Black Country Core Strategy Issue and Option Report

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(1) 6. Review of Existing Core Strategy Policies and Proposals

6.1 The Core Strategy was adopted in 2011. Following publication of the National Planning Policy Framework (NPPF) in 2012 a conformity assessment was undertaken and that judged the Core Strategy to be compliant with the NPPF. Many of the Core Strategy policies remain fit for purpose and can be rolled forward with minor updates to reflect changing circumstances. However, some have been overtaken by events and will need to be updated or amended more significantly. In particular, some policies may need amending to reflect differing policy requirements for sites within the urban area and outside it.

6.2 This Part of the Report considers each of the Core Strategy policy areas in turn to identify those which need only minor amendments and updates to figures and those which may need to be significantly amended, removed or replaced.

6.3 This Part of the Report is divided into the following Policy areas:

  1. Health and Wellbeing
  2. Creating Sustainable Communities
  3. The Economy and Employment
  4. Centres
  5. Transportation and Accessibility
  6. The Black Country Environment
  7. Waste
  8. Minerals
  9. Growth Network Detailed Proposals
  10. Monitoring and Additional Policies

6.4 Table 3 provides an overview of the extent to which the current Core Strategy policies may be changed as part of this review. This is just to provide an indication of current thinking and the ‘degree of change’ may well alter as a result of consultation responses or new evidence. Please see the individual policy areas for further detail.

Table 3 Overview of Potential Changes to Existing Core Strategy Policies

Existing Core Strategy Policy

Degree of Change to be consulted on

Reason for potential change

CSP1 The Growth Network

Major

Figures within the policy are likely to be updated as a result of new evidence and minor changes made to the extent of the Regeneration Corridors to reflect Local Plans.

CSP2 Development Outside the Growth Network

Major

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.

CSP3 Environmental Infrastructure

Major

Garden City principles could be added to the policy along with the removal of references to renewable energy.

CSP4 Place Making

None

Place making strategy and principles are considered robust and unlikely to require amendment.

CSP5 Transport Strategy

None

Transport strategy and principles are considered robust and unlikely to require amendment.

DEL1 Infrastructure Provision

Potentially Major

The policy may need to be changed to reflect new infrastructure needed to support development outside the urban area. Minor changes may also be needed to reflect potential changes to national policy in securing infrastructure contributions from developers.

DEL2 Managing the Balance between Employment Land and Housing

Potentially Major

Changes may be needed to reflect more definitive site allocations within Local Plans and to allow widen the scope of the policy to assess changes of use from employment land to uses other than housing.

HOU1 Delivering Sustainable Housing Growth

Major

To reflect new evidence on housing need across the Black Country.

HOU2 Housing Density, Type and Accessibility

Minor (Potentially Major)

To ensure the policy is consistent with emerging national policy

HOU3 Delivering Affordable Housing

Major

To reflect changes to national policy and reflect new evidence regarding affordable housing needs

HOU4 Accommodation for Gypsies, Travellers and Travelling Showpeople

Major

To reflect new evidence of needs for this type of accommodation.

HOU5 Education and Health Care Facilities

Minor (Potentially Major)

To review the requirement for alternative provision when a facility is lost. Potential to broaden the policy to secure such infrastructure to serve major housing developments.

EMP1 Providing for Economic Growth and Jobs

Major

Revised targets to reflect up-to-date evidence of need and supply. Potential changes to criteria and definitions.

EMP2 Actual and Potential Strategic High Quality Employment Areas

Major

Revised targets to reflect up-to-date evidence of need and supply. Potential changes to criteria and definitions.

EMP3 Local Quality Employment Areas

Major

Revised targets to reflect up-to-date evidence of need and supply. Potential changes to criteria and definitions.

EMP4 Maintaining a Supply of Readily Available Employment Land

Potentially Major

Potential changes to reflect a portfolio based approach.

EMP5 Improving Access to the Labour Market

Potentially Minor

Minor change to allow for use of planning conditions.

EMP6 Cultural Facilities and the Visitor Economy

Minor

Update to lists of attractions and facilities to reflect current priorities.

CEN1 The Importance of the Black Country Centres for the Regeneration Strategy

Minor

Potential to merge this policy with CEN2.

CEN2 Hierarchy of Centres

Minor

Potential to merge this Policy with CEN1

CEN3 Growth in the Strategic Centres

Potentially Major

Criteria, targets and thresholds may be revised based on new and emerging evidence

CEN4 Regeneration of Town Centres

Potentially Major

Criteria and thresholds may be revised based on new and emerging evidence

CEN5 District and Local Centres

Minor

Some minor change to thresholds may be required depending on new emerging evidence

CEN6 Meeting Local Needs for Shopping and Services

Potentially Major

Criteria and thresholds may be revised based on new and emerging evidence

CEN7 Controlling Out-of-Centre Development

Potentially Major

Criteria may be revised based on new and emerging evidence

CEN8 Car Parking in Centres

Minor

Some minor changes may be required resulting from changes to other relevant policies

TRAN1 Priorities for the Development of the Transport Network

Minor (Potentially Major)

To reflect the proposed changes to the priorities for the development of the transport network and accessibility standards.

TRAN2 Managing Transport Impacts of New Development

Minor

Policy wording anticipated to remain very similar.

TRAN3 The Efficient Movement of Freight

Minor

Policy wording anticipated to remain very similar.

TRAN4 Creating Coherent Networks for Cycling and Walking

Minor

Policy wording anticipated to remain very similar.

TRAN5 Influencing the Demand for Travel and Travel Choices

Minor (Potentially Major)

The criteria based approach will need to be reworded/updated going forward.

ENV1 Nature Conservation

Minor

Policy updated to be consistent with national policy.

ENV2 Historic Character and Local Distinctiveness

Minor

Policy updated to reflect latest national policy and guidance, particularly in relation to Design and Access Statements.

ENV3 Design Quality

Potentially Major

Policy updated to reflect changes to housing standards at a national level. Policy could look to introduce standards for water consumption, access and space

ENV4 Canals

Minor

Overall approach in policy to remain unchanged but references to specific canal schemes could be removed.

ENV5 Flood Risk, Sustainable Drainage Systems and Urban Heat Island

Minor

Amendments to reflect most recent national guidance and to strengthen policy wording.

ENV6 Open Space, Sport and Recreation

Minor

Update some references in the policy and supporting text to reflect changing circumstances

ENV7 Renewable Energy

Potentially Major

Possible changes to provide flexibility for non-domestic buildings and changes to the 10% requirement.

ENV8 Air Quality

Minor

Changes to reflect the approach in the adopted Black Country Air Quality SPD

WM1 Sustainable Waste and Resource Management

Minor

Policy approach maintained but figures will be updated to reflect new evidence

WM2 Protecting and Enhancing existing waste management capacity

Minor

Policy approach maintained and new evidence will update the identified strategic waste management sites.

WM3 Strategic Waste Management proposals

Minor

Policy approach maintained but references to specific sites will be updated to reflect changes in circumstances, new evidence and Local Plans

WM4 Locational Considerations for new waste facilities

None

The policy has been successful in raising the quality of new waste facilities across the Black Country

WM5 Resource Management and New Development

None

Policy provides an appropriate level of control over resource management for new developments

MIN1 Managing and Safeguarding Mineral Resources

Potentially Major

Policy to be updated to reflect new evidence and a proposed change to the prior extraction threshold for sites within the green belt

MIN2 Production of Aggregate Minerals

Minor

Updated to reflect the recent evidence from Local Plans and other new evidence.

MIN3 Maintaining Supplies of Brick Clay

Minor

Updated to reflect the recent evidence from Local Plans and other new evidence.

MIN4 Exploitation of other mineral resources

Minor

Updated to reflect the recent evidence from Local Plans and other new evidence. Possible reference to fracking

MIN5 New Proposals for Minerals Development

None

Policy considered to identify all of the key issues that need to be addressed in relation to new mineral developments

These Policy areas are discussed in detail in turn below.

(5) Policy Area A - Health and Wellbeing

6.5 The Core Strategy has a key role in improving health and wellbeing. Developing strong, healthy and vibrant communities is vital to ensuring the wellbeing of the Black Country’s population. The existing Core Strategy does not have a specific ‘Health and Wellbeing section’ – instead, these issues are addressed through the set of thematic policies which together address many health and wellbeing issues.

6.6 Since the adoption of the Core Strategy there has been much research and guidance produced on ways of improving health and wellbeing through spatial planning and place-making. Health professionals and planners are adopting a more collaborative and holistic approach to encourage healthier lifestyles, minimise health inequalities and prevent ill health, through a well-designed built environment. Planning policies that contribute towards healthier communities, for example by introducing standards for developers, can allow health to be built into the environment at the earliest possible stage. This is often referred to as ‘designing in health’, in the same way that crime can be ‘designed out’. This can be as important as investment in healthcare, as healthcare treats the symptoms, whereas planning can help address the causes of health inequalities and poor health. The key ways in which the physical environment can influence health is summarised in Figure 10 below.

Figure 10 The relationship between the physical environment and health and wellbeing (Dudley MBC Planning for Health SPD)

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6.7 If communities and households have access to facilities and services, healthy food choices, local employment opportunities, active transport options and well-designed public open space, they will be happier, healthier and more resilient in terms of physical and mental health. It has also been shown that developments which meet a certain quality design standard can help prevent ill health, creating a “health premium”. Local planning policies, and the selection of locations for new developments and facilities, should enable people to have a choice of high quality and attractive places to live and allow them to reach the services they need by sustainable forms of transport, enabling the healthier choice to be the easiest choice.

6.8 The most common health inequalities in the Black Country relate to obesity and inactivity, which are well above the national average for both adults and children. These are framed against an ageing population, with social exclusion also a prominent issue. Alcohol related harm and problem debt are also major issues. These inequalities and issues should be at the forefront of decision making to improve health and wellbeing through strategic planning.

6.9 In the adopted Core Strategy, and other Local Plan documents, there are many policies which promote health and have a positive impact on health across the Black Country. These include policies relating to protection of employment land, increasing environmental infrastructure, improving air quality, promoting sustainable transport and enabling active travel, providing more affordable housing and ensuring sustainable and quick access to residential services. The Core Strategy is a regeneration strategy that provides homes and jobs, which are key to the health and wellbeing of communities. One fundamental way that the Core Strategy helps to address health and wellbeing inequalities is by providing employment opportunities and securing economic security for the communities of the Black Country. The Core Strategy Review will consider ways to strengthen health promotion further, focusing on four main themes which embody the strategic links between planning and health:

Theme 1 - Location and accessibility of healthcare and community facilities

6.10 Accessibility to health care and community facilities must be addressed in terms of location and physical access. Car ownership levels decrease with age and are low for younger families, young people in lower income groups and the unemployed. A large percentage of the Black Country’s ageing population rely on living within easy walking distance of healthcare services or at least having regular, reliable access to such facilities. It is therefore important to locate new homes in areas with good access to existing healthcare and community services or where new, sustainable facilities can be created to serve new development.

Theme 2 - Planning for active lifestyles

6.11 Providing an appropriate quality, quantity and variety of open space, including parks, natural areas and allotments, and sport and recreation facilities, is key to achieving better health and wellbeing for the population. As well as encouraging physical activity, access to open space, sports and other recreation facilities promotes relaxation and reduction in stress for those living nearby, and can also bring about social interaction within communities, including for people who feel excluded. The provision of open space and other publicly managed facilities needs to be considered in the context of increased financial pressures and the need for alternative funding and management solutions.

Theme 3 - Designing for safety and wellbeing

6.12 Social exclusion can be reduced by effective design solutions which integrate well maintained public spaces, community facilities, shops and parks into the surrounding development. Well designed places can also help to reduce the circumstances and opportunity for crime and increase public confidence and security. The design of places also needs to take account of transport which has a direct impact on health and safety. Air pollution, noise, traffic and congestion all have a negative impact on people’s ability to use their environment and major transport routes can act as barriers between and around communities. Walking and cycling, which are sustainable and active forms of transport, need to be given priority.

