Object

Representation ID: 43852

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.1 Policy CSP1 identifies that the Plan will deliver at least 47,837 new homes creating sustainable mixed communities that are supported by adequate infrastructure. The policy sets out this will be delivered through the following method:
· Delivery of the majority of development in the existing urban area;
· Supporting and enhancing the sustainability of existing communities through focusing of growth and regeneration into the Growth Network made up of Strategic Centres and Core Regeneration Areas;
· Protecting and enhancing the quality of existing towns and neighbourhood areas and rebalancing the housing stock by delivering homes supported by jobs and local services;
· Delivering a limited number of Neighbourhood Growth Areas in highly sustainable locations on the edge of the urban area;
· Protecting the openness, integrity and function of the Black Country's designated and retained Green Belt by resisting inappropriate development;
· Protecting the Black Country's character and environmental assets including heritage assets, natural habitats and open spaces; and
· Minimising and mitigating the likely effects of climate change.
4.2 However, despite the above, the Plan identifies that there remains a substantial shortfall in both housing provision and employment land provision (a shortfall
of 28,239 homes and 210 ha. of employment land) which cannot be met through the Plan and is to be exported to neighbouring LPAs through the Duty to Co-operate. The supporting text within the Plan indicates that the current position regarding the Duty to Co-operate is set out in the draft Statement of Consultation and "will be elaborated on in more detail in Statements of Common Ground at Publication stage".
4.3 This is not supported by Taylor Wimpey, as it is considered that this information should be known now and therefore made publicly available. It remains there is no indication within the Plan how this shortfall will be addressed or what measures would be introduced should the Duty to Cooperate not deliver the housing and employment requirements (or indeed should the Duty be removed as suggested within the Planning for the Future white paper).
4.4 Whilst Policy CSP1 also makes reference to delivering growth in the Strategic Centres and Core Regeneration Area, it does not make reference to the Strategic Development Allocations. As implied by their title, these Allocations are fundamental to delivering the overall Development Strategy and should duly be referenced within Policy CSP1, including clearly defining their role.
4.5 It is also considered appropriate that when considering the provision of new homes, the need to provide a broad range in the type and location of housing sites, is a fundamental to element in creating a balanced housing market that will assist in meeting the Black Country's local housing needs.
4.6 The above issues are linked back to the Plan's own evidence base. The Housing Market Assessment evidence (March 2021) is clear that commuting to Shropshire, Cannock Chase and Telford and Wrekin have become increasingly common destinations for those residents leaving the Black Country. This evidence demonstrates that out-migration to more distant rural authorities is increasing, and this is likely to increase journey to work distances. It is notable that these locations are generally more rural in character than the Black Country. It is likely that if this trend is to be reduced it would necessitate new housing sites being brought forward which can prove attractive to those residents desiring a more rural aspect. This underpins the need to provide for a range of housing locations including those on the edge of the conurbation, involving Green Belt release, which could potentially encourage those residents otherwise considering relocating to Telford and Wrekin and Shropshire to remain.
4