Draft Regulation 18 Sandwell Local Plan
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Draft Regulation 18 Sandwell Local Plan
Policy SDS1 – Development Strategy
Representation ID: 889
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SDS6 – Sandwell's Green Belt
Representation ID: 890
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
Policy SDS6
WM CPRE support the Policy to protect the Green Belt within Sandwell, including the very important asset of the Sandwell Valley.
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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SDS7 - Green and Blue Infrastructure in Sandwell
Representation ID: 891
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Object
Draft Regulation 18 Sandwell Local Plan
Policy SHO1 - Delivering Sustainable Housing Growth
Representation ID: 892
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SHO2 – Windfall developments
Representation ID: 893
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
Policy SHO2
WM CPRE generally support Policy SHO2 on Windfall sites. However, it should refer to both large and small windfall sites.
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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SHO3 - Housing Density, Type and Accessibility
Representation ID: 894
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Object
Draft Regulation 18 Sandwell Local Plan
Policy SHO4 - Affordable Housing
Representation ID: 895
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SEC4 – Other Employment Sites
Representation ID: 896
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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 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.
Support
Draft Regulation 18 Sandwell Local Plan
Policy SCE1 - Sandwell's Centres
Representation ID: 897
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
Policy SCE1
WM CPRE supports the aspiration for more mixed used / redevelopment for housing in town centres.
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.
Comment
Draft Regulation 18 Sandwell Local Plan
1. Sandwell 2041: Spatial Vision, Priorities and Objectives
Representation ID: 898
Received: 18/12/2023
Respondent: Campaign to Protect Rural England West Midlands Group
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.
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.