Comment

Representation ID: 22501

Received: 07/10/2021

Respondent: Persimmon Homes West Midlands

Agent: Planning Prospects Ltd

Policy CSP1 -- Development Strategy


It is fundamentally important that the Black Country Plan (BCP) properly identifies the development needs of the Black Country and fully provides for them within the Plan through to 2039. In this regard it has to be recognised that the current Black Country Core
Strategy (BCCS) has not been successful in its approach and a new Strategy is essential if the growth needs of the Black Country are to be successfully met. The BCCS focused on the re• use of brownfield, often previous employment, land to meet development needs, including for housing. However, the challenges to their delivery have not been over come and the market has consistently shown a requirement for choice and variety in sites for residential development. The experience during the BCCS period has shown that whilst making best
use of existing brownfield land within the urban area is important, a strategy that focuses
too heavily on this, particularly in seeking to meet the need for residential development, will not succeed and will result in a shortfall of available development land to meet needs. A more balanced approach is needed and seeking to continue an approach which has only
been partly successful would not be sound.


Support is given to the Objectives of the BCP which include the provision of, "housing that meets fill our needs". The Strategic Priorities in seeking to meet that objective include, "to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents", and, "to improve and diversify the Black Country housing offer". These points - around comprehensively meeting need; providing range and choice; and delivering improvement and diversification in housing provision -are important and must influence the policies of the BCP. Paragraph 1.43, and elsewhere highlights key challenges to deliver provision of good quality housing to meet the needs of a growing population and accommodating significant housing and employment needs. It acknowledges that to meet those needs there is a requirement to assess and review the
Green Belt and identify areas for growth in the context of a deficit in the supply of brownfield land. Exceptional circumstances clearly exist in this context such that it is essential that Green Belt land is released for development as there is simply not enough brownfield land which suitable, available and deliverable to meet development needs.

Policy CSP1 -- Development Strategy should be explicit in recognising the need for the release of Green Belt land. Reference is made to, "delivering the majority of development in the existing urban area", and whilst that remains relevant, the BCP must also acknowledge that a change in strategic direction away from the BCCS is necessary and this will include the delivery of development in other areas including Green Belt. This is implicit in the reference to growth in locations on the edge of the Urban Area, but the only explicit mention of the Green Belt in Policy CSPl refers to its protection.

Equally, the BCP very clearly relies on exporting a significant amount of its development requirement -some 28,239 new homes, and 210ha of employment land - to other authorities through the Duty to Co-operate. Whilst we comment on this further in our
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representations elsewhere below, exporting development need must be reflected and made absolutely explicit in the Development Strategy.

A Development Strategy that relies on Green Belt release to help meet development needs must refer and commit to that release, and Policy CSPl is not explicit in that regard, neither is it explicit in the strategy approach which is exporting very substantial development needs (equivalent to some 37% of the overall requirement) to other areas and must be explicit on this point.

In summary;


• It is important that the plan meets the full needs for development in the area
• A revised Development Strategy is supported which recognises the failings in the approach of the previous BCCS and a more balanced provision of sites to support delivery is essential
• Exceptional Circumstances are clearly evident given the lack of supply of sites from other sources to meet development needs
• The Development Strategy should be explicit in recognising that Green Belt will be required to be released to meet needs
• Further it should be explicit in recognising that a component of need will not be accommodated within the Black Country and will need to be delivered across boundaries