Theme 4 - Life stages, equality and inclusion

6.13 The role of spatial planning and public health is to support people and give them the independence they need to live in good health throughout their life. Children and young people need opportunities for sport and recreation and places where they can interact socially with their peers. As they become older, job and training opportunities need to be available and accessible. Every person should have easy access to community facilities and the services they may require throughout all stages of their life. As people progress into later life, daily requirements will change and it is essential that residential areas are designed to reflect this, enabling people to continue to live in the places they are familiar with and in which they have developed social networks, family ties and a sense of belonging. Ideally, new communities and developments should reflect all of these factors, so that developments are built to a standard that allows genuine inclusivity.

Developing and Using the Health Evidence Base

Joint Strategic Needs Assessment (JSNA)

6.14 Each Black Country Local Authority has a Joint Strategic Needs Assessment (JSNA) which identifies priorities based on the needs of the population. These needs are numerous and relate to the wide breadth of health determinants. They are used to inform commissioning intentions and inform the Health and Wellbeing Strategy for each local area.

Joint Health and Wellbeing Strategy (JHWS)

6.15 Each Local Authority Health and Wellbeing Board produces a Joint Health and Wellbeing Strategy which aims to improve the health and wellbeing of their population and reduce inequalities through actions affecting the wider determinants of health e.g. housing, education, regeneration, planning, environment and resilient communities.

Health Impact Assessment (HIA)

6.16 A Health Impact Assessment (HIA) is a tool that enables Health and Wellbeing Boards and Local Planning Authorities to assess what impact a change of policy or new development, service or strategy will have on the health of the local population. Undertaking an HIA produces information on how negative impacts on health can be reduced and positive health gains can be encouraged. The HIA can also identify the different groups which will experience health gains or losses. HIA’s can be carried out at any stage in the development process but are best undertaken at the earliest stage possible.

6.17 As part of the Core Strategy review, HIAs will be of value in assessing the impact of larger housing sites, where sustainable and active transport links, access to services, air quality, noise and neighbourhood amenity, social cohesion, housing quality and design and environmental quality will be key factors. Health impacts will also be taken into account through the Sustainability Appraisal process, with an assessment of population-level place-based health determinants presented in a Health and Wellbeing Technical Paper, which forms part of the evidence base for this Topic Area.

(17) Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No; If no, please provide details

(14) Question 33 – Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No; If yes, is a new policy needed to address such issues for example?

(20) Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No; Any further comments.

(19) Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

(6) Policy Area B - Creating Sustainable Communities in the Black Country

6.18 The Policies in the Creating Sustainable Communities section of the existing Core Strategy set out the housing target for the Plan period and where and when this housing will be delivered. They set out the framework for site allocation documents and area actions plans to make housing allocations, including appropriate accessibility standards and density levels, affordable housing requirements and the amount of gypsy and traveller accommodation required. The strategic approach to education, health care facilities and other infrastructure that is needed to serve existing and new housing development is also established

6.19 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review.

(1) Policy HOU1 - Housing Land Supply

6.20 Policy HOU1: Delivering Sustainable Housing Growth, together with Tables 5, 6 and 7 and the Housing Trajectory, set out housing targets for the current Core Strategy Plan period (2006-26) and how and when these will be met, both within and outside the Growth Network. Appendix C: Black Country Monitoring Summary sets out progress made during 2006-16 towards meeting these targets, and Appendix B sets out a housing trajectory for the period 2016-26, based on current sources of housing supply set out in up-to-date SHLAAs for the four authorities.

6.21 As explained in Part 3, the housing target for the new Plan period (2014-36) will be established through the review, based on need and the availability and deliverability of new sources of housing land supply. It is proposed to update Policy HOU1 and detailed housing figures throughout the Core Strategy once this process is complete. This will include: re-profiling the distribution of development set out in Table 1; changing the proportion to be built on previously developed land; and possible phasing to ensure that brownfield regeneration is prioritised.

6.22 The Core Strategy identified a supply in excess of need to allow for the likelihood that some of the supply would not be delivered during the plan period, by applying a discount of 10% for allocated sites and 15% for broad locations. However, since adoption of the Core Strategy, detailed work has been undertaken as part of the preparation of site allocation documents and area action plans to understand the sites within the growth network, providing greater certainty regarding delivery. It is therefore proposed to reduce the levels of discount applied to these locations.

6.23 When the Core Strategy was adopted it was predicted that significant housing loss would take place through demolitions focussed in housing renewal hubs. However, although investment has taken place and will continue within housing market intervention areas, this has not involved large-scale demolitions. Therefore it is proposed to revise the expected contribution to the land supply of housing renewal hubs and to revisit and update their locations.

6.24 The housing supply included a small site windfall allowance, which was supported in the Core Strategy Inspector’s Report. This is the contribution that is expected to come from sites which are too small to allocate in Local Plans. This allowance has since been supported by monitoring information and changes to national policy - which now allows a windfall allowance to be made in the five year supply. Therefore it is proposed to include an up-to-date small site windfall estimate of 505 per year in the housing supply for the review Core Strategy. It is proposed that the threshold for small sites should be sites for fewer than 10 homes or smaller than 0.25 ha, in line with the Housing White Paper 2017.

6.25 Potential has also been identified to increase high density housing allocations within Strategic Centres, particularly in Walsall, which currently has a low housing target and where the emerging AAP proposes to reduce the new office floorspace target, providing flexibility for other uses in the longer term.

6.26 If these sources of supply prove to be of strategic significance it is proposed to include them in the housing supply for the review Core Strategy.

(43) Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

(6) Policy HOU 2 - Housing Density, Type and Accessibility

6.27 Policy HOU2: Housing Density, Type and Accessibility sets a framework for determining the most appropriate house type mix at a local level. The Policy introduced an approach to density on larger housing sites which is based on accessibility by sustainable transport to residential services. The Policy also sets a net density range of between 35 dwellings per hectare and 60 dwellings per hectare for the majority of sites. The Policy is in line with consultation proposals in the Housing White Paper 2017 to introduce minimum density standards and to promote the development of previously developed land and land surrounding transport hubs. However the threshold used in the Policy, of 15 homes or more, is inconsistent with those used in the Housing White Paper and the NPPF.

6.28 As evidenced in the Housing Background Report, the majority of housing built since 2011 has accorded with the density and accessibility requirements of the Policy. However, it has proved difficult for Local Plan documents to prescribe the density and house type mix for each site allocation, as required by the final paragraph of the Policy, therefore it is proposed to remove this paragraph from the Policy.

6.29 Looking to the future, the standards may not apply equally well to green belt release locations, and in particular to urban extensions. In line with proposals in the Housing White Paper, it is important that such locations are chosen on the basis of good walking or public transport access to residential services, however achieving high levels of access may be more difficult to achieve on the urban fringe.

6.30 Para 3.11 sets out the broad mix of homes to be provided to meet the needs of different sizes of household. The Black Country and South Staffordshire Strategic Housing Market Assessment (SHMA) 2017 provides guidance on the likely needs of different groups for housing over the new Plan period. This concludes that, given the nature of the existing housing stock, the optimum mix overall would be: 12% 1 bed; 22% 2 bed; 40% 3 bed; and 26% 4 bed properties, although this would vary by area and tenure. The SHMA also provides guidance on the needs of certain groups for housing, including the elderly and families with children. In particular the SHMA highlights a need for 162 new sheltered and extra care homes every year to meet the needs of older persons – 5% of the total housing need.

(35) Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dph be increased to maximise brownfield housing delivery?

(22) Question 37a - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why

(6) Question 37b – If no, should it be reduced to 11 homes or more? Yes/No; If No, what other threshold should be used and why?

(29) Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?

(20) Question 39 - Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.

(34) Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.

6.31 Local authorities are now required to identify the level of demand for self and custom build housing in their area by setting up a register, and to take account of demand when preparing a local plan. The review should therefore consider if and how to take account of demand for self and custom build housing in the Core Strategy.

6.32 There are currently only nine records on self and custom build registers in the Black Country. Therefore, it may be possible for such small-scale need to be met through local policies and allocations, rather than through a specific policy in the Core Strategy.

6.33 If a policy approach was required, one option would be to set a target for each authority to allocate smaller sites to provide for the requirements of those on local authority self and custom house-building registers. An alternative would be to introduce a Core Strategy policy requiring larger housing sites to provide a proportion of serviced plots for self and custom build housing. Under both options, subsidising the provision of serviced plots is unlikely to be viable on brownfield sites in the urban area, but may be deliverable on greenfield sites outside the urban area.

6.34 The development of Houses in Multiple Occupation (HMOs) in parts of the Black Country has become an issue in recent years as this type of accommodation sometimes raises local concerns relating to matters such as amenity space and parking. National guidance supports addressing these issues through local approaches, including the use of Article 4 Directions, which are based on local evidence.

(21) Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:

(11) Question 41b - A target for each authority? Yes/No; Any further comments.

(12) Question 41c – A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments.

(10) Question 41d - Another approach altogether? Yes/No; If yes, please specify

(1) Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.

(3) Policy HOU3 - Affordable Housing

6.35 Policy HOU3: Delivering Affordable Housing set out a target for affordable housing provision over the Plan period based on need set out in the 2008 SHMA. The aim was to provide at least 550 new affordable homes per year, through grant funded schemes and by securing 25% affordable housing on private housing sites of 15 homes or more, where viable. This target was significantly exceeded during 2009-2015, with 1045 new affordable homes provided per year on average, the majority grant funded.

6.36 The 2017 SHMA has updated housing need information and suggests that the affordable housing target should be higher, at 23.4% of total housing need or 832 homes per year. Looking at historic trends this should be deliverable, although this does depend on levels of grant funding available in future.

6.37 The Housing and Planning Act 2016 introduced starter homes as a new housing product for 23-40 year old first time buyers, to be sold on at a discount of at least 20% below market value for 15 years. The Act requires planning authorities to promote the supply of starter homes and allows a starter homes requirement to be set in local plans. Starter homes will at some point be classified as affordable housing through a change to the NPPF. However, the SHMA states that, in the Black Country, starter homes are not priced below entry-level market housing and are therefore not genuinely affordable within existing criteria. The SHMA sets out a separate estimate of the need for starter homes over the Plan period – 5.3% of total housing need, or 188 homes per year. Starter homes are likely to be cheaper for developers to provide than other affordable tenures, depending on detailed requirements which will be set out in regulations.

6.38 The Housing White Paper has since clarified that there will not be a statutory requirement to provide starter homes, but instead there may be a requirement for sites of more than 10 homes to provide 10% affordable home ownership, including starter homes and shared ownership products. This threshold is inconsistent with the 15 home threshold used in Policy HOU3. In addition, this requirement would reduce the ability of Policy HOU3 to deliver affordable rent products in line with local need.

6.39 In light of these factors, options need to be explored to increase affordable housing delivery on private sites. One option would be to increase the overall affordable housing proportion in Policy HOU3, therefore requiring developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. It may not be possible to secure this target on some sites due to viability. However, this is currently the case when applying the 25% requirement, as explained in para 3.15 of the Core Strategy.

6.40 Another option would be to reduce the eligible site threshold to over 10 homes or 1,000 sqm gross floorspace, in line with national guidance (NPPG para 31). A further option would be to introduce an increased affordable housing requirement for green belt release sites, where such an increase is likely to be financially viable.

(35) Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.

(27) Question 43a - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.

(6) Question 43b – If no, should it be reduced to 11 homes or more? Yes/No; Question 43c – If answered no to 43b, what threshold should be used?

(31) Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any Further comments.

(12) Question 44b -If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?

(28) Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.

(1) Policy HOU4 - Accommodation for Gypsies, Travellers and Travelling Showpeople

6.41 Policy HOU4 sets out indicative targets for gypsy and traveller pitches, travelling showpeople plots and transit pitches between 2008 and 2018. Site allocation documents and area action plans have since allocated some sites to contribute towards meeting these targets and a number of windfall sites have come forward. It is expected that the majority of new provision will be privately funded. Such sites are likely to be designed for single families and therefore smaller than local authority sites. Smaller sites are more likely to arise as windfalls, as has taken place in recent years.

