Black Country Core Strategy Issue and Option Report

(16)3. The Strategic Challenges and Opportunities

3.1 This part of the Report summarises the key strategic challenges and opportunities that have arisen since the Core Strategy was adopted in 2011. These issues are the main reasons why a review is needed and they help explain the degree to which the existing Spatial strategy remains up to date and fit for purpose.

The strategic challenges and opportunities are expressed as a set of nine key issues:

Updating the evidence base

Meeting the housing needs of a growing population

Supporting a resurgent economy

Supporting strong and competitive centres

Protecting and enhancing the environment

Reviewing the role and extent of the green belt

Keeping the Black Country connected

Providing infrastructure to support growth

Working effectively with neighbours

(10)Key Issue 1 – Updating the evidence base

3.2 The Review must be based on up to date and robust evidence. The Core Strategy was adopted five years ago, and the evidence on which it was based is older. Some of this evidence will be relevant to this review and can continue to be relied upon to support policies that can be carried forward. However other parts of the evidence base are out-of-date or have been superseded by changes in circumstance or national policy.

3.3 A range of detailed evidence will be used which has been prepared to support the preparation of Local Plan documents and completed following the adoption of the Core Strategy including viability evidence and delivery plans. Up-to-date Strategic Housing Land Availability Assessments (SHLAAs) and Annual Monitoring Reports are also available for each authority.

3.4 To make sure land is used efficiently without harming important environmental and other assets, or placing existing or future residents at risk, it is important to map assets and constraints that affect development. These include factors such as flood risk, nature conservation designations and heritage assets.

3.5 The key pieces of evidence considered necessary to support the review are listed in Table 1, with the sequencing supporting the overall review programme. Some of these studies will be completed in stages and it may also be necessary to refresh elements in the light of new information and specific issues raised through the consultations and Plan preparation stages.

3.6 Key strategic evidence has already been completed to inform this consultation report, including the Strategic Housing Market Assessment (SHMA), which establishes the local housing need for the area, and Stage 1 of the Economic Development Needs Assessment (EDNA), which establishes the supply and demand for employment land.

3.7 All current evidence is available through the Core Strategy website: www.blackcountrycorestrategy.dudley.gov.uk and the key findings are summarised in the context of the Key Issues they relate to below.

Table 1 Evidence Base for the Black Country Core Strategy Review

Issue	Evidence	Programming	Status
Housing	Greater Birmingham and Solihull LEP / Black Country Authorities Strategic Housing Needs Study (SHNS) Stage 3 Report (PBA)	To inform Issues and Options Report	Completed August 2015
	Strategic Housing Market Assessment for Black Country and South Staffordshire including Gypsy and Traveller needs (PBA)	To inform Issues and Options Report	Completed February 2017
	Strategic Housing Land Availability Assessments for Dudley, Sandwell, Walsall and Wolverhampton (Local authorities)	To inform Issues and Options Report but to be updated as the Plan progresses.	Completed 2016/17
	Housing Background Report (Local authorities)	To inform Issues and Options Report	Completed May 2017
Employment	West Midlands Strategic Employment Sites Study (PBA/JLL)	To inform Issues and Options Report	Completed 2015
	Black Country and South Staffordshire sub-regional High Quality Employment Land Study (WECD)	To inform Issues and Options Report	Completed 2015
	Black Country and Southern Staffordshire Regional Logistics Sites Study (URS)	To inform Issues and Options Report	Completed 2013
	Black Country Strategic Economic Plan (SEP)	To inform Issues and Options Report	Completed 2014 / Draft Refresh 2017
	West Midlands Combined Authority Strategic Economic Plan (SEP)	To inform Issues and Options Report	Completed 2016
	Black Country Economic Development Needs Assessment (WECD)	Stage 1 to inform Issues and Options Report. Stage 2 to inform Preferred Spatial Option Report	Stage 1 Completed February 2017
Strategic Growth / Green Belt	Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study	To inform Black Country and South Staffordshire Green Belt Study and Preferred Spatial Option Report	Commenced March 2017 To be completed September 2017
	Black Country Green Belt Review (see Key Issue 6)	To inform Preferred Spatial Option Report	Scoping underway To be completed mid 2018
Town Centres	Retail Capacity Study and town centre uses study	To inform Draft Plan	Scoping underway
The Natural Environment	Ecological Network Study	To inform Preferred Spatial Option Report	Scoping underway
	Strategic Mapping of the Black Country’s Natural Environment	To inform Preferred Spatial Option Report	Scoping underway
Infrastructure	Flood Risk / Water Infrastructure Study	To inform Preferred Spatial Option Report	Scoping underway
	Infrastructure Studies	Stage 1 to inform Preferred Spatial Option Report and Stage 2 to inform Draft Plan	Scoping underway
Transport	West Midlands Strategic Transport Plan: Movement for Growth (WMCA)	To inform Preferred Spatial Option Report	Completed 2016
	Transport Impacts and Accessibility Planning Study	Stage 1 to inform Preferred Spatial Option Report and Stage 2 to inform Draft Plan	Scoping underway
Waste	Waste Study	To inform Publication Plan	Scoping underway
Delivery	Delivery Studies	Stage 1 to inform Preferred Spatial Option Report and Stage 2 to inform Draft Plan	Scoping underway
Viability	Viability Studies	Stage 1 to inform Preferred Spatial Option Report and Stage 2 to inform Draft Plan	Scoping underway
General	Assets and Constraints	To inform Preferred Spatial Option Report	Scoping underway
Sustainability Appraisal / Habitat Regulations Assessment	Sustainability Appraisal Scoping Report (Lepus)	To inform Issues and Options Report	Completed February 2017
	Sustainability Appraisal of Issues and Options Report (Lepus)	To inform Issues and Options Report	Completed May 2017
	Cannock Chase SAC Partnership Memorandum of Understanding	To inform Issues and Options Report	Agreed May 2016

