Black Country Core Strategy Issue and Option Report

(28) 4.Reviewing the Strategy to Meet New Challenges and Opportunities

4.1 Part 2 of this Report summarised the existing Core Strategy and showed how it has been an effective tool to shape the location and form of development and regeneration in the area since 2011. However, given the challenges and opportunities that the Black Country now faces, it is important to revisit the vision and objectives of the Core Strategy to consider if these are still relevant and if the Spatial Strategy is still appropriate looking forward to 2036.

4.2 This part of the Report addresses this by testing the Vision and Objectives and then setting out a series of Options on how the key issues summarised in Part 3 can be addressed.

(2) Vision, Principles, Spatial Objectives and Strategic Policies

4.3 The Core Strategy sets out a vision, based on three major directions of change:

• Sustainable Communities;
• Environmental Transformation; and
• Economic Prosperity,

4.4 These directions of change reflect the three dimensions of sustainable development set out in the NPPF, and are supplemented by five more locally specific sustainability principles:

• facing up to climate change;
• sustainable development;
• social inclusion;
• putting brownfield first; and
• a comprehensive approach to development.

4.5 It is considered that this vision and set of principles remain fundamental to the review of the Core Strategy, and should be the starting point when examining sources of land supply for new homes, employment and other land uses, for example ensuring that new housing is located with good sustainable access to employment uses, whilst safeguarding and enhancing the environment.

4.6 In order to deliver this Vision, and in line with the Principles, the Core Strategy set out a series of ten spatial objectives which formed the starting point for the spatial strategy and strategic policies. These objectives are:

1. Focussed investment and development in comparison shopping, office, employment, leisure, tourism and culture within the four Strategic Centres.
2. A restructured sub-regional economy which provides sufficient strategic high quality employment land in the best locations within Regeneration Corridors to attract new high technology and logistics businesses and also recognises the value of local employment land.
3. Model sustainable communities on redundant employment land in the Regeneration Corridors.
4. Enhancements to the character of the Black Country’s existing housing areas.
5. A network of vibrant and attractive town, district and local centres.
6. A high quality environment.
7. A first-class transport network providing rapid, convenient and sustainable links between the Strategic Centres, existing and new communities, and employment sites.
8. A sustainable network of community services, particularly high quality lifelong learning, health care and sport and recreation facilities.
9. Sufficient waste recycling and waste management facilities in locations which are the most accessible and have the least environmental impact.
10. Safeguard and make the most sustainable use of the Black Country’s mineral resources including primary, secondary and recycled materials, without compromising environmental quality

4.7 It is considered that this set of objectives remains a sound basis for the planning and regeneration of the Black Country over the review period. However, following the completion of theevidence base summarised in Table 1, some of these objectives may need to be amended, for example, the changing role of centres and the opportunities provided by bringing forward new sources of housing land supply.

4.8 These objectives form the basis for five strategic policies which set out the overarching Spatial Strategy summarised in Part 2. These policies are:

• CSP1 – The Growth Network
• CSP2 – Development Outside the Growth Network
• CSP3 – Environmental Infrastructure
• CSP4 – Place-Making
• CSP5 – Transport Strategy

4.9 It is considered that, in the main, the overall approach which underpins these Policies remains appropriate, however they will require updating in response to the new challenges and opportunities outlined in Part 3. It is anticipated that figures in Policy CSP1 and Table 1 (which shows the distribution of development between the Growth Network and the rest of the Black Country) will need to be updated and rolled forward to 2036 in line with new evidence, and that minor changes will need to be made to the extent of the Regeneration Corridors to reflect Local Plans. Based on emerging evidence, the approach to development outside the Growth Network is likely to be subject to significant change in order to accommodate housing and employment land growth needs. Therefore Policy CSP2 will need to reflect new growth proposals outside the Growth Network and proposed changes to the green belt boundary. Proposed changes to Policies CSP3, CSP4 and CSP5 are set out in Part 6.

(4) Reviewing the Spatial Strategy

4.10 The existing Core Strategy is ambitious. It looks to regenerate a growth network of four Strategic Centres and sixteen Regeneration Corridors within the urban area and to meet growth needs by making maximum use of previously developed land within this network - largely redundant and under used employment sites. The growth network covers areas with high accessibility, including key public transport corridors with a high frequency service, and includes the vast majority of development opportunities. The green belt around the urban area is protected from development.

Figure 8 Current Local Plan Allocations

4.11 The current Local Plan allocations which have been made in accordance with the spatial strategy are shown on Figure 8. This strategy, with its focus on the Growth Network, has the ability to meet the majority of long term development needs and so should be largely carried forward into the review.