6.42 A new Black Country and South Staffordshire Gypsy, Traveller and Travelling Showpeople Accommodation Assessment (GTAA) has been undertaken, in line with current national guidance, which has produced new targets for each authority for the period 2016-36 as set out in Tables 4 and 5. It is proposed to use the new targets to replace those in Core Strategy Table 9. The GTAA recommends that provision of transit sites or stopping places is explored, but proposes no specific targets for such provision. Such sites address short term issues and are best addressed through enforcement and police action, and the local authorities are working with the police to deliver transit sites and stopping places where appropriate. Therefore it is proposed to remove the transit site target from Core Strategy Table 9.

Table 4 Requirement for Gypsy and Traveller Residential Pitches (Black Country and South Staffordshire GTAA, 2017)

Local Authority

Existing pitches 2016

Need 2016-21

Need 2021-26

Need 2026-31

Need 2031-36

Total need 2016-36

Dudley

47

11

4

5

5

25

Sandwell

16

-1

1

1

1

2

Walsall

40

15

4

5

5

29

Wolverhampton

43

2

3

4

4

13

Black Country

146

27

12

15

15

69

Table 5 Requirement for Travelling Showpeople Plots (Black Country and South Staffordshire GTAA, 2017)

Local Authority

Existing plots 2016

Need 2016-21

Need 2021-26

Need 2026-31

Need 2031-36

Total need 2016-36

Dudley

12

8

2

2

2

14

Sandwell

15

5

2

2

2

11

Walsall

66

15

6

7

7

35

Wolverhampton

3

0

0

0

0

0

Black Country

96

28

10

11

11

60

(3) Question 46 - Do you agree with the proposed new gypsy, traveller and travelling showpeople accommodation targets? Yes/No; If no, please explain why.

Policy HOU5 - Education and Health Care Facilities

6.43 Policy HOU5 aims to protect existing networks of education and health care facilities and sets out locational criteria for new health care and education facilities. The public sector now has a significantly reduced role in direct provision and strategic planning for such facilities and it is increasingly difficult to ensure that alternative provision is secured when an existing facility is lost.

6.44 Since 2011 parts of the Black Country have seen significant investment in the school estate (through the former Building Schools for the Future programme, the Primary School Programme and expansions funded by local authorities) and in further and higher education investment (e.g. University of Wolverhampton). However, a national baby boom has significantly increased the need for new primary school places, which is now working through to secondary schools and is placing pressure on the school estate.

6.45 The funding regime for education and health has changed since 2011 with funding for education now being channelled through the Education Funding Agency rather than through local authorities. The Government expects all new schools to be academies or free schools. This makes it harder for local authorities to direct the provision of new or expanded schools to locations where there is existing need or need as a result of housing growth. Most health provision at the local level is also now commissioned through clinical commissioning groups.

6.46 Community Infrastructure Levy (CIL) has been adopted in Dudley and Sandwell, and is proposed in Walsall. However, the viability of development in much of the Black Country limits the amount of CIL that can be raised and there are competing infrastructure demands, so CIL cannot provide sufficient sums to wholly fund new education and health care facilities and running costs.

6.47 It is anticipated that Policy HOU5 will have a criteria based approach to making service providers demonstrate why health care and education facilities are no longer required or viable. Given the potential need for new and improved social infrastructure to serve new large housing developments, as identified in Part 5, there may be merit in expanding the scope of Policy HOU5 to cover other types of built social infrastructure, such as community meeting places, and to set out standards in the Policy to ensure that new communities are well served?

(19) Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing developments? Yes/No; If no, please explain why.

(7) Question 48 - Do you agree that the requirement in HOU5, to demonstrate there is adequate alternative provision to meet the needs of the community served by a facility which is to be lost, should be reviewed? Yes/No; If yes, please explain why.

(3) Policy Area C - The Black Country Economy

6.48 The employment land policies of the Core Strategy seek to ensure that a sufficient stock of employment land is available to meet demand and support the growth and diversification of the economy. At the heart of these Policies is a recognition of the need for a step-change in the quality of the employment land offer in order to attract growth sector high technology and logistics sector businesses. Areas of vacant or underused poor quality employment land which are incapable of accommodating future economic uses are proposed for release to other uses, especially housing.

6.49 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review. However, some of the individual policies may need updating as discussed below. Policy DEL2, which seeks to control the release of employment land to alternative uses, especially housing, has also been included.

(4) Policy DEL2 – Managing the Balance between Employment Land and Housing

6.50 This policy essentially manages the release of poorer quality employment land, primarily Local Quality Employment Land, for housing. It distinguishes between employment areas which are allocated for potential release for new housing and other employment areas, notably those areas which have been safeguarded for employment uses. The Policy is useful in enabling the appropriate delivery and phasing of new housing development on brownfield, former employment sites to meet a number of overarching objectives of the Core Strategy.

6.51 Issues have been identified in the application of this policy, e.g. can it be reasonably applied in the assessment of proposals for the change of use of employment land to uses other than housing, and is there a need for this policy when a site allocation on an employment area (determining whether it should be safeguarded for employment uses or potentially be released for housing) can be considered more determinant? However, not all of the employment land within the Black Country currently has been categorised along these lines, and there is an argument that there is still a need to manage the release of employment land sites where this is considered appropriate.

(33) Question 49a – Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.

(12) Question 49b - If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.

(3) Policy EMP1 – Providing for Economic Growth and Jobs

6.52 In order to support the delivery of these priorities, the Core Strategy distinguishes between Strategic High Quality Employment Land and Local Quality Employment Land, and quantifies how much occupied land (i.e. currently used for economic activity) should be provided in each category. This ‘stock’ approach is unusual as most development plans seek to quantify additional employment land needs only and do not establish how much land should be used to accommodate existing jobs. The overall employment land requirement is set out in Policy EMP1.

6.53 Policy EMP2 of the Core Strategy proposes a major uplift in the amount of Strategic High Quality Employment Land resulting from a combination of firstly the bringing forward of new sites and secondly investment in underperforming existing employment areas (Potential Strategic High Quality Employment Land). Policy EMP3 explains that the amount of Local Quality Employment Land is proposed to reduce as a result of the anticipated contraction in some traditional ‘land hungry’ employment sectors.

6.54 The overall effect of Policies EMP2 and EMP3 is that the total stock of employment land within the Black Country is proposed to contract from 3,565ha in 2009 to 3,392ha in 2016 and 2,754ha in 2026.

6.55 Monitoring and evidence collected to support the preparation of Area Action Plans and Site Allocations Documents has shown that the employment land stock has proved to be more resilient than envisaged when the Core Strategy evidence base was being prepared in 2008-09. This is due to a number of factors, including an ongoing and increasing demand for sites and premises associated with a resurgence in manufacturing coupled with a deficit in supply. Evidence also shows that many of the existing employment areas that were identified for potential release to housing are in multiple ownership and have high remediation costs, making them difficult to bring forward for redevelopment. The effect of these trends has been that, although the stock of Local Quality Employment Land contracted by 394 ha between 2009 and 2016, this contraction was 146 ha less than anticipated in Policy EMP3.

6.56 Performance against the delivery of the Strategic High Quality Employment Land targets has been mixed. In 2016, monitoring shows that there is some 641 ha of Strategic High Quality Employment Land in the Black Country with a further 109 ha in South Staffordshire. This total is 155 ha short of the target in Policy EMP2. However, the development of sites in South Staffordshire has been quicker than expected, delivering the total target for 2026 by 2016. Over 60 ha of additional sites which have the potential to meet Black Country needs are now being taken forward through the South Staffordshire Site Allocations Document.

6.57 The overall impact of more resilient Local Employment Areas combined with slightly disappointing performance against High Quality Employment Land targets is that the overall stock of employment land in the Black Country has fallen to 3,335 ha in 2016, broadly equivalent to the target in Policy EMP1.

6.58 The EDNA recommends a change in approach from the existing Core Strategy and that the Black Country should be planning for a net uplift in employment land in the review. The Study shows that, in order to plan for a resurgent manufacturing sector in particular, up to an additional 800ha of employment land is required for the period to 2036.

(23) Question 50a – Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.

(4) Question 50b - Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/No; Please explain why.

(1) Policy EMP2– Strategic High Quality Employment Land and Policy EMP3 – Local Quality Employment Land

6.59 The Core Strategy seeks to safeguard the best quality employment land for those uses that are most able to contribute towards the growth and diversification of the economy. Currently EMP2 identifies Strategic High Quality Employment Land as being characterised by excellent accessibility, high quality environment and clusters of high technology based sectors. Within these areas, new development is restricted to primarily manufacturing and logistics uses within Use Classes B1(b)(c), B2 and B8.

6.60 The EDNA advises that retaining this Policy approach will continue to give due prominence to high quality export led advanced manufacturing which has an important role to play in the rebalancing of the UK economy. However, the existing Black Country Strategic High Quality Employment Areas contain a wide mix of uses and activities, and the existing definition cuts across the conventional planning use classes and so it is possible for a High Quality employment use to change to a Local Quality employment use without the need for planning permission.

6.61 Local Quality Employment Areas are characterised by a critical mass of industrial, warehousing and service activity with good access to local markets and employees. These areas provide for manufacturing and warehousing activity but also other uses that need to be accommodated on industrial land as they play a significant part of the area’s economy, waste management and scrap metal, trade wholesale, construction, haulage/transfer depots and the motor trade.

6.62 The EDNA recommends that the Core Strategy should continue to focus these activities into particular areas so as not to compromise the quality of Strategic High Quality Employment Areas. However, in some cases, business operating in these sectors are associated with leading edge technology and require high specification, well located premises. Restricting such operations to Local Quality Employment Areas could be seen to be an overly restrictive approach in these circumstances.

(5) Question 51 – Do you think that the criteria used to define Strategic High Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

(5) Question 52 – Do you think that the criteria used to define Local Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

(4) Question 53 – Do you think that Strategic High Quality Employment Areas should continue to be protected for manufacturing and logistics uses, with the other uses set out in Policy EMP3 discouraged? Yes/No; if not, what alternative approach do you recommend?

Policy EMP4 – Maintaining a supply of readily available employment land

6.63 Policy EMP4 is intended to aid industrial development by maintaining a constant reservoir of readily available land that is ‘shovel ready’. However, it has proved difficult for the Black Country Authorities to reach this target due to the challenges of bringing forward sites associated with abnormal ground conditions and low rental / capital values. Employment sites often have long lead in times and the concept of ‘shovel ready’, though well intentioned, does not reflect the land development process in the Black Country.

6.64 The approach could also be seen to be too broad-brush in nature - it is based on a single quantum of land rather than what size, type or quality of sites is needed. So it is feasible that the total quantitative requirement could be met but this may be made up of a large number of sites which are too small to meet the needs of modern industry.

6.65 The EDNA advises that Policy EMP4 is subject to significant amendment and that there should be a move towards an approach which requires the provision of a balanced portfolio of sites rather than a simple arithmetic figure.

(6) Question 54 – Do you agree that the current approach in Policy EMP4 is no longer fit for purpose and should be amended to reflect a portfolio based approach? Yes/No; If no, what alternative approaches would you recommend?

(1) Policy EMP5 – Improving access to the labour market

6.66 Policy EMP5 encourages the use of planning obligations to be negotiated with the developers / owners of major, new job creating developments to secure initiatives and / or contributions towards the recruitment and training of local people.

6.67 It is important to retain this Policy in order that the jobs created in new and existing sectors of the economy can be made available to as many existing residents as possible. However, it would be useful to clarify that such contributions can be secured through planning conditions as well as through section 106 agreements.

(13) Question 55 - Do you agree with the proposal to retain Policy EMP5? Yes/No; If no please explain why.

Policy EMP6 – Cultural Facilities and the Visitor Economy

6.68 Policy EMP6 sets out priorities for developing and enhancing the visitor economy and other cultural facilities across the Black Country. It is proposed to update the lists of attractions and facilities which are listed in the Policy, in line with current priorities.

(11) Question 56 - Do you agree with the proposal to update Policy EMP6 in line with current priorities? Yes/No; If no, please explain why

(3) Policy Area D - The Black Country Centres

6.69 The 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. The existing Policies are based on the following objective:

6.70 ‘The unique character of the Black Country is largely defined by its network of centres and the relationships between them. This provides the basic spatial structure for the sub-region and is reflected in the 3 elements of the Vision. The Policies for Centres will ensure the network of Black Country Centres are consolidated, maintained and enhanced and will contribute to the delivery of Spatial Objectives 1, 2, 5, 7 and 8.’