3.8 Published alongside this consultation report is a Sustainability Appraisal scoping report and assessment prepared to inform and support this stage of the plan making process. Sustainability Appraisal reports will be prepared to inform each stage of the review process. Under the Conservation of Habitats and Species Regulations 2010 (‘Habitat Regulations’) an assessment screening report will be prepared at Preferred Spatial Option stage.

(4)Key Issue 2 – Meeting the housing needs of a growing population

3.9 One of the most important objectives of any local plan is to ensure that it identifies sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan. These include the children of residents already in the area who will grow up and want to form new households, and people who will move into the area because of work, study or other reasons. A key factor in household growth is that people are on average living longer than previous generations, so the existing housing stock is not being “freed up” at the same rate as new households are forming.

3.10 Housing need is assessed at the level of the Housing Market Area (HMA). This is the area within which a high proportion of home moves occur and usually covers several local authorities. There is often an overlap between adjacent HMAs, but for plan preparation purposes the HMA usually follows local authority boundaries. The Black Country forms part of the wider Greater Birmingham and Black Country Housing Market Area (HMA). The examination of the Birmingham Development Plan, which has now been adopted, confirmed that there is a shortfall of 38,000 homes arising from Birmingham’s needs to 2031 that cannot be accommodated within the City even allowing for the proposals in the Plan to use land currently in the City’s green belt.

Figure 5 The Greater Birmingham and Black Country Housing Market Area

3.11 A Greater Birmingham and Black Country Strategic Housing Needs Study was completed in 2015 to assess the housing need for the wider HMA and consider scenarios for distributing the housing shortfall. The study concluded that the supply of brownfield land across the HMA is insufficient to accommodate this shortfall, and that the majority of that shortfall will have to be met on greenfield sites, including green belt land outside Birmingham’s administrative area. Options, including urban extensions and growth around railway stations, are identified as possible ways of addressing the shortfall. The study recognises that the time needed to review plans and allocate and deliver sites means that it may not be possible to meet the shortfall in full by 2031. The duty to cooperate offers a mechanism to explore new housing provision beyond the HMA where there are clear migration or commuting links.

3.12 Stepping back from this wider context, the starting point for the Core Strategy review is to assess local housing need arising within the Black Country over the Plan period (2014-36). It has been decided to assess the local needs of the Black Country and South Staffordshire jointly, as this area forms a logical sub-market of the HMA. Therefore, a Strategic Housing Market Assessment (SHMA) - a more detailed study making use of the most up-to-date population and household projections - has been prepared for the Black Country and South Staffordshire during 2016-17.

