Object
Black Country Core Strategy Issue and Option Report
Representation ID: 3024
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
No.
If the BCAs are going to explore the implementation of the Nationally Described Space Standard then this will need to be justified in line with the PPG, which requires account to be taken of the following:
need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions
It is likely that there will be some significant implications on the viability of developments if the NDSS is progressed. Where viability is not effective, this is likely to be where the housing market is strongest and where it is more difficult for younger people to access the housing market. Increasing house sizes of the smallest units could price exclude those with smaller budgets. So there are potential negative effects across the Black Country to be considered. With viability likely to be a factor on a large number of sites, the resultant loss/reduction of affordable housing provision and other s.106 obligations, will need to be balanced against securing the NDSS.
We agree that the evidence clearly demonstrates that a Green Belt review is needed to meet the development needs identified and that this is an essential component of the new Core Strategy.
However, it is also our view that the Green Belt review should extend beyond the current plan period in accordance with the Framework, which explains that when undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. In this context, it is highly likely that the need for housing and employment land will continue to grow and that capacity in the urban area will not exist to meet these needs. Consequently, safeguarded sites will also need to be identified. It is our view that the period up to 2051 should be considered. This is 15 years beyond the end of the existing plan period and links to the time period that local authorities are required to identified a supply of sites for (Paragraph 47).
Whilst the Green Belt review might be undertaken by the BCAs and South Staffordshire, it is important that the review is not just confined to their administrative area. Other authorities also directly adjoining the BCAs and an understanding of the function of the green belt along these boundaries is also important so that all the options available to deliver the housing need are considered.