6.71 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review. However, some of the individual policies may need updating as discussed below.

Policy CEN1: The Importance of the Black Country Centres for the Regeneration Strategy

6.72 The unique character of the Black Country is largely defined by its network of centres and the relationship between them. They are the focus for retail, leisure, commercial, community and civic uses. They provide the most accessible locations for public services, such as health and education facilities. The strategy is to maintain and enhance these centres in a manner appropriate to their role and function in the hierarchy, in order to deliver economic growth and support a viable network of centres to meet the needs of Black Country residents.

(2) Policy CEN2: Hierarchy of Centres

6.73 The adopted Core Strategy sets out a hierarchy of centres so that investment in town centre uses of an appropriate scale are promoted. “Main Town Centre Uses” are those uses contained in the NPPF, Annex 2: Glossary[1]. To maximise regeneration to protect the identified centres and ensure the sustainable distribution of investment, a hierarchy of centres, consisting of three levels, has been identified across the Black Country:

6.74 Strategic Centres. The Strategic Centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton will provide the main focus for comparison (clothes, white goods etc) shopping, office employment, large scale leisure and cultural facilities in the Black Country.

6.75 Town Centres[2] The Black Country Town Centres will complement the Strategic Centres and perform a more reduced shopping and business role but remain an important focus for day-to-day shopping (particularly convenience –‘food shopping), leisure, community and cultural activity. The town centres are characterised by being served by at least one anchor supermarket.

6.76 District and Local Centres. These Centres vary in scale but all portray characteristics that provide for day-to-day convenience shopping and services to meet local needs.

6.77 Each level in the hierarchy will have a specific policy approach reflecting its scale and function, although it is recognised that within the hierarchy there is a need for the different characteristics of individual centres to be acknowledged. This policy approach is important in helping to ensure that developments are located in a centre that will be most appropriate to the role and function of their scale, nature and catchment area.

6.78 The centres and retail evidence will look at how each of the centres is performing and this could lead to additions to or changes in the hierarchy. The current hierarchy is set out in Table 6.

Figure 11 Black Country Core Strategy Centres Key Diagram - Updated

image012


Table 6 Black Country Core Strategy Hierarchy of Centres - Updated[3]

Local Authority

Dudley

Sandwell

Walsall

Wolverhampton

Strategic Centres

- Brierley Hill

- West Bromwich

- Walsall

- Wolverhampton

Town Centres

- Dudley

- Stourbridge

- Halesowen

- Blackheath

- Cradley Heath

- Great Bridge

- Oldbury

- Wednesbury

- Cape Hill

- Bearwood

- Bloxwich

- Brownhills

- Aldridge

- Willenhall

- Darlaston

- Bilston

- Wednesfield

District and Local Centres

- Kingswinford

- Lye

- Sedgley

- Amblecote

- Cradley / Windmill Hill

- Gornal Wood

- Netherton

- Pensnett

- Quaryy Bank

- Roseville

- Shell Corner

- The Stag

- Upper Gornal

- Wall Heath

- Wollaston

- Wordsley

- Hawne

- Oldswinford

- Smethwick High Street

- Owen Street, Tipton

- Scott Arms

- Carter’s Green

- Quinton

- Princess End

- Old Hill

- Stone Cross

- Langley

- Hamstead

- Rood End

- Queens Head – Bristnall

- Smethwick High Street (Lower)

v Brandhall

v Bristnall

v Causeway Green

v Charlemont

v Crankhall Lane

v Dudley Port

v Hagley Road

v Hill Top

v Lion Farm

v St Mark’s Road

v Poplar Rise (City Road)

v Vicarage Road

v Tividale

v West Cross

v Whiteheath Gate

v Yew Tree

v Park Lane

- Caldmore

- Stafford Street

- Pleck

- Pelsall

- Leamore

- Palfrey

- High St Walsall Wood

- Rushall

- Blakenall

- Lane Head

- Streetly

- Queslett

- Lazy Hill

- New Invention

- Bentley

- Park Hall

- Moxley

- Fullbrook

- Collingwood Dr. Pheasey

- Birchills

- Coalpool / Ryecroft

- Beechdale

- The butts

- Spring Lane

- Shelfield

- Beacon Road, Pheasey

- Brackendale

- Woodlands

- Shelfield

- South Mossley

- Dudley Fields

- Streets Corner

- Buxton Road, Bloxwich

- Coppice Farm

- Turnberry road, Bloxwich

- Stafford Road (Three Tuns)

- Cannock Road (Scotlands)

- Tettenhall Village

- Whitmore Reans / Avion Centre

- Broadway

- Bushbury lane

- Showell Circus

- Wood End

- Stubby Lane

- Heath Town

- Parkfield

- Spring Hill

- Penn manor

- Upper Penn

- Penn Fields

- Bradmore

- Merry Hill

- Castlecroft

- Finchfield

- Tettenhall Wood

- Newbridge

- Aldersley

- Pendeford Park

- Fallings Park

- Ashmore Park

- Compton Village

- Warstones Road

- Dudley Road (Blakenhall)

o Chapel Ash

v New local centres identified in Sandwell Site Allocations and Delivery DPD (2012)

o New local centre identified in Wolverhampton City Centre Area Action Plen (2016)

(5) Question 57 – Do you support the proposal to merge Policy CEN1 and Policy CEN2, given that both policies focus on the overall strategy in the Black Country, including the hierarchy of centres? Yes/No; If you have any comments on Policies CEN1 and CEN2 please provide details.

(5) Question 58 – Do you think there is any evidence to suggest that the hierarchy of centres is not appropriate going forward in the context of the regeneration strategy? Yes/No; If so, please provide details.

(4) Question 59 – Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.

(5) Question 60 - Is there evidence to suggest that identified centres are no longer performing as a centre or at their identified level in the hierarchy? Yes/No; If Yes, do you agree that they should be moved / removed within or out of the hierarchy? Please explain why.

(10) Question 61 - In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?

Policy CEN3: Growth in the Strategic Centres

6.79 Town centres today are facing a multitude of challenges to their continuing vitality and viability. Many High Streets are characterised by falling retail sales, reduced footfall, increased business failures and rising vacancies. The growth of internet shopping and multi-channel retailing also means that many retailers are actively seeking to reduce rather than increase their store portfolios. There is a need to consider the changing character of the High Street with an increased move towards leisure and service uses within core retail areas, more mixed use schemes and pressure to provide homes to meet future needs and provide a resident population for centres to serve.

6.80 At the same time there is continued competition from existing and new out-of-centre large format retail and mixed use schemes. The quantity of comparison retail, convenience retail and other uses to plan for in the Strategic Centres is therefore a key issue for the Core Strategy. The level of town centre activity and floorspace in the Black Country centres is affected by consumer and businesses trends and the wider economy in ways that will impact on the spending power available. There is also a need to plan for the population and housing growth that is predicted for the Review period up to 2036.

6.81 It is important to strengthen and diversify the Black Country economy. It is believed that concentrating office investment in the Strategic Centres is the best way to build an office market and ensure the viability of centres which provide a balanced range of uses and employment provision. However, monitoring has shown that delivering large scale office development has been a challenge and it is proposed to reassess the target for office development to take account of recent experiences and future trends.

6.82 Policy CEN3 will be reviewed in the context above and ‘The Centres and Retail Evidence’ will be updated to assess national trends in main town centre uses, provide realistic floorspace figures to plan for, and comment on the implications for the Black Country’s Centres in terms of the existing policy approach, including impact testing thresholds. The policy will also be reviewed in light of the Area Action Plans that have been produced for the Strategic Centres since the adoption of the Core Strategy.

(5) Question 62 - Do you agree that the Strategic Centres should remain the focus for large scale comparison retail (clothes, white goods etc), office and major commercial leisure development in the Black Country? Yes/No; Any further comments?

(6) Question 63 - Do you agree that the targets for comparison retail floorspace and office floorspace should be revisited as part of this review to take into account current and future trends? Yes/No, Any further comments?

(5) Question 64 - Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?

(8) Question 65 - Should the Core Strategy set any targets or policy requirements for leisure development in the Strategic Centres? Yes/No; Any further comments?

(4) Question 66 - Should the Core Strategy set new housing targets for the Strategic Centres through the review? Yes/No; Any further comments?

(6) Question 67 - Do you think there are any other uses and/or developments that should be planned for in the Strategic Centres Yes/No; Please provide details.

Brierley Hill Retail Pre-Conditions

6.83 The Core Strategy imposed three conditions on new Comparison retail development within Merry Hill (part of Brierley Hill Strategic Centre). Brierley Hill Area Action Plan which was adopted in 2011 translated these into two conditions. The conditions are:

  • Implementation of improvements to public transport, including completion of initiatives of equivalent quality and attractiveness to the proposed Metro extension from Wednesbury to Brierley Hill, and improvements to bus services connecting the centre with other locations in the Black Country and beyond, and other measures to improve accessibility to and circulation within the centre by non-car modes; and
  • Introduction of a car parking management regime including the use of parking charges compatible with those in the region’s network of major centres.

(7) Question 68 - Do you agree with the proposal to re-examine the detail and appropriateness of the existing conditions for retail growth at Merry Hill through the Core Strategy review? Yes/No; Do you have any further comment to make on this issue?

(1) Policy CEN4: Regeneration of Town Centres

6.84 The network of Town Centres in the Black Country provide for convenience (food) and local comparison shopping, local services, community and leisure facilities. The comparison shopping role of many of these centres has declined over the last decade or so and many of the centres do not offer the physical capacity for future major development, and find it difficult to attract significant retail and/or other commercial investment. However, the Core Strategy’s potential housing growth options may lead to a need for further convenience shopping and mixed use development in certain town centres once the housing locations are determined.

(8) Question 69 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country Town Centres? Yes / No; Please explain why.

(7) Question 70 – Do you think there are any specific developments or uses that should be supported in any particular Town Centre? Yes/No; Please provide details.

(10) Question 71 - Should the Core Strategy set housing targets for the Town Centres? Yes/No; Please explain why.

(1) Policy CEN5: District and Local Centres

6.85 A network of District and Local Centres provide for day-to-day local shopping and service needs. Many of the centres act as the heart of the local community with community halls, libraries and religious buildings. The majority benefit from good public transport, walking/cycling links and car parking provision.

6.86 The adopted Core Strategy established a ‘three level hierarchy of centres’ in the Black Country which resulted in the identification of two new Local Centres at Hawne and Oldswinford in Dudley and also the removal of Darlaston Green within Walsall from the hierarchy. Para 4.33 of the Core Strategy states that the designation of new local centres could come forward through relevant Local Development Documents (such as Area Action Plans and Site Allocation Documents).

6.87 Since adoption of the Core Strategy, the Sandwell Site Allocation Document (SAD) has identified 17 new centres. Following adoption of the SAD in 2012 these centres have been designated local centres and have therefore been added to the hierarchy. The Wolverhampton City Centre Area Action Plan (AAP), adopted in 2016, designated a new local centre at Chapel Ash. Through Walsall’s emerging SAD a new local centre has been identified – Blackwood Local Centre. Following the anticipated adoption of the SAD in 2017 this centre will be a recognised established centre in planning policy terms. An updated Core Strategy Hierarchy of Centres is set out in Table 6.

6.88 Detailed boundaries for any proposed new centre and any adjustments made to existing centre boundaries will be delivered through Local Development Documents prepared by each individual local planning authority.

(7) Question 72 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country District and Local Centres? Yes/No; Please explain why.

(2) Question 73 - Are there are any specific developments or uses that should be supported in any particular District or Local Centre? Yes/No; Please provide details.

The Centres Threshold Approach

6.89 Reflecting the priority to steer regeneration to the most sustainable locations, development in out-of-centre locations should be carefully managed by policy to avoid undermining the strategy for growth in centres. To ensure this, the policies include a floorspace and threshold approach for the undertaking of impact tests, as set out in Table 7. Development is not precluded above these thresholds, but simply set appropriate local triggers for proportionate testing of proposals to ensure they support balanced growth across the Black Country and do not individually or cumulatively lead to harmful impacts. Policies CEN3-5 set floorspace thresholds for convenience and comparison retail development to ensure retail growth is focused in the appropriate centres according to their level in the hierarchy. In some cases they also provide thresholds for office and other centre uses. Policies CEN6 and CEN7 sets floorspace thresholds for out-of-centre applications.