3.13 The SHMA concludes that the local housing need or “Objectively Assessed Housing Need” (OAN) for the Black Country over the period 2014-36 is 78,190 homes. In order to be compatible with the SHNS, which covers the period 2011-31, the OAN also includes an allowance for a notional “backlog” arising over the period 2011-14 where the SHNS suggests that the annual need for housing was greater than that planned for in the existing Core Strategy. The SHMA OAN figure will be used as the basis for deriving the Core Strategy review housing target. The SHMA may be updated during the review as and when new Government projections and guidance become available and housing supply information changes.

3.14 Work is ongoing to confirm how much new housing can be provided from various sources to help meet the need. A step by step approach has been taken – firstly understanding what has already been built, has planning permission or is identified for development in Local Plans and the capacity of small ‘windfall’ sites within the urban area. This provides the housing capacity of the existing Core Strategy up to 2026, which is detailed in existing SHLAA reports and summarised in the Housing Background Report. The second step is to assess what further capacity exists over the Core Strategy review period up to 2036, which includes identified sites and small and large windfall sites, which is also summarised in the Housing Background Report. This information is presented in Figure 6.

3.15 Figure 6 shows that completions and SHLAA housing supply can deliver 48,185 homes, leaving a requirement for an additional 30,005 homes to accommodate over the Plan period. Identified sites and “windfall” sites have the potential to deliver around 8,335 homes during 2026-36, reducing the ‘gap’ to around 21,670 homes. There may be potential to increase high density housing allocations in some Strategic and Town Centres and to release limited areas of surplus open space for housing in some areas. These sources of supply have not yet been fully quantified and further work will take place during 2017/18 to firm up estimates. However, these sources are unlikely to generate more than a few thousand homes in total, and potentially less.

3.16 A key source of housing supply under the existing spatial strategy is the release of surplus employment land for housing. Local Plans have been successful in identifying and allocating 300 ha of such sites, with capacity to deliver around 10,400 homes during 2016-26, subject to overcoming delivery constraints (see Part 2 – Delivery). A key decision to be made through the review (as set out in Part 4) is whether it is possible and desirable to continue to make such allocations up to 2036, in light of changing employment land needs (see Key Issue 3) and delivery and viability issues. At this stage it is anticipated that, if this option were pursued, it would be extremely challenging to exceed past levels of allocations, due to delivery constraints and the need to protect viable employment premises. Therefore, this source of supply is unlikely to exceed a further 10,400 homes over the period 2026-36.

3.17 Therefore, a large number of new homes and supporting services will need to be accommodated outside the existing urban area of the Black Country, All such land in the Black Country is currently green belt. Part 4 sets out how it is proposed to carry out a search for new sites, including the proposed approach to reviewing the green belt boundary (see Key Issue 6).

3.18 At the HMA level, a joint approach to addressing the HMA-wide shortfall in housing land supply is being developed and a HMA Strategic Growth Study is underway. The Core Strategy review process will reflect the findings of this study and any agreements reached as other local plan reviews progress. The Black Country have committed to test the accommodation of an extra 3,000 homes up to 2031 beyond local need, to help address the shortfall in the wider HMA. This produces a total requirement for land to accommodate 24,670 new homes.

3.19 All of these figures will be tested on an ongoing basis as part of the evidence gathering process during the review and so may be subject to change.

(4)Key Issue 3 – Supporting a resurgent economy

3.20 The NPPF requires the planning system to support sustainable economic growth to create jobs and prosperity, meet global competition and a low carbon future and requires local authorities to plan proactively to meet the development needs of businesses and support a modern economy.

3.21 The Core Strategy review will set out a clear vision and strategy to reflect these aims and make provision for local and inward investment to meet need over the longer Plan period.

3.22 An Economic Development Needs Assessment (EDNA) has been prepared for the Black Country during 2016-17. This builds upon and updates a number of sub-regional employment land studies completed since the adoption of the Core Strategy in 2011 - the West Midlands Strategic Employment Sites Study, the Black Country and South Staffordshire sub-regional High Quality Employment Land Study and the Black Country and Southern Staffordshire Regional Logistics Sites Study.

