Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2983
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
The evidence base currently comprises employment studies that assess strategic sites, high quality employment land and regional logistics sites. Additional employment evidence is necessary to assess the entire supply of employment land across the Black Country, including the value, demand and characteristics of the existing supply. This will be crucial to informing whether it is feasible to release employment land to deliver approx. 10,400 new homes. If any existing employment sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location for residential development, and whether existing neighbouring uses would provide an issue for future residents. A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability and capacity of sites to meet the area's housing needs. To provide a robust assessment of infrastructure public consultation should be undertaken. These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country attend schools in other authority areas, such as South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.
It is also considered that the Black Country authorities include a robust landscape character assessment in the scoping of the evidence base document Strategic Mapping of the Black Country's Natural Environment. We expect that an updated landscape character assessment will engage with neighbouring authorities such as SSDC and stakeholders involved in landscape assessment and captures changes to the aesthetic, perceptual and experiential qualities of the landscape, particularly land to the north and south of Jones Lane, which adjoins existing residential built form. The Black Authorities should adhere to the aspirations set out in the West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016), which recognises the importance of planning to meet ambitions targets such as the creation of 500,000 new jobs and an addition 215,000 homes within the region. The BCCS Review needs to provide a robust strategy to meet the significant growth across the Black Country and should do in close cooperation with SSDC to meet the priority actions set out in the WMCA SEP.
The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.
As part of this the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.
The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the Black Country Green Belt Review to conclude which land is suitable for Green Belt release.
The Green Belt Review should be carried out in conjunction with assessing sustainable locations for residential development in neighbouring authorities such as SSDC, which falls within the same strategic housing market area and maintains strong economic links.