Table 7 The Centres Threshold Approach

Type of Centre

Area for Application of floorspace thresholds

Assessment Required

Strategic Centre

Brierley Hill

West Bromwich

Walsall

Wolverhampton

Comparison retail – in centre proposals

Comparison retail – edge of centre proposals

Convenience retail – in centre and edge of centre

Over 500 sq. metres gross if the proposal would result in the overall targets for comparison retail being exceeded.

Over 500 sq. metres gross OR

for proposals that are below this threshold which are considered to have significant impact on the centres.

Over 500 sq. metres net OR for proposals that are below this threshold which are considered to have significant impact on the centres.

Town Centres

See Hierarchy

Comparison retail – In centre for all Town Centres EXCEPT Dudley

Convenience retail – In centre for all Town Centres EXCEPT Dudley

Comparison retail – Edge of centre EXCEPT Dudley

Convenience retail – Edge of centre EXCEPT Dudley

DUDLEY Town Centre only

Comparison retail – In Centre

Convenience retail – In Centre

Comparison retail – Edge of Centre

Convenience retail – Edge of Centre

Offices (B1(a)) – In Town Centres

Over 500sq metres gross demonstration of appropriate scale

Over 650 sq metres net demonstration of appropriate scale

Over 500 sq metres gross OR for proposals that are below this threshold which are considered to have significant impact on the centres.

Over 650 sq metres net OR for proposals that are below this threshold which are considered to have significant impact on the centres.

demonstration of appropriate scale if the proposal would result in the overall targets for comparison retail being exceeded (15,000sq metres gross)

demonstration of appropriate scale if the proposal would result in the overall targets for convenience retail being exceeded (5,000 sq metres net)

any proposal if it would result in the overall targets for comparison retail being exceeded (15,000sq metres gross)

any proposal if it would result in the overall targets for convenience retail being exceeded (5,000 sq metres net)

Over 5000 sq metres gross

District & Local Centres

See Hierarchy

Comparison retail; Office (B1(a)); Leisure – In Centre

Convenience retail – In Centre

Comparison retail; Office (B1(a)); Leisure – Edge of Centre

Convenience retail – Edge of centre

Over 200 sq metres gross demonstration of appropriate scale

Over 500sq metres net demonstration of appropriate scale

Over 200 sq metres gross OR for proposals that are below the threshold but which are considered likely to have a significant impact.

Over 500 sq metres net OR for proposals that are below the threshold but which are considered likely to have a significant impact.

Strategic Centres

6.1.1 The strategy for the Strategic Centres proposed large amounts of comparison floorpsace. Therefore impact assessments would only be required for in-centre proposals over 500sqm that would result in these overall targets being exceeded.

6.1.2 Impact assessments are required for any edge of centre comparison retail proposals that exceed 500sqm but also for proposals that are below this threshold which are considered to have a significant impact on the centres.

6.1.3 In terms of convenience retail any proposals for above 500sqm of net floorspace in Strategic Centres require impact assessments, as do edge-of-centre proposals that exceed this threshold. Again impact assessment can be requested for proposals that are below the threshold but which are considered likely to have a significant impact.

Town Centres

6.1.4 Individual proposals for above 500sqm comparison retail and above 650sqm net convenience retail in all town centres, other than Dudley, will have to show they are of appropriate scale.

6.1.5 Individual proposals for above 500sqm comparison and 650sqm net convenience retail in edge-of centre locations in all centres other than Dudley will require impact assessments. Impact assessment can be requested for proposals that are below the threshold but which are considered to have a significant impact.

6.1.6 For Dudley in centre proposals that would result in the total amount of additional comparison exceeding 15,000sqm and the total amount of additional convenience floorspace exceeding 5,00sqm net will need to show they are of appropriate scale and edge of centre schemes that result in the total figures being exceeded require impact assessments.

6.1.7 There are also thresholds for offices in town centres to ensure they do not go beyond meeting their local service function and draw investment away from the Strategic Centres. Up to an additional 5,000sqm of gross office B1(a) development is allowed in each town centre with any development exceeding this figure requiring an impact assessment.

District and Local Centres

6.1.8 Proposals of up to 500sqm net convenience retail and proposals for comparison, office or leisure uses of up to 200sqm will be permitted where they are shown to be of an appropriate scale. Edge of centre schemes above these thresholds will require impact assessments. Impact assessment can be requested for proposals that are below the threshold but which are considered to have a significant impact.

(5) Question 74 - In the context of the ‘centres first’ strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of Strategic, Town, District and Local Centres? Yes/No; Please explain why.

(2) Question 75 - Should thresholds apply to all main town centre uses (Yes) or just retail uses (No)? Please explain why.

(1) Policy CEN6: Meeting Local Needs for Shopping and Services

6.1.9 In addition to the hierarchy of centres there is an extensive network of small parades and local shops meeting essential day-to-day needs of communities within walking distance. Policy CEN6 protects such facilities unless it can be demonstrated they are no longer viable. The policy allows for new facilities that are not in a centre of up to 200 sq.m gross, or extensions which would create a total development of 200 sq.m gross, subject to demonstrating need, and/ or deficiencies in the existing provision of convenience shopping, main town centre uses, health and educational facilities. Proposals are subject to meeting strict criteria to ensure development complements the regeneration strategy for centres. Larger scale developments (over 200sq m gross) have to meet the requirements of Policy CEN7.

6.1.10 The potential levels of housing growth in the Black Country up to 2036 means that Policy CEN6 is likely to be a key consideration where new local facilities are proposed to meet the specific needs of new housing development, as recognised in Policy HOU2.

(4) Question 76 - Is the approach set out in Policy CEN6 appropriate in the context of supporting local community needs? Yes/No; Please explain why.

(2) Question 77 - Does the wording of the criteria clearly achieve the objectives of the centres strategy? Yes/No; Please explain why.

(2) Question 78 - Should the policy clarify that this policy applies both to applications in edge-of-centre and out-of-centre locations, and should this also be referred to in the relevant centres policies? Yes/No; Please explain why.

(2) Question 79 - Should the policy set what types of uses this policy applies to and set out any further types of material considerations that could be relevant for the determination of certain proposals, for example, the location or concentration of hot food takeaways, premises selling alcohol or gambling operations? Yes/No; Please explain why.

(1) Question 80 - Should the policy clarify that those schemes of multiple units, where individual units are below the set figure, but the cumulative figure is above, also need to meet the relevant requirements of other centres policies? Yes/No; Please explain why

Policy CEN7: Controlling Out-of-Centre Development

6.1.11 The Spatial Strategy is based upon major investment in the network of centres in the Black Country, with the exception of developments to meet specific local ‘day-to-day’ needs which are permitted under Policy CEN6. Therefore, developments outside of centres need to show there is a clear justification why proposals cannot be accommodated within or, failing that, on the edge of any appropriate centre.

6.1.12 In accordance with national policy and to support the strategy, Policy CEN7 states that any proposal for a town centre use in an out-of-centre location, whether brought forward through a Local Development Document or planning application, will only be considered favourably if the sequential andimpact assessments contained in the most recent national guidance are satisfied. As Policy CEN6 applies to proposals up to 200sqm (gross), this means that any application above 200sqm (gross) should undertake the impact tests. The policy also states that it is important to ensure developments are accessible by a choice of means of transport.

6.1.13 The policy approach in CEN7 also applies to applications for extensions and variation of conditions.

(7) Question 81 – Do you agree that the approach of strong control over out-of-centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Country Centres? Yes/No; Please explain why.

(3) Question 82 - Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.

(1) Question 83 - Should Policy CEN7 provide more guidance on accessibility? Yes/No; If yes, please explain why .

Policy CEN8: Car Parking in Centres

6.1.14 The provision, location, type and charging of car parking has an important role to play in the sustainable growth of the Strategic Town Centres. It also supports the sustainability principles embedded within the Core Strategy transport strategy to manage demand and influence travel behaviour towards sustainable modes (Polices TRAN2 and TRAN5). A key principle of the approach towards car parking is that unless justified car parking will serve the centre as a whole in order to support the centres vitality and viability.

6.1.15 Walsall, Wolverhampton and West Bromwich Strategic Centres all have a parking management regime in place including charging. As a result of the historical development and unique nature of the Merry Hill shopping centre, Brierley Hill is the only one of the four Strategic Centres that does not currently have car parking charges in place. Hence, Policy CEN8 specifically refers to charging policy for parking to ensure parking policy at the local level is not used as a tool for competition between the centres. The detail of how the policy will be implemented at the local level will be through Development Plan Document’s/ Area Action Plans, in accordance with the principles of Policy CEN8.

6.1.16 Non-Strategic Centres have increasingly struggled to compete with the more dominant higher order centres and out-of-centre shopping provision with free car parking. As a result, the policy requires that a lower pricing regime may be identified for Town, District and Local Centres. The provision of parking in new developments within centres will be managed through Development Plan documents, including Town Centre Area Action Plans and Supplementary Planning Documents prepared by individual local planning authorities.

(3) Question 84- Do you think that Policy CEN8 is still appropriate for managing car parking in centres and will ensure the network of Black Country Centres are maintained and enhanced over the plan period? Yes/No; Please explain why.

(2) Question 85 - Should Policy CEN8, with regards to pricing of car parks, continue to be applied to Strategic Centres to ensure that pricing of parking is not used as a tool of competition? Yes/No; Please explain why.

Other Centres Issues

(4) Question 86 – Do you think that there are other centre uses or centres issues that need to be addressed in the centres policies? Yes/No; Please provide details.

(4) Question 87 - As shopping, leisure and other commercial trends continue to change, should the revised Core Strategy have a policy to reallocate out-of-centre attractions that are no longer viable for town centre uses for alternative uses such as for employment uses or housing? Yes/No; If no, please explain.

(6) Policy Area E - The Black Country Transport Network

6.1.17 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review. However, some of the individual policies may need updating as discussed below.

(1) Policy CSP5 Transport Strategy

6.1.18 The Transport policies of the Core Strategy seek to ensure that reliable and efficient transport networks to support national economic competitiveness and growth are provided. Improved access to key destinations is vital to achieve the required step change in the quality and extent of the network to reverse the outward migration of population from the Black Country and to support economic and social aspirations. It is important the network provides rapid, convenient and sustainable links between the Strategic Centres of the Black Country and wider West Midlands, housing growth areas, employment areas, local communities and the regional and national transport networks.

6.1.19 Since the publication of the Core Strategy, the Combined Authority’s strategic transport plan “Movement for Growth” has been developed and adopted. This strategy is based on making better use of existing capacity and providing new sustainable transport capacity to support regeneration and growth in the West Midlands. The strategy is to create an overall integrated transport system serving the West Midlands based on four tiers:

6.1.20 National and Regional Tier:National highway connections, based on Highways England’s strategic highway network of motorways and trunk roads. National and regional passenger rail services and coach services, rail freight capacity and rail freight interchanges.

6.1.21 Metropolitan Tier: An integrated Metropolitan Rail and Rapid Transit Network (Rail, Metro, Bus Rapid Transit, Tram-train) with high quality main centre interchanges and supporting park and ride provision. A Key Route Network of main roads. A “flagship” Metropolitan Strategic Cycle Network.

6.1.22 Local Tier: High quality local bus services integrated with the rail and rapid transit network, accessible transport, local roads, local cycle networks integrated with the Strategic Cycle Network and attractive, safe conditions for walking and cycling.

6.1.23 Smart Mobility Tier:Intelligent mobility services to help make the most of transport capacity and help inform people of the travel options available to them. This includes the development and delivery of a trial “Mobility as a Service” (MaaS) initiative.