3.23 The EDNA provides an up to date assessment of employment land requirements over the review period, the suitability of the existing Core Strategy and the associated policy approach. The work identifies a number of growth scenarios based on a range of potential economic outcomes. For all scenarios the EDNA assumes that the 300 ha of occupied employment land already allocated for housing through Local Plans is lost to the employment land supply over the Plan period.

3.24 In order to accommodate the level of growth associated with the most likely scenario, the EDNA recommends that the review should plan for up to 800 ha of additional land to meet the needs of the Black Country for the period 2014-36 within the B1(b), B1(c), B2, B8 use classes and other ancillary uses normally located within employment areas.

3.25 This figure of 800 ha is recommended in the EDNA to be the most appropriate as it represents around 550 ha of land as a basic requirement, informed by past trends, for the Black Country industrial sector to keep functioning, plus approximately 250 hectares of land for growth in the industrial sector, to reflect the employment forecasts associated with the economic growth aspirations of the Black Country SEP in particular i.e. a “past trend plus some growth” scenario.

3.26 In the first instance, need should be accommodated within the existing Growth Network and other parts of the urban area. It is anticipated that 394 ha of land is either currently available or is likely to come forward within the Black Country itself, including opportunities to intensify existing employment areas. A further 90-170 ha of land in South Staffordshire (including the proposed West Midlands Interchange) has the potential to contribute towards meeting Black Country needs.

3.27 The ‘gap’ between anticipated need and existing and future supply is therefore up to some 300 ha. This is a Black Country wide requirement, and the review will need to guide the distribution and phasing of this new supply – for example, should the success of the M54 corridor on the northern edge of the Black Country, in its development as a nationally significant investment location, be built upon and / or should high quality development land in other accessible locations in the south of the Black Country be brought forward?

3.28 The review should provide for a portfolio of employment sites capable of meeting a wide variety of investment needs. These include needs for local and lower quality activities which provide jobs and are important to the functioning of industrial areas. However, it is evident that there is a particular shortage of large and accessible high quality investment opportunities available in the short term. There remains a specific need for large scale, rail-based logistics provision to serve the Black Country and in the absence of any suitably large sites within the administrative area, the proposed West Midlands Interchange located at Four Ashes in South Staffordshire has the potential to satisfy some or most of this need. Discussions with South Staffordshire Council on this issue are on going and will continue under Duty to Cooperate work.

3.29 The EDNA suggests that the Core Strategy should continue to safeguard a wide range of sustainable local employment areas and promote the recycling of brownfield sites within them. However, looking forward over the review period, there may be a limited number of existing employment areas which are unlikely to be ‘fit for purpose’ and could be considered for redevelopment to alternative uses, especially housing. These redundant employment areas could contribute towards meeting housing land requirements, subject to overcoming significant viability issues. This potential source of housing supply is considered under the Strategic Options set out in Part 4.

(1)Key Issue 4 – Supporting strong and competitive centres

3.30 The existing Core Strategy seeks to maintain strong and competitive strategic centres that will be the focus for retail, commercial and other development and sets out the amount of retail and office development planned for up to 2026.

3.31 The primary evidence base informing the Core Strategy’s policy framework in respect of retail and centres is set out in the Black Country Centres Study undertaken by GVA Grimley and published in November 2009. The Study includes capacity projections for convenience and comparison good floorspace based on survey zones and uses population forecasts and expenditure growth projections. The Study identified limited capacity over and above what was then being planned for in centres, and no quantitative or qualitative need to plan for further out-of-centre retail development. This is because the Strategy was predicated on redirecting capacity generated out-of-centre towards centres to support and reinforce their vitality and viability.

3.32 The NPPF requires positive planning policies to promote competitive town centre environments and to set out policies for the management and growth of centres over the plan period. New evidence on retail will be commissioned to inform the rolling level of floorspace that will be needed to be planned for across the Black Country and in particular the Strategic Centres.

3.33 The Core Strategy currently sets ambitious targets for office floorspace and delivery against these targets has been a challenge. New evidence will establish the demand for offices in the Strategic Centres and the delivery issues around attracting offices into centres. Further evidence will also be needed on other centres uses such as leisure in the recognition of the crucial role these uses play in supporting the vitality and viability of centres.