4.12 However, new evidence indicates that further land will be needed, beyond the existing spatial strategy, to meet all of the Black Country’s growth needs. It is estimated that further land will be required to provide 22-25,000 new homes and up to 300 ha of new employment land.

4.13 In responding to this challenge there are choices to be made. It is proposed that these choices are made sequentially, as set out in Table 2 below:

Table 2 Approach to accommodating growth

Stage	Options	Description
1 – Continuing the role of the Growth Network	1A	Continue and strengthen the Growth Network with some corridors being housing led and others employment led. Remaining housing and employment land growth to be accommodated in the green belt.
	1B	Restructure the existing Growth Network, with more occupied employment land being redeveloped for housing in the Regeneration Corridors. Remaining housing and employment land growth, and replacement employment land, to be accommodated in the green belt.
2A – Housing Development outside the Growth Network	H1	Rounding off the green belt and meet housing needs through a large number of small sites.
	H2	Identification of a limited number of large Sustainable Urban Extensions in the green belt
2B – Employment Development outside the Growth Network	E1	Extend existing employment areas on the urban fringe into the green belt
	E2	Provide new freestanding employment sites in sustainable locations in the green belt
	E3	Provide new employment land within Sustainable Urban Extensions in the green belt
	E4	Export growth to neighbouring areas with strong economic links to the Black Country

4.14 Stage 1 will explore the opportunities that exist to maximise the growth potential of the urban area by testing how existing land is used within the Growth Network, with a focus on employment land as the main ‘variable’. On the basis of Stage 1, Stage 2 will test the capacity of new sources of land supply outside the urban area for both housing and employment. In the Black Country, all land outside the urban area is designated as green belt. Therefore, some green belt land will be needed to be identified for development in the Plan if growth needs are to be met – the scale and mix of which will be determined through the Stage 1 Options.

4.15 The Options are described in more detail in the following sections.

(10) Stage 1: Strategic Options 1A and 1B – continuing the role of the Growth Network

4.16 Within the Growth Network, the existing Core Strategy supports a sustainable mix of uses but with some Regeneration Corridors focussed on employment land and others on housing. This approach could be changed by restructuring some of the Regeneration Corridors to change the balance between employment and housing - relocating some existing employment activity to the edge of the urban area and replacing it with high quality residential areas.

4.17 Two strategic option have been identified. Option 1A continues the existing strategy, with some Regeneration Corridors being housing led and others employment led. Housing and employment land growth needs would be accommodated outside the Growth Network, in the green belt.

4.18 Option 1B involves restructuring the existing Regeneration Corridors, with more of the existing employment land being replaced with housing, and remaining growth needs and replacement employment land being provided in the green belt. This option may allow more housing need to be met within the Black Country, however delivery will be very challenging due to the high costs of site assembly, business relocation and land remediation and so significant public sector funding would be required.

4.19 Underpinning both of these options is the strategic need to increase the employment land stock as recommended in the EDNA – this is in contrast to the existing Core Strategy which plans for a net contraction in employment land. This means that any employment land ‘displaced’ through Option 1B will need to be made up elsewhere.

4.20 The opportunities and challenges presented by the Strategic are explored below.

Strategic Option 1A - Meet all remaining housing and employment land growth needs outside the Growth Network Description - Continue and strengthen the Growth Network with some corridors being housing led and others employment led. Remaining housing and employment land growth to be accommodated in the green belt.
Opportunities	Challenges
Can provide for a sustainable pattern of development, close to the urban edge and close to where need arises within the Black Country. Can facilitate the extension/expansion of high frequency public transport corridors. Would significantly boost the supply of housing and employment land. Would broaden the range and diversity of new homes available. Would reduce the need to promote the redevelopment of existing employment sites for residential development. Opportunities to create balanced communities with new local facilities and employment areas which could also benefit those living on the urban edge.	Would require significant adjustments to the green belt boundary to release land for development beyond the urban area. Limited scope for development in some parts of the urban fringe. May not have sufficient capacity to accommodate all growth needs Capacity of public transport will need to be increased to accommodate growth in some locations. Additional infrastructure investment will be required in some locations, including schools. Delivery on larger sites may be towards the end of the plan period. Impacts on the wider transport network may need to be mitigated in some locations.