6.1.24 The Core Strategy sets the agenda for the transformation of the Black Country transportation network. It identifies the key factors required to enhance the transport infrastructure and assist delivery of the Spatial Objectives for the area:

  • Improved accessibility of services to the population
  • Improved connectivity through an integrated public transport network, including future links to High Speed Rail
  • Improved road networks and links to the national M5 and M6 motorway network
  • Improved access to the freight railway network for HGV’s and better management of their movements
  • Improved walking and cycling provision
  • Increase in use of low –emission vehicles

6.1.25 The large-scale land use changes proposed in the Core Strategy require an effective and integrated transport network which will serve existing and new developments and promote greater use of sustainable transport modes, (walking, cycling public transport and car sharing) helping to reduce the growth in car borne journeys. This transport strategy for the Black Country is intended to reflect the following strategic outcomes:

  • Enabling the expansion of strategic centres
  • Providing communities with improved access to employment, residential services and other facilities and amenities, with travel choices that are attractive, viable and sustainable
    Improving air quality and helping to address negative impacts on climate change
  • Improving the accessibility of employment sites to residential areas
  • providing reliable access for freight to the national motorway network
  • Facilitating access to employment areas, particularly strategic high quality employment opportunities
  • Containing congestion by developing and managing transport networks to operate more efficiently
  • Improve road safety
  • Supporting the strategy through demand management (such as pricing, availability of car parking and road user charging) and the promotion of sustainable transport
  • Improve access to information relating to travel options for visitors, businesses and local people.

6.1.26 The transport objectives for the Core Strategy continue to reflect:

  • Current National transport guidance and ‘Movement for Growth’ the current West Midlands Strategic Transport plan;
  • The vision and Spatial objectives for Black Country;
  • Existing and Future transport challenges

The Black Country Strategic Economic Plan

6.1.27 The government’s DaSTS goals for transport have been superseded by new advice, which is captured within the Movement for Growth document. The transport strategy and policies in the Core strategy reflect the approach in West Midlands Strategic Transport plan ‘Movement for Growth’, which covers a twenty year period. The shared long term vision remains the same.

6.1.28 The technical work undertaken by PRISM modelling to inform the development of the Black Country Core Strategy demonstrated that the various multi modal networks continue to function during the plan period and that planned interventions deliver improvements to their performance. However, following the issues and options stage further transport modelling will be undertaken to forecast the traffic impacts of the specified green belt scenarios, identify locations that may require further investigation regarding traffic impacts and identify the transport infrastructure requirements for any potential new green belt sites (including highway, public transport, walking & cycling routes). An emphasis on ‘Smarter Choices’ and the recognition of the benefits to be secured by embracing and promoting the advantages of new technologies, such as broadband, video conferencing and internet shopping, assists in achieving the transport outcomes in the long term.

6.1.29 The Highways England Road Investment strategies integrate with the Core Strategy approach. Work commissioned by Midlands Connect, the joint East-West Midlands transport partnership, is studying the Midlands Motorway Hub. This will identify nationally significant infrastructure with short, medium and long term priorities which will impact on the Black Country. The Midlands Connect inter-regional transport strategy will be published in spring 2017. HS2 brings with it new drivers for access to rail interchange, and opportunities for the re-casting of services within the local rail network.

6.1.30 Proposals to enhance the connectivity of the region to HS2 have been assessed and corridors within the Black Country identified as priorities for investment at a West Midlands and sub regional level.

6.1.31 The primary evidence remains appropriate, with additions in the form of:

  • Movement for Growth
  • West Midlands HS2 Connectivity Strategy
  • Midlands Connect Emerging Strategy (Jan 2017)

(7) Question 88 - Do you agree that the overall transport strategy supports all of the Core Strategy spatial objectives? Yes/No; Please explain why.

Policy TRAN1 – Priorities for the Development of the Transport Network

6.1.32 The Core Strategy seeks to identify ways to deliver an improved and integrated transport network both within the Black Country and in links with regional and national networks. The regional and national landscape for transport has changed significantly since the adoption of the Core Strategy. The wider West Midlands has formed a Combined Authority, a new body for the development and promotion of nationally significant infrastructure has been established in the form of Midlands Connect and High Speed 2 (HS2) is set to be delivered.

6.1.33 The West Midlands Strategic Transport Plan: Movement for Growth outlines an approach to transportation described above. Movement for Growth provides a significant part of the transport evidence base for the Core Strategy review.

6.1.34 Since the adoption of the Core Strategy in 2011 the following TRAN1 priority improvements have been delivered or are committed for delivery in the short term:

  • Darlaston SDA access scheme completed,
  • I54 motorway access in place,
  • Metro Line 1 Improvements complete,
  • Burnt Tree Junction improvement delivered,
  • Junction 9 of M6 improvement works complete,
  • Active Traffic Management and Hard Shoulder Running on M6 in Black Country complete,
  • Red Routes package 1 completed,
  • Established West Midlands Rail Ltd to increase local influence over rail passenger services.
  • Wolverhampton Interchange (Bus Station) completed,
  • Wolverhampton Interchange (train station) and Metro Strategic Centre Extension now committed,
  • Midland Metro between Wednesbury and Merry Hill / Brierley Hill committed.

6.1.35 It is proposed to update the Core Strategy Transport Key Diagram to show delivered, committed and remaining priorities.

6.1.36 The TRAN1 policy remains appropriate, but the key transport priorities are now considered by the Black Country authorities to be:

  • Continue to provide rapid transit extensions to the Midland Metro and re-introduce rail services to connect the Black Country Strategic Centres to each other and Birmingham. First priority now being to complete committed schemes for Wednesbury to Merry Hill / Brierley Hill and Wolverhampton Interchange Strategic Centre Extension
  • Improving M5 junction 1 and Birchley Island adjacent to J2
  • Improving junction 10 of M6
  • Active Traffic Management and Hard Shoulder Running through M6 / M5 interchange to M5 Junction 3
  • Delivering a quality bus network across the Black Country, Improving access from the Black Country to Birmingham Airport and the two Future HS2 stations in the West Midlands.
  • Highway improvements to support regeneration in strategic centres and key growth locations
  • Multi-modal whole corridor investment in the Black Country’s main roads which form part of the West Midlands Key Route Network
  • West Midlands Strategic Cycle Network links in the Black Country
  • Development of road to rail freight interchange facilities to serve the sub region

6.1.37 Priority will also be given to the implementation of the other projects identified in the West Midlands Strategic Transport Plan: Movement for Growth, particularly local rail improvements, transport interchanges and park and ride sites, including:

  • Improved rail passenger services,
  • Walsall to Wolverhampton passenger rail,
  • Improvements to existing railway stations, and provision of new railway stations to meet demand at particularly Aldridge, Willenhall, James Bridge Enterprise Zone and Portobello.

6.1.38 Other corridors where the public transport demand would support rapid transit include:

  • Stourbridge to Brierley Hill,
  • A456 Hagley Road from Birmingham to Quinton,
  • A449 Stafford Road from Wolverhampton to i54,
  • A34 Walsall to Birmingham

(8) Question 89 - Do you support the proposed changes to the priorities for the development of the transport network? Yes/No; Please explain why.

Policy TRAN2 – Managing Transport Impacts of New Development

6.1.39 An even greater focus on choice of modes for access to new developments, including electric vehicle charging infrastructure, use of low emission vehicle technology and provision for cycles and motorcycles is needed. Smart mobility and mobility as a service should also be recognised for its role in supporting modal choice.

(4) Question 90 - Do you support the proposed changes relating to managing transport impacts of new developments? Yes/No; If no, please explain why.

Policy TRAN3 – The Efficient Movement of Freight

6.1.40 The spatial objectives for freight remain the same and there are proposals coming forward for Rail Freight Interchange at Bescott and Four Ashes which support the sub regional economy. References to the Principal Road Network should now be changed to Key Route Network, as defined by the West Midlands Combined Authority.

(5) Question 91 - Do you support the proposed changes relating to the efficient movement of freight? Yes/No; If no, please explain why.

(1) Policy TRAN4 – Creating Coherent Networks for Cycling and Walking

6.1.41 Walking and Cycling strategies are incorporated within ‘Movement for Growth’ and the West Midlands Cycle Charter, with targets to raise levels of cycling across the West Midlands to 5% of all trips by 2023 and 10% by 2033. The four Black Country Local Authorities have a combined walking and cycling strategy and use funding allocated through the Integrated Transport Black and competitive opportunities to make infrastructure improvements.

6.1.42 A map of the Black Country cycling investment opportunities has been developed as part of the Black Country Cycling and Walking Strategy, to identify, missing links, barriers and whole route improvements through the Black Country and connecting with adjacent authorities.

6.1.43 In order to achieve a coherent Black Country and West Midlands cycle network, the four local authorities have agreed to follow the West Midlands Cycle Charter for design principals.

6.1.44 It is proposed to update the Cycle Network Diagram to reflect the Walking and Cycling Strategy.

(5) Question 92 - Do you support the proposed approach to providing a coherent network for walking and cycling? Yes/No; Please explain why.

Policy TRAN5 – Influencing the Demand for Travel and Travel Choices

6.1.45 The Black Country Local Authorities are committed to considering all aspects of traffic management in the centres and wider area in accordance with the Traffic Management act 2004. It is proposed to retain the current priorities for traffic management in the Black Country, but to add a reference to further joint working to develop the identified West Midlands Key Route Network in order to manage region-wide traffic flows, and to introduce the following new priorities:

  • Introducing opportunities for new transport technologies, including ultra low emission vehicles, new traffic systems and smart ticketing,
  • Promoting mobility as a service.

(4) Question 93 - Do you support the proposed changes to Policy TRAN5? Yes/No; Please explain why.

(9) Policy Area F - The Black Country Environment

Environmental Infrastructure and Place-Making

6.1.46 Environmental infrastructure is a key theme of the Core Strategy Vision and there are a range of policies in the Core Strategy, supported by other Local Plan policies and proposals, to help deliver this transformation and support regeneration. Since adoption of the Core Strategy there has been progress in a number of areas. Environmental proposals have been taken forward in Development Plan Documents (DPDs) and historic landscape characterisation studies have been completed. An up-to-date Black Country Environment Spatial Plan is being produced to draw together existing evidence underpinning the review and work to define ecological networks within the Black Country is underway.

6.1.47 Work is also underway to develop viable Garden City principles (visit www.tcpa.org.uk/garden-city-principles for more details of these principles) which could be applied to housing-led developments in the Black Country, covering sustainable transport and green infrastructure networks, biodiversity gains, carbon emission reductions and climate change resilience.

6.1.48 Adoption of DPDs setting out detailed and deliverable environmental proposals has removed the need for Environmental Infrastructure Guidance Phase 2, therefore it is proposed to remove references to this throughout the Core Strategy. It is also proposed to update environmental proposals in Appendix 2 of the Core Strategy to reflect adopted DPDs and include new proposals to address the environmental infrastructure needs of new developments in light of up-to-date evidence. If Garden City principles are agreed, any additional requirements could be inserted in Policy CSP3: Environmental Infrastructure. It is also proposed to remove reference in Policy CSP3 to renewable energy generation as a form of environmental infrastructure, as this implies that expanding renewable energy generation would always be appropriate whereas it is not always possible to support such expansion. Policies CSP3 and CSP4: Place -Making would otherwise remain unchanged.

(16) Question 94 - Do you support the proposed changes relating to environmental infrastructure and place-making? Yes/No; If you think that any other changes should be made to Policies CSP3 or CSP4, please provide details.

(26) Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?

(10) Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

(4) Policy ENV1 - Nature Conservation

6.1.49 This Policy has worked effectively to protect and enhance biodiversity and geodiversity across the Black Country. It is proposed to amend the Policy to include Ancient Woodland in the list of nationally designated sites and to bring the wording on mitigation into line with NPPF para 152. It is also proposed to add to the list of requirements for new development the incorporation of biodiversity features, such as new natural green space, use of native species and nest boxes, as this is supported by para 118 of the NPPF. To update the supporting text, it is proposed to include reference to the Black Country Geopark.

(20) Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?

(4) Policy ENV2 - Historic Character and Local Distinctiveness

6.1.50 This Policy strengthened previous approaches to the historic environment in the Black Country which recognises and builds on the diverse character of the area. Historic Landscape Characterisation (HLC) principles have been used to define locally distinctive elements of the Black Country and guide local policies and proposals. This work does not indicate the need to amend the list of locally distinctive elements listed in the Policy. It is proposed to update the Policy to reflect latest national policy and guidance, particularly in relation to Design and Access Statements (which are not now required).