(9)Key Issue 5 – Protecting and enhancing the environment

3.34 The NPPF requires the planning system to protect, contribute to and enhance the environment while providing for the nations development needs. The environment is a key consideration in the NPPF’s pursuit of sustainable development.

3.35 The Core Strategy Review will set out a vision and strategy for the protection and enhancement of the Black Country environment and make provision for environmental infrastructure required to support growth across the Black Country. To assist with achieving these aims new and updated evidence regarding the environment will be commissioned as the review progresses and in response to the findings of the Options consultation. This is anticipated to include an Ecological Network Study, Strategic Mapping of the Black Country’s Natural Environment and Flood Risk / Water Infrastructure Study.

3.36 Under the ‘Habitats Regulations’, spatial plans are required to be assessed for their impact on protected sites that are designated as being of European Importance. Some of the most important of these sites can be affected by developments over a wide area and it is possible that changes in the Black Country might affect the Severn and Humber Estuaries, which – as well as being protected under the international Ramsar Convention - are designated as Special Protection Areas (SPAs) and Special Areas of Conservation (SACs). There are also a number of other SACs within and outside the Black Country that could be affected by the proposals in the Core Strategy review.

3.37 The Black Country authorities have worked closely with the Cannock Chase SAC Partnership in recent years. The Partnership, which includes local authorities affected by the SAC who are advised by Natural England, aims to ensure that the requirements of the Habitats Regulations are met in relation to Cannock Chase SAC. The key objective of the SAC Partnership is to secure appropriate mitigation for the cumulative impact of local plan policies and proposals, and individual planning applications, on the integrity of Cannock Chase SAC. The evidence suggests that increasing numbers of visits are putting pressure on the habitat for which the site is designated and that housing growth might increase the numbers of visits.

3.38 The Partnership has agreed a Memorandum of Understanding (MoU). This is based on the view that there is a 15 km ‘zone of influence’ around the SAC and seeks to establish a programme of measures to mitigate for the impact of new homes within this area, together with a system for collecting developer contributions from housing developments within 8km of the SAC to pay for this programme. A very small part of Walsall Council falls within the 8km zone and the northern parts of Wolverhampton and Walsall fall within the 15km zone.

3.39 The SAC Partnership is in the process of commissioning new evidence to inform Local Plan reviews. Key aims are to determine how further housing growth is likely to impact on the integrity of the SAC and whether the current programme of mitigation measures is sufficient to mitigate for this growth. A HRA screening exercise, drawing on the evidence in respect of Cannock Chase SAC and other European sites that might be affected by the Plan, will be undertaken for the Preferred Spatial Option stage of the Core Strategy review.

(615)Key Issue 6 – Reviewing the role and extent of the green belt

3.40 The green belt is central to the Strategy by providing areas of open land close to where people live and focussing development within the urban area by restricting urban sprawl. The NPPF states that the boundaries of the green belt should only be altered in ‘exceptional circumstances’, through the preparation or review of the Local Plan. The need to accommodate unmet housing needs can contribute towards establishing a case for exceptional circumstances and elsewhere in the region it has been recognised that this threshold has been met.

3.41 The existing Core Strategy concluded that all development needs to 2026 could be met within the existing urban area and so it did not need to be supported by a green belt review. Indeed, there has been no strategic green belt review in the Black Country since the designation of the existing green belt in the late 1970s.

3.42 Newer evidence summarised in Key Issues 2 and 3 above suggests that, for the period to be covered by the Core Strategy review, there will be a significant housing need within the Black Country and the wider HMA, and a need for employment land, which will require the identification of new sites on land outside the urban area that is not currently proposed for development. Within the four Black Country authorities and immediate neighbours nearly all such land is currently green belt and the Review of the Core Strategy will therefore need to explore and identify the potential to accommodate such growth in these areas.

3.43 The current Core Strategy identifies broad locations for development but does not allocate specific sites. Such allocation is left to site allocation documents and area action plans prepared by individual authorities. However, given the strategic importance of the matter to the delivery of the plan, it is considered that a formal review of the Black Country green belt and any release of sites from the green belt, including the allocation of specific sites for development by 2036, should be carried out through the Core Strategy review.

