Comment

Representation ID: 2956

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.54 BDW support the broad Housing Spatial Option H2 - Sustainable Urban Extensions. 2.55 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs). 2.56 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period. 2.57 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet all of the Black Country's outstanding housing growth. 2.58 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure to meet its growth aspirations. 2.59 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.60 Turley is a member of the Home Builders Federation and regularly advises national and local housebuilders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. Housebuilders require certainty in their own supply. A site of less than 50-100 dwellings would provide one or two years supply maximum, whereas an SUE site would offer between three and five years supply, depending on the size of the site. 2.61 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller sites are less cost effective for housebuilders. This could significantly compromise the potential delivery of the Black Country's housing needs. 2.62 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed. 2.63 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations. 2.64 Any site selection criteria should reflect the NPPF, recognising that planning should actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision. 2.65 Given the critical mass of SUEs, they have the potential to sustain significant on-site services. It must be noted that Pennwood is capable of sustaining on site leisure and retail facilities and all associated infrastructure should its full capacity be allocated.

2.66 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). Firstly, any site's performance against the Green Belt purposes is separate to any site selection process. The Green Belt Review is a separate exercise to determining the sustainability of a site. Secondly, SUEs in the Green Belt can have many environmental benefits, including delivering significant public open space (it is widely recognised the Black Country Green Belt is largely inaccessible), as well as biodiversity enhancements.