(12) Question 97 - Do you support the proposed changes relating to Historic Character and Local Distinctiveness? Yes/No; If no, please provide details of any other changes that should be made to Policy ENV2.

(2) Policy ENV3 - Design Quality

6.1.51 Since the Core Strategy was adopted housing standards have been simplified at a national level. It is not now possible to require a particular Code for Sustainable Homes Level, so it is proposed to remove this requirement from Policy ENV3: Design Quality. However, it is possible for Local Plans to introduce separate national standards for water consumption, access and space.

6.1.52 A lower than normal water consumption rate could be required for new build homes if this is supported by evidence of clear need. The Black Country does not currently lie in an area of serious water stress, as defined by the Environment Agency, therefore clear need may be difficult to demonstrate. The Black Country is covered by two water companies – South Staffordshire and Severn Trent and so there may be a need to introduce a water consumption standard in one company area but not the other.

6.1.53 A specified % of new build homes could be required to meet access standards M4(2) accessible and adaptable or M4(3) wheelchair user (the equivalent of Lifetime Homes). These standards would make housing usable or easily adaptable for those with disabilities and there is evidence of local need for such housing, however the standards would make housing more expensive to build and might not be achievable for certain types of housing.

6.1.54 The Housing White Paper (2017) states that there will be a review of the national space standard, which could be reduced or removed. However, if there are no changes, the Nationally Described Space standard (CLG, March 2015) could be introduced through the Core Strategy, covering internal floor area and dimensions for key parts of the home. This would need to be justified by evidence of current build sizes and impact on viability. Given that the standard is modest and is generally met in new build housing across the Black Country, and that Black Country overcrowding rates are higher than the national average, it is likely that introduction of this standard would be viable and would help to achieve better living conditions.

(17) Question 98 - Do you support the proposed changes relating to Design Quality? Yes/No; If you think that any other changes should be made to Policy ENV3 please provide details.

(15) Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

(14) Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

(26) Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

(19) Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

(1) Policy ENV4 - Canals

6.1.55 This Policy was developed in close collaboration with the Canal and River Trust and provides a comprehensive approach to dealing with proposals affecting canals which remains appropriate. There are a number of potential projects which involve the addition to, or restoration of, sections of the canal network within and outside of the Black Country which might affect its waterways. While the current Core Strategy is generally supportive of such projects, the associated technical challenges, such as water availability and compliance with Habitats Regulations, can require a detailed consideration of project feasibility to justify any support. Therefore, it is considered that canal projects require a fine grained approach that is not suited to a strategic document such as the Core Strategy and it is proposed to remove references to canal projects, specifically the restoration of the Hatherton Branch Canal, from the Core Strategy, as part of the review. Such projects could then be considered at a local level, where appropriate, through preparation of site allocation documents and area action plans.

(11) Question 100 - Do you support the removal of the reference made to canal projects? Yes/No; Do you think that any other changes should be made to Policy ENV4? Please provide details.

(4) Policy ENV5 - Flood Risk, Sustainable Drainage (SuDS) and Urban Heat Island Effects

6.1.56 This Policy was developed in close collaboration with the Environment Agency and has proved effective in delivering SuDS (Sustainable Drainage Systems) on developments and reducing surface water flows to greenfield rates on larger developments, where it has been practical to do so.

6.1.57 Changes to national policy on SuDS, including the requirement that SuDS should be provided unless demonstrated to be inappropriate (see NPPG para 79), generally support Policy ENV5. However, the Ministerial Statement of 18/12/14 states that this type of policy should only apply to major developments, to avoid excessive burdens on business. Therefore it is proposed to amend part a) of the Policy to apply only to major developments (10 or more homes and major commercial developments).

6.1.58 Although part a) refers to ground conditions, as this is a key factor in the Black Country restricting the type of SuDS which can be provided, there is no requirement to prioritise natural green space SuDS where this is practical and viable. It is therefore proposed to include the requirement to prioritise natural green space SuDS within part a), as this type of SuDS supports wider environmental infrastructure aims as set out in Policy CSP3.

6.1.59 Part d) requires surface water flows to be reduced to greenfield rates on sites requiring a Flood Risk Assessment. As the review will be considering greenfield sites, it is also proposed to add to the policy a specific requirement for greenfield sites to maintain surface water flows at greenfield rates.

(25) Question 101a - Do you support the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects? Yes/No; Further comments?

(3) Question 101b - Do you think that any other changes should be made to Policy ENV5 Yes/No: If yes, please provide details.

Policy ENV6 - Open Space, Sport and Recreation

6.1.60 Policy ENV6 creates the framework for open space policies at a local level. The Policy is in line with national guidance and is supported by detailed policies in Local Plans, therefore it is proposed to retain this Policy and update some references in the Policy and supporting text to reflect changing circumstances.

(18) Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain.

(8) Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No; If no, please explain.

(9) Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes should be made. Yes/No ; If yes, please provide details.

(3) Policy ENV7 - Renewable Energy

6.1.61 Policy ENV7: Renewable Energy set out a new policy for the Black Country authorities, in line with ‘Merton’ style policies across the country at the time, to deliver 10% renewable energy on major development sites, subject to viability. Wolverhampton and Dudley Councils have subsequently adopted SPDs to provide guidance on application of the Policy and Wolverhampton has been successful in securing this requirement on most developments. Other Black Country authorities have not been as successful in securing the requirement due to viability. Developers sometimes argue that higher energy efficiency standards should be accepted in lieu of renewable energy generation. For housing developments this would not now be possible, as national policy does not allow Local Plans to set policies requiring energy efficiency standards which exceed building regulations (see above).

6.1.62 At the time Policy ENV7 was introduced it was anticipated that zero carbon standards would start to be introduced from 2016, making Policy ENV7 redundant over time. However, although building regulations energy efficiency standards have since been tightened, the Government now has no plans to improve these standards further or to introduce zero carbon standards in future. The simplification of housing standards referred to above does not affect the ability of Local Plans to keep existing Merton style policies, and non domestic buildings can still be required to exceed building regulations standards e.g. through BREEAM.

6.1.63 Therefore, Policy ENV7 remains the only mechanism in the Black Country to increase renewable / low carbon energy production and to directly reduce the carbon emissions which will result from the significant amounts of development planned up to 2036.

6.1.64 It is proposed to make minor changes to the Policy, by explaining the term ‘residual energy demand’ (as set out in the Wolverhampton SPD) and removing the last bullet point which does not add value. However, more major changes could be made to the Policy. For example, the requirements could be loosened for non domestic buildings to allow increased energy efficiency standards in lieu of renewable energy provision. The % requirement could also be changed, although this would need to be justified with evidence e.g. regarding viability. For example, for green belt sites it might be more viable to require a higher %.

(10) Question 103a - Do you think that Policy ENV7 should be changed to allow increased energy efficiency standards to be accepted in lieu of renewable energy provision for non-domestic buildings? Yes/No; If not, please explain

(3) Question 103b - Do you think that the 10% requirement should be changed? Yes/No; If yes, please specify what percentage would be more appropriate and to what type of site it should apply to.

(1) Policy ENV8 - Air Quality

6.1.65 Since adoption of the Core Strategy the Black Country authorities have taken part in the West Midlands Low Emissions Towns and Cities Programme (WMLETCP), which has resulted in the adoption of a Black Country wide SPD on Air Quality, which supports Policy ENV8: Air Quality. The Black Country approach is in line with national policy and the current national focus on air quality issues, in light of growing evidence of health problems linked to air pollution.

6.1.66 It is proposed to retain and reword the Policy and supporting text to reflect the approach set out in the SPD and the WMLETCP.

(3) Question 104 - Do you support the proposed changes relating to Air Quality? Yes/No; If you think that any other changes should be made to Policy ENV8 please provide details.

(3) Policy Area G - Waste

6.1.67 Managing waste in a responsible way is an important element of sustainable development and facing up to climate change. This can be achieved including by addressing waste as a resource, minimising waste, managing unavoidable waste in ways that will minimise harmful effects and providing sufficient waste management capacity to meet current and future requirements of the Black Country.

6.1.68 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review. However, some of the individual policies may need updating as discussed below.

Policy WM1 - Sustainable Waste and Resource Management

6.1.69 Policy WM1 aims to achieve zero waste growth by 2026 and sets out a number of measures by which sustainable waste management will be delivered. This Policy is considered to provide generally the right kind of framework to address the waste management issues for the Black Country, in accordance with the NPPF.

6.1.70 The Policy then identifies landfill diversion targets for municipal solid waste (MSW) and commercial and industrial waste (C&I) and the new waste capacity that will need to be provided to meet these targets and achieve “equivalent self-sufficiency” in waste terms by 2026. A Waste Study will be commissioned to update these figures at Draft Plan stage, enabling a full assessment of the potential impacts of housing and employment growth, and taking into account any available national and regional data.

(4) Question 105 - Do you think that Policy WM1 identifies all of the key waste issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/No; If not, please specify what changes should be made to the Policy. If you have any evidence that can be referred to in the Waste Study, please provide details.

(2) Policy WM2 - Protecting and Enhancing Existing Waste Management Capacity

6.1.71 Policy WM2 identifies existing strategic waste management sites and sets out conditions governing proposals to improve or redevelop such sites, including loss for housing or community uses in line with the wider Spatial Strategy. The Policy also controls proposals for housing and other potentially sensitive uses close to an existing waste management site, where there is potential for conflict between the uses. The Waste Study will provide information to update the identified strategic waste management sites.

(2) Question 106a - Do you support the approach set out in Policy WM2? Yes/No; If no, please explain why.

(1) Question 106b – Are there any strategic waste management sites that no longer need to be protected? Yes/No; If yes, please provide details.

(2) Question 106c – Are there any new sites that do need to be protected? Yes/No; If Yes, please provide details.

Figure 12 Black Country Core Strategy Waste Key Diagram

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Policy WM3 - Strategic Waste Management Proposals

6.1.72 Policy WM3 identifies locations for proposed new strategic waste management infrastructure which are expected to make a significant contribution towards the new capacity requirements set out in Policy WM1. It is proposed to update this list by removing those projects which have been completed and adding proposals which have been permitted or allocated in other Local Plan documents. The Waste Study will provide information to update the list of strategic waste management proposals.

(1) Question 107 - Do you think that there are any strategic waste management proposals that should either be removed from or added to the list in Policy WM3? Yes/No; If so, please provide details.

Policy WM4 - Locational Considerations for New Waste Management Facilities

6.1.73 Policy WM4 sets out locational considerations, assessment criteria and information requirements for all types of waste management proposals, including landfill. This includes the requirement that waste arising in the Black Country should be managed within the Black Country where feasible and managed as close as possible to its source of origin. A key aim of the policy is to minimise adverse visual impacts, harmful effects on the environment and human health and localised impacts on neighbouring uses.

6.1.74 The Policy identifies employment areas as the ideal location for most waste management facilities, and identifies waste operations most suited to local quality employment land, including skip hire, scrap yards and open air facilities. The Policy has been successful in raising the quality of new waste facilities across the Black Country, by ensuring these are contained within a building or physical enclosure and that quality boundary treatments and landscaping are provided. This has helped to minimise impacts on neighbouring uses and increase environmental quality.

(1) Question 108 – Do you agree that Policy WM4 provides an appropriate level of control over the location and design of new waste management facilities? Yes/No; If no, what changes do you think should be made to the Policy?

Policy WM5 - Resource Management and New Development

6.1.75 Policy WM5 sets out general principles on waste management and resource efficiency to be addressed by new developments, including requirements to manage large amounts of waste on-site or nearby, to recycle and re-use products as far as possible, and to design sites with resource and waste management in mind. The Policy also sets out specific information requirements for major developments.

(1) Question 109 – Do you agree that Policy WM5 provides an appropriate level of control over resource management for new developments? Yes/No; If no, what changes do you think should be made to the Policy?

(1) Policy Area H - Minerals

6.1.76 Minerals are an important – and finite – resource for the nation in providing raw materials for many activities, including development. The Black Country has an interesting and complex geology. The availability of mineral resources has done much to shape the development and character of the area and dealing with the legacy of past mineral working is a major issue. However, whilst mineral resources underlie almost all of the Black Country, active workings are now confined to the fringes of the area. New or expanded workings might face environmental constraints and could conflict with plans for future housing and employment growth.