3.44 The examination of the Black Country Green Belt sits in the context of wider work. The Greater Birmingham and Black Country Housing Market Area (HMA) authorities are working together and have commissioned a Strategic Growth Study to identify the need and locations for additional housing growth across the West Midlands conurbation and neighbouring areas (see Key Issue 2).

3.45 Once this work has been concluded which is likely to be September 2017, the findings will inform and provide the basis for a more detailed green belt review for the Black Country as part of the Core Strategy Review.

3.46 The two studies together will therefore provide a robust and thorough examination of the green belt surrounding the Black Country to assess and identify the potential to release sites from the green belt, alongside growth within the urban area, to meet the projected needs identified for housing and employment growth up to 2036.

3.47 This Black Country Green Belt Review will be carried out in conjunction with South Staffordshire Council due to the fact that a large proportion of the Black Country urban fringe extends into South Staffordshire and there are also strong housing market and economic links between the Black Country and South Staffordshire. This consistency of approach will enable the Black Country to work collaboratively with South Staffordshire on cross-boundary issues, through parallel plan reviews (see Key Issue 9 – Working effectively with neighbours).

3.48 Completion of the Black Country Green Belt Review is expected to be by the middle of 2018 and will enable the selection of preferred green belt site allocations for consultation in the Preferred Spatial Option report for the Core Strategy Review, due to be published in September 2018.

(5)Key Issue 7 – Keeping the Black Country connected

3.49 The existing spatial strategy focuses regeneration and development into a series of highly accessible high volume transport corridors where public transport accessibility is greatest.

3.50 The Black Country authorities are working with the other metropolitan authorities in the West Midlands to develop an overarching transport strategy and priorities for transport investment through the West Midlands Transport Strategy: Movement for Growth. The emerging strategy is proposing a balanced approach to transport investment which recognises the need to invest in all modes of transport but also the critical need to increase the proportion of people using public transport and walking and cycling.

(2)Key Issue 8 - Providing infrastructure to support growth

3.51 Since the adoption of the current Core Strategy, national policy and the plans and requirements of infrastructure providers have changed and new information is available. Local Plan documents have been produced across the Black Country which have considered infrastructure needs in greater detail. Infrastructure requirements change over time and, in light of the growth required across the Black Country up to 2036, a review of infrastructure needs is required.

3.52 Physical and social infrastructure is required to enable and support the growth required over the plan period. New housing and economic development will put pressure on existing services and utilities, but may also create opportunities to provide infrastructure solutions to ease and remedy existing issues. This includes local, strategic and cross-boundary infrastructure requirements. A range of studies on infrastructure will be required to support the review, covering both brownfield regeneration areas and green belt sites.

3.53 Examples of potential infrastructure issues requiring further evidence are:

• Work on the delivery of industrial sites has indicated there might be some limits on the electricity supply to support more industry, particularly energy-intensive heavy industry in certain areas of the Black Country.
• The expansion of development of modern communications, with Government support for new technologies (3G, 4G, 5G) is leading to new proposals and expectations.

3.54 It is crucial that viability and market constraints that impact on the delivery of development sites are fully understood. The revised core strategy will be informed by robust delivery and viability studies that consider the delivery of the new growth identified as well as the impact that releasing green belt may have on urban areas to ensure that the strategy supports the regeneration of all the Black Country.

(6)Key Issue 9 – Working effectively with neighbours

3.55 The Black Country authorities are committed to working in partnership with all neighbouring and related authorities and key stakeholders at a sub-regional and regional level, and are actively involved in meeting their requirements under the duty to cooperate, as required by the NPPF. This will ensure that strategic priorities across local boundaries are properly coordinated and enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas.

3.56 There has been a significant amount of cooperation to date. This has included engagement through the West Midlands Metropolitan Area Authorities Joint Committee, the West Midlands Integrated Transport Authority and the West Midlands Duty to Cooperate Group, which provides a forum to facilitate active and on-going engagement on local plan preparation and cross boundary strategic priorities. On-going work is also taking place with authorities in the Greater Birmingham and Black Country Housing Market Area on housing needs. Engagement also takes place through the Black Country Local Enterprise Partnership (BCLEP).

