. Objective 6 should explicitly commit to meeting this obligation of identifying sufficient land for homes.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SDS1 – Development Strategy

Representation ID: 830

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

Policy SDS1 should be clear on how the projected provision for net additional homes is arrived at, and what provisions will be taken to ensure that delivery matches projected requirements.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SDS2 – Regeneration in Sandwell

Representation ID: 831

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

3.0 Regeneration Areas as set out within policy SDS2 are the stated focus for new development, regeneration and public and the encouragement of private investment. Subsection 3(e) states that at least 2,581 new homes of mixed type and tenure are to be delivered in the regeneration areas; in sustainable locations well- supported by community services. Sandwell currently has a significant shortfall in housing delivery against Government requirements. It is highly likely that a component of any solution addressing the current housing shortfall will be higher density residential development on brownfield land included within in the identified Regeneration Areas.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SDS4 - Achieving Well-designed Places

Representation ID: 832

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

The Sandwell Local Plan discusses that well-designed places should accord with the latest National Planning Guidance and other material considerations. Point 9 of the policy states that a design code will be produced for Sandwell which shall reflect local character and design preferences, providing a framework for creating high-quality places. This approach is supported and in accordance with National Design Guide and National Model Design Code, provided that it incorporates the requisite flexibility necessary to address local market conditions and the impact that these have on development values.

Support

Draft Regulation 18 Sandwell Local Plan

Policy SNE2 – Protection and Enhancement of Wildlife Habitats

Representation ID: 833

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

Paragraph 8 (c) of the Framework refers to improving biodiversity and paragraph 174 (d) to providing net gains for biodiversity. Draft policy SNE2(1) states that

‘All development proposals in Sandwell shall deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. Where achievable, a higher net gain may be agreed. Losses and gains will be calculated using the extant national Biodiversity Metric…’

Vulcan agrees with policy SNE2 and reflecting the forthcoming mandatory requirement for a minimum 10% biodiversity net gain across all major development.

Object

Draft Regulation 18 Sandwell Local Plan

Policy SNE3 – Provision, Retention and Protection of Trees, Woodlands and Hedgerows

Representation ID: 834

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

Policy SNE1 (11) includes a blanket statement that

‘Development should be designed around the need to incorporate trees already present on site, using sensitive and well-designed site layouts to maximise their retention’.

There should be acknowledgement that there will not be the justification for the retention of some trees, particularly in the context of poor specimens and wider development benefit. The policy text should be consistent with the Framework (2023), which says planning policies should ensure ‘…that existing trees are retained wherever possible’ (paragraph 131).

The policy also sets out at SNE1 (9) that
‘…tree planting on new development sites should make a minimum contribution of 20% canopy cover and a recommended contribution of 30% canopy cover across the site, especially in areas where evidence demonstrates that current levels of canopy cover are lower than the local average.’

It is noted that this is based upon the Emergency Tree Plan for the UK – The Woodland Trust 2020 but there is no basis in the Framework (2023) or Planning Practice Guidance for the introduction of blanket thresholds for canopy cover.
The same observation is made in respect of SNE1 (18) and its requirement that

‘…removal of trees, suitable replacement trees must be provided onsite. Where sufficient suitable onsite replacements cannot be provided, off-site planting or woodland enhancement, including support for natural regeneration, in the near vicinity of the removed tree(s) must be provided, in line with the mitigation hierarchy set out in Policy SNE2.’
The requirement for replacement trees and the number to be provided should be the subject of site-by-site assessments, alongside a measured consideration of biodiversity net gain.

Support

Draft Regulation 18 Sandwell Local Plan

Policy SNE6 – Canals

Representation ID: 835

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

Policy SNE7 is positively written, and Vulcan supports the reference to the canal network being a focus for future development through its ability to deliver a high-quality environment and enhanced accessibility for pedestrians, cyclists, and other non-car-based modes of transport.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SNE6 – Canals

Representation ID: 836

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

Policy SNE6(d) refers to development proposals
‘…promoting high quality design, including active frontages onto the canal and improving the public realm...’.
The policy should acknowledge that such aspirations should be pursued where possible. Canalside development also offers the potential for waterfront views particularly from residential properties, and this should be stated in the context of seeking to achieve high-quality urban design and cross- referencing urban design policies.

Object

Draft Regulation 18 Sandwell Local Plan

Policy SCC1 – Increasing efficiency and resilience

Representation ID: 837

Received: 18/12/2023

Respondent: Vulcan Property II Limited

Agent: Vulcan Property II Limited

Representation Summary:

... To provide clarity for applicants, draft policy CC1 should include assessment criteria against which the local planning authority can determine whether a development compliant with its climate change and energy policies in the context of local requirements and site-specific circumstances.

Whilst the sentiment of maximising opportunity and minimising impact where possible is in the spirit of the guidance provided by the Framework, it does not make for a development plan policy that is easily applied to individual development proposals. The policy is arguably not sound in the absence of prescriptive, unambiguous assessment criteria.

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