6.1.77 Over recent years the only minerals extracted have been sands and gravels and Etruria Marl (a type of clay used for brick and tile making). Other minerals, including building stone and coal, have been extracted in the past, and there may be other ways of exploiting mineral resources in the future. However, facilities for the recycling of construction, demolition and excavation waste (both on permanent sites and as part of redevelopments) produce more aggregates than are provided by quarrying.

6.1.78 The broad scope of the Policies in this section remain appropriate to be carried forward into the Review. However, some of the individual policies may need updating as discussed below.

6.1.79 Much of the evidence about mineral resources has been long established and many of the mineral operations in the Black Country have been in existence for some time. Changes that are proposed to the Minerals Key Diagram to reflect changing circumstances are listed below:

6.1.80 WALSALL

Etruria Marl Quarry along the A461 - ceased extraction and is operating as a landfill site

MA1 – ceased operation (not restored)

MA2 – ceased operation (could restart)

6.1.81 DUDLEY

Sedgley Works – ceased operation and redeveloped for housing

Stourbridge Works – ceased operation and allocated for housing

Himley Quarry – brick clay extraction has ceased and site is operating as a landfill site

6.1.82 The authorities welcome any additional evidence there might be about the existence and workability of mineral resources and about mineral infrastructure, and will ensure that the implications for mineral resources and the impacts of mineral issues on development will be taken into account in future work on the capacity for and delivery of new development.

Figure 13 Black Country Core Strategy Minerals Key Diagram

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Managing and Safeguarding Minerals Resources

6.1.83 Policy MIN1 sets out a strategy for the sustainable management of mineral resources, providing a context for other Policies in this section of the Core Strategy. The Policy is considered to continue to provide the right kind of framework to address key minerals issues for the Black Country, in accordance with the NPPF.

6.1.84 The Policy identifies the mineral resources in the Black Country that are or could be of economic importance. These underlie almost all of the Black Country and are protected by inclusion within a Mineral Safeguarding Area (MSA), which is shown on the Core Strategy Minerals Key Diagram and defined in more detail in individual authorities’ Local Plans. None of the work undertaken to inform Local Plan preparation indicates that the MSA in the Core Strategy should be amended.

6.1.85 The Policy protects and promotes mineral extraction, where feasible and appropriate. It establishes Areas of Search where development will not be permitted where it would sterilise mineral resources, and restricts development which would compromise the ability of operational quarries to function.

6.1.86 More generally across the MSA development proposals are encouraged to consider the extraction of minerals in advance of construction. Information demonstrating that mineral resources would not be needlessly sterilised is required for larger developments - 5 ha or more in the urban area and 0.5 ha or more in the green belt. This should include a scheme for ‘prior extraction’, or justification as to why one would not be feasible or desirable. Since 2011, prior extraction has been considered as part of the remediation of some relatively large sites (notably Phoenix 10 in Walsall), but has not proved viable or practical for any particular site.

6.1.87 However, the review will need to bring forward significant housing and employment growth in the green belt, much of which falls within the MSA. Speed of delivery, particularly of housing sites, will be a key issue, and although prior extraction may be viable for some green belt sites it could also significantly delay development. It is also unlikely that all promoters of smaller green belt sites will be able to carry out site investigations and a viability assessment to inform site allocation, making it difficult to estimate the delivery timescales for such sites. Therefore, it is proposed to increase the 0.5 ha threshold for green belt sites to 3 ha, or approximately 100 homes. This would mean that prior extraction could be seriously considered for all larger sites, in light of comprehensive evidence, whilst being weighed against the importance of early delivery of development.

6.1.88 The final part of Policy MIN1 refers to key mineral related infrastructure (including handling, storage and processing facilities), identified on the Minerals Key Diagram, and requires proposals that would result in the loss of any of these facilities to demonstrate there is no longer a need for the facility or redevelopment for other mineral related uses.

(3) Question 110 - Do you think that Policy MIN1 identifies all of the key minerals issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/no; If no, what changes should be made to the policy?

(4) Question 111 - Do you agree with the proposed change to ‘prior extraction’ requirements, to maintain a size threshold in urban areas and increase the threshold for green belt sites to 3 ha? Yes/No; If no, what evidence do you have to justify an alternative approach?

(3) Question 112a – Are there any key mineral related infrastructure sites that no longer need to be protected? Yes/No, Please provide details.

(2) Question 112b – Are there other sites that do need to be protected? Yes/No; If Yes, Please any details.

Production of Aggregate Minerals

6.1.89 Policy MIN2 states that the main source of supply of aggregates from within the Black Country will be from secondary and recycled materials. It also seeks to make an appropriate contribution towards the primary land-won sand and gravel target for the former West Midlands County area. However, the Joint Local Aggregates Assessment (LAA) prepared by the West Midlands Metropolitan Authorities in 2015 confirms that the sand and gravel working areas identified in the Solihull Local Plan 2013 should be sufficient to meet this target. During the Core Strategy review it is intended to update the LAA to cover the period up to 2036.

6.1.90 The Core Strategy proposes that extraction of primary aggregates should be concentrated in two Areas of Search around existing quarries in the eastern part of Walsall. Recent work for Walsall’s SAD has estimated the resources available in these areas, although working has not taken place in recent years and there is no significant resource with planning permission. The SAD defines the Areas of Search in detail and seeks restoration of the existing / remaining quarry workings as part of any proposals for further mineral extraction.

6.1.91 The Core Strategy allows for sand and gravel extraction outside the Areas of Search if there is evidence that extraction targets cannot be met. However, the Mineral Study for Walsall’s SAD has concluded that there is no need to make further provision for sand and gravel extraction up to 2026 and no evidence of workable deposits.

6.1.92 Policy MIN2 also includes provision for ‘borrow pits’ to provide material for specific construction or engineering projects. This is subject to such proposals being well-related to the project they are serving and being temporary permissions.

(1) Question 113 - Do you think that Policy MIN2 identifies all of the key aggregate minerals issues that need to be addressed in the Core Strategy up to 2036, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

Maintaining Supplies of Brick Clay

6.1.93 The extent of Etruria Marl brick clay resources in the Black Country is shown in Appendix 7 of the Core Strategy, and there are also fireclay resources that are not currently being worked. Policy MIN3 aims to provide each operational brick and tile works with a supply of Etruria Marl for as long as possible and for 25 years where feasible, and expresses support for the principle of brick clay extraction in the identified areas of search within Walsall and Dudley, subject to strict environmental controls and restoration requirements.

6.1.94 However, the constrained sites occupied by the quarries in Dudley and evidence supporting Walsall’s SAD indicate that there is unlikely to be significant potential to extract further Etruria Marl within the areas of search. Evidence shows that there is a deficiency in local supply of brick clays, in which case Policy MIN3 would allow for extraction of clay outside the areas of search. However, the only areas that are not heavily built up and where there could be brick clay reserves are in Walsall Wood / Shelfield / Aldridge area of Walsall where one site is being restored (Vigo/Utopia), another is being infilled with non-hazardous waste (Highfields South) and a third, with a ‘dormant’ permission is the subject of a designation as a SSSI (Highfields North).

6.1.95 The Core Strategy also referred to the existence of fireclays (in association with surface coal measures) in the Brownhills area of Walsall. It identified a dormant permission at Brownhills Common and an Area of Search at Yorks Bridge but explained that fireclay has not been extracted locally in recent years. Work for Walsall’s SAD has set out policy requirements in case there should be efforts to progress mineral extraction at Brownhills Common. It also sets out detailed requirements in case there is any proposal for mineral extraction in the Yorks Bridge area. It has not, however, proposed a new area of search as it is not considered that an extraction proposal could be delivered in the period to 2026. Rather Yorks Bridge is included within the Mineral Safeguarding Area.

6.1.96 The Core Strategy also supports the pooling or sharing of brick clay resources, stockpiling of clays and importation of clays from outside the locality, where this is needed.

(3) Question 114 – Do you have evidence of workable, viable deposits of brick clays outside the areas of search, which could justify defining new areas of search? Yes/No; If yes, please provide details.

(1) Exploitation of Other Mineral Resources

6.1.97 Policy MIN4 identifies coal, fireclay and natural building stone as the main resources that might be exploited over the Plan period. The Policy sets out criteria governing proposals for such exploitation, including exploitation of coal bed methane.

6.1.98 The Policy sets out a general presumption against deep mining of coal, surface coal working and the disposal of colliery spoil. However, some surface coal resources occur in association with fireclay, which is of importance for brick and pottery making. The policy refers to an existing ‘dormant’ permission for the working of clay and coal at Brownhills Common. Walsall’s SAD includes a policy (M9) to guide any future workings and restoration – and at the nearby sites Birch Coppice and at Yorks Bridge – in case proposals should come forward.

6.2.1 Since the Core Strategy was adopted, ‘fracking’ (the hydraulic fracturing of underground rock strata to extract shale gas) has become an issue that has attracted media attention. It is subject to the Government’s PEDL regime, with the involvement of regulatory bodies including the Environment Agency and the Health and Safety Executive. No licences have been sought in the Black Country. Walsall’s SAD includes a policy which requires similar considerations to apply to the exploitation of shale gas as to coal bed methane.

(3) Question 115a - Do you have evidence of any realistic possibility of fracking in the Black Country? Yes/No; If yes, please provide details.

(1) Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No; If yes, please provide details.

New Proposals for Mineral Developments

6.2.2 Policy MIN5 sets out the criteria relating to new mineral developments, including environmental, transport and amenity issues.

(2) Question 116 - Do you think that Policy MIN5 identifies all of the key issues that need to be addressed in relation to new mineral developments in the Core Strategy, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

Policy Area J - Growth Network Detailed Proposals

6.2.3 Appendix 2 of the existing Core Strategy document set out detailed proposals for the transformation of the Regeneration Corridors and Strategic Centres. These proposals are summarised in Tables 2 and 3 of the existing Core Strategy main document. It is proposed to update Appendix 2 and Tables 2 and 3 of the existing strategy to reflect adopted and emerging Site Allocations Documents and Area Action Plans, and also to add in new proposals for development, infrastructure and delivery to cover the period up to 2036, in line with new evidence, particularly the EDNA, which identifies potential surplus employment land suitable for housing up to 2036. Given the level of detail now provided in adopted Local Plans, it is also proposed to reduce the amount of detail provided in Appendix 2. This includes amendments to the boundaries of the Regeneration Corridors and Strategic Centres where these do not now accord with more detailed Local Plan documents or in light of more up-to-date evidence.

(7) Question 117 - Do you agree with the proposed approach to updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy of this document? Yes/No; If not, what alternative approach would you suggest?

Policy Area K – Monitoring and Additional Policies

6.2.4 The Core Strategy includes a Monitoring Framework, to measure progress towards achieving the Core Strategy Vision and Spatial Objectives. This Framework includes at least one indicator for each Policy. Progress against these indicators has, where possible, been reported in the annual Authority Monitoring Report (AMR) produced by each authority.

6.2.5 A number of the Core Strategy indicators have proved difficult to collect data for or have had limited functionality. National policy on Local Plan monitoring has changed significantly since the Core Strategy was adopted and is now less prescriptive, for example Core Output Indicators no longer exist. Therefore it is proposed to significantly reduce the number of indicators in the Core Strategy and to focus on the key quantitative indicators which relate to delivery of development, as set out in Appendix C.

(9) Question 118 - Do you agree with the proposal to streamline and simplify the Core Strategy Monitoring Framework? Yes/No; If no, please explain why

6.2.6 In reviewing the Core Strategy, there is opportunity to consider whether any additional policies are required to deal with an issue in the Black Country. This may especially be the case if new challenges have been identified that cannot be addressed through amending existing policies. In the light of new evidence it is considered that the need to consider amending the green belt to accommodate further growth will require a new section in the Plan, which is likely to include the allocation of specific sites rather than broad areas for development.

(7) Question 119 – Do you think that a new Core Strategy policy is required? Yes/No; If yes, please explain why and provide details of the suggested policy.

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