3.57 In June 2016 the West Midlands Combined Authority (WMCA) was formally established and will have a crucial role to play in supporting the delivery of the Core Strategy. The WMCA currently covers the geography of the BCLEP, the Greater Birmingham and Solihull LEP, the Coventry and Warwickshire LEP, Shropshire and Telford as shown on Figure 6.

Figure 7 West Midlands Combined Authority

3.58 The WMCA has responsibility for transport strategy within the metropolitan area and important regeneration and economic development functions. The WMCA Strategic Economic Plan was produced in 2016 which sets out ambitious growth targets. The WMCA is also charged with coordinating the duty to cooperate across the area.

3.59 The Black Country authorities will continue to engage closely with neighbouring authorities and key stakeholders during the review process. Joint work is on-going with South Staffordshire District Council in particular. South Staffordshire forms part of the same Housing Market Area as the Black Country, and a joint SHMA has been prepared to reflect these close links. South Staffordshire also includes parts of the urban fringe of the Black Country, where the local authority boundary follows the edge of the urban area. The South Staffordshire Site Allocations Document has reached Publication stage, however given the scale of housing growth required a South Staffordshire Local Plan review is being advanced to allow parallel consideration of strategic issues affecting both the Black Country and South Staffordshire.

3.60 South Staffordshire also has a crucial role to play in contributing towards meeting the employment land needs of the Black Country, reflecting the interlinked economies of the area. The South Staffordshire land portfolio is largely focussed on meeting demand for large, highly accessible premium sites that cannot be physically accommodated in the Black Country. These sites include the hugely successful i54 business park which is home to a number of international businesses including Jaguar Land Rover.

Summary of the Key Issues

3.61 In summary, the key issues which are driving the Core Strategy review are:

• The existing evidence base is dated, and in parts does not provide a sound basis to underpin the Core Strategy as it rolls forward to 2036. A selective review and update of the evidence is needed to help test and re-shape the Plan.
• There is a need to continue to plan for a growing population. The existing strategy will meet the majority of long term needs and prioritising the delivery of brownfield sites within the urban area should continue. But there is a gap between need and anticipated supply of around 22,000 homes and there is a need to look beyond the existing Growth Network to meet it.
• New evidence tells us that the economy is forecast to grow over the review period at a faster rate than anticipated and there is a need to find more land in the right places, at the right time and of the right quality to support it. The existing Strategy can deliver a significant proportion of this need but, as with housing, there is a need to consider new locations and there are genuine spatial choices. This means that existing sustainable employment areas should also be protected and there is a need to plan for a net increase in employment land.
• Extending the Plan period and delivering significant levels of housing and employment growth will in turn support the viability of the Black Country centres. Growth targets for key town centre uses need to be revisited and there is a need to understand how changing consumer shopping patterns will impact on the role of the centres and the mix of uses they contain.
• An emerging body of work is promoting a more sophisticated approach to planning for environmental infrastructure and how it can support growth aspirations. The review needs to develop this thinking at a Black Country level into a series of locally-specific and inter-related programmes. The current mitigation strategy for Cannock Chase SAC also needs to be reviewed in light of growth aspirations.
• The green belt is central to the Strategy by providing areas of open land close to where people live and focussing development within the urban area. But there has been no strategic green belt review in the Black Country since the 1970s and, as a last resort, it is inevitable that some green belt land will be needed to accommodate long-term development needs. A strategic growth study will be commissioned to identify the most sustainable locations to meet these needs and this will include a robust green belt review.
• The review needs to reflect the recently adopted West Midlands Transport Strategy including key projects and programmes.
• National policy and the long term investment programmes of key infrastructure providers is constantly evolving. There is a need to review the capacity of existing infrastructure against its ability to support the existing Strategy and the additional anticipated growth.
• The regional landscape within which the Black Country sits is changing. The West Midlands Combined Authority will have a more significant role over the Plan period and there is a need to reflect the aspirations of the Strategic Economic Plan and other key programmes associated with HS2. The need is also recognised to work much more closely with neighbouring authorities on issues of cross-boundary significance such as housing, employment and transport