Strategic Option 1B – Restructure the Growth Network Description - Restructure the existing Growth Network, with more occupied employment land being redeveloped for housing in the Regeneration Corridors. Remaining housing and employment land growth, and replacement employment land, to be accommodated in the green belt.
Opportunities	Challenges
Better able to accommodate housing need within the Black Country. Could provide for development to take place within the urban area closer to where need arises. Will support on-going regeneration and investment in the urban area with consequential social and economic benefits. Will provide a wider range of uses within Regeneration Corridors.	Extremely challenging in terms of delivery and viability, requiring significant public sector funding for land remediation and assembly and business relocations. Intentions of businesses / landowners in Regeneration Corridors are not known at this stage. There may not be sufficient suitable locations in the green belt to meet employment land needs. Would require significant adjustments to the green belt boundary to release land for development beyond the urban area. May not have sufficient capacity to accommodate all growth needs Capacity of public transport will need to be increased to accommodate growth in some locations. Additional infrastructure investment will be required in some locations, including schools. Delivery on larger sites may be towards the end of the plan period. Impacts on the wider transport network may need to be mitigated in some locations.

The Options are illustrated in Figure 9 below.

(14) Stage 2: Strategic Options 2A and 2B – Housing and Employment outside the urban area

4.21 The Stage 1 Options will provide an overall steer on how much housing and employment development will need to be accommodated outside the urban area. For Stage 2, two sets of Options have been identified, one for housing (2A) and one for employment (2B).

Strategic Option 2A – accommodating housing growth outside the urban area

4.22 Two broad Housing Spatial Options have been identified.

4.23 Spatial Option H1 is based on ‘rounding off’ the green belt edge by identifying a large number of small to medium sized sites. There are significant green belt wedges which extend into the Black Country urban area which could also be ‘rounded off’ as part of this Option. Sites could range in size from a few homes to hundreds of homes, where this would provide a defensible new green belt boundary and sufficient services exist.

4.24 Spatial Option H2 adopts a more focussed approach by identifying a limited number of large scale Sustainable Urban Extensions (SUEs). The Strategic Housing Needs Study (SHNS) defines a SUE as a development on the edge of a settlement which can accommodate 500-5,000 homes and is of a scale appropriate to the size of the settlement being extended. No SUEs are currently being promoted in the Black Country. At this stage, no size of SUE has been ruled out.

4.25 The SHNS considered the potential to locate SUEs close to existing railway stations, to promote sustainable transport and meet the needs of new households to access employment hubs. Future opportunities may arise from planned improvements to the West Midlands railway network, including additional capacity and electrification of some lines. In the longer term, HS2 will provide further opportunities and there is potential to provide a station at Aldridge on the existing network.

4.26 Development of a certain critical mass can itself support changes to public transport accessibility by making routes more viable or funding infrastructure. However, this may be challenging and expensive to achieve and should only be considered as a realistic option when robust evidence can demonstrate its deliverability. In particular, it is likely that only an SUE of 10,000+ homes could support the provision of a new rail station.

4.27 At a local level, there is also potential to extend the existing Regeneration Corridor network (corridors 7, 11, 13, 14 and 15) into the green belt, which may support the existing spatial strategy. There may be other ways for green belt releases to support the urban regeneration strategy, for example through cross-funding infrastructure required for regeneration, or through phasing to allow brownfield sites to be brought forward first.

4.28 Depending on size and location, a SUE could require a range of infrastructure and services, including new roads, footpaths and cycleways, drainage and services, open spaces, shops and schools. For large SUEs, there is also the potential to provide employment land as part of a mixed use development to help meet employment land requirements and a balance of uses. The amount of housing that can be delivered in SUEs over the Plan period is likely to be limited by market and infrastructure delivery constraints. For this reason, smaller sites may produce more housing completions than a single SUE in one location.

4.29 The opportunities and challenges presented by the two Housing Spatial Options are explored below.

Spatial Option H1 – Rounding off Description - “Round off” the edge of the green belt, including internal green belt wedges, to release a large number of small to medium sized sites for housing.
Opportunities	Challenges
Could provide for a sustainable pattern of development where local public transport and residential services are present Smaller sites may require less new infrastructure then larger sites so could have shorter delivery timescales Would provide sites suitable for a broader range of housebuilders and so potentially higher levels of completions. Could provide for development to take place within the urban area closer to where need arises. Could promote wider choice and opportunity within the housing market and allow diversification of the housing stock.	Would require many minor adjustments to the green belt boundary, with a potentially greater impact on a wider area. This option would not meet all the housing needs. Smaller sites may not individually trigger requirements for new infrastructure but could place cumulative pressure on existing infrastructure.

Spatial Option H2 – Sustainable Urban Extensions Description - Release land from the green belt to allocate a limited number of Sustainable Urban Extensions across the Black Country (including cross boundary options) in the most sustainable locations which have the potential to be well served by infrastructure.
Opportunities	Challenges
Would significantly boost the supply of housing and maximise provision of affordable housing Could provide for development to take place close to the urban edge, near to where need arises. Could promote choice and opportunity within the housing market and allow diversification of the housing stock in the areas concerned. More opportunity to provide necessary infrastructure as part of large planned developments.	Would require large-scale adjustments to the green belt boundary with potentially major impacts on green belt purposes and environmental assets, focused in the areas concerned. Likely to concentrate delivery later in the plan period due to infrastructure and phasing issues. Risk of over reliance on a limited number of large sites. Delivery may be limited by market and infrastructure constraints.

4.30 Some individual development opportunities may fall under more than one of the Spatial Options. At this stage it is not possible to be specific about the precise implications for each of the Options, however, they have been subject to a high level sustainability appraisal. The next stage of the review process will assess the merits of each of the Options in light of the Call for Sites responses and the results of the Black Country Green Belt Review (see Part 2) in order to arrive at a Preferred Spatial Option.

Meeting housing needs outside the Black Country

4.31 If, when these two Housing Spatial Options have been fully explored, total need still cannot be met, the Black Country would need to work with other authorities to “export” the shortfall. Exporting means that other authorities agree to try and accommodate part of the shortfall through a review of their Local Plan. In the first instance growth should be exported to authorities within the Greater Birmingham and Black Country Housing Market Area (HMA), as the Black Country has the strongest migration and commuting links with these areas. However, if these authorities are not likely to be able to accommodate all of the shortfall, growth can be exported to authorities outside the HMA but with existing or potential links to the Black Country, such as Telford & Wrekin. In both cases release of green belt land would be the last resort.

4.32 The potential challenges raised by exporting are:

• Limited opportunities to provide the types of homes needed by Black Country residents, including affordable homes
• Increase in migration flows and commuting between the Black Country and other areas
• A ‘real’ decline in the Black Country’s population

4.33 However, there are also potential opportunities:

• Growth could support investment in transport infrastructure to more closely link developments to the Black Country.
• Some sites in neighbouring authorities could be more sustainable and deliverable than sites within the Black Country’s green belt.

4.34 As the Black Country boundary follows the edge of the urban area in many places, areas on the urban fringe of the Black Country which fall within neighbouring districts of South Staffordshire, Bromsgrove, Cannock and Lichfield may provide sustainable locations for growth to meet Black Country needs. Given the possibility that exporting housing growth to authorities within the HMA will be necessary, the Call for Sites extends to parts of these authorities which adjoin the Black Country urban area or which could potentially form part of a larger development which would adjoin the Black Country urban area.

Strategic Option Area 2B – accommodating employment land growth outside the urban area

4.35 It is considered that the provision of additional employment land to meet needs should continue to focus on recycling brownfield land within established and safeguarded / allocated employment areas. Such areas remain the most sustainable locations and recycling this land contributes towards the overarching strategy of urban regeneration. However, evidence has identified that, to meet future need and particularly to provide an appropriate portfolio of land and sites, options for meeting employment land growth in the green belt potentially need to be considered. Four Spatial Options have been identified, however the preferred option could be a combination of these, and all of the Spatial Options may be required to meet total need.

4.36 The opportunities and challenges presented by the Employment Land Spatial Options are explored below.

Spatial Option E1 – Extend existing employment areas on the urban fringe into the green belt Description – extend existing employment sites and areas on the edge of the urban area into adjoining green belt land.
Opportunities	Challenges
Maximises use of existing infrastructure Potentially less impact on the green belt purposes and environmental assets	Limited capacity around some employment sites.

Spatial Option E2 – Provide new freestanding employment sites in sustainable locations in the green belt Description – identify new high quality employment sites in sustainable and highly accessible locations in the green belt.
Opportunities	Challenges
Potential to attract national and international, footloose investment. Opportunity to provide a balanced supply of employment land across the Black Country including areas not currently well served by a range of employment land.	May require significant infrastructure with associated viability challenges. Would require the release of significant areas of green belt and have potentially greater impact on environmental assets.

Spatial Option E3 – Provide new employment land within Sustainable Urban Extensions in the green belt Description – include employment land within large scale mixed use Sustainable Urban Extensions on the edge of the Black Country urban area.
Opportunities	Challenges
Could use infrastructure provided to support comprehensive development with the potential for cross subsidy.	Would be dependent on being able to identify SUEs of a sufficient size in appropriate locations.

Spatial Option E4 – Export growth to neighbouring areas with strong economic links to the Black Country Description - explore opportunities to provide high quality employment land in neighbouring areas with strong economic links to the Black Country
Opportunities	Challenges
Eliminates the need to find sites within the Black Country green belt with any associated constraints.	May not be the most sustainable option as it moves jobs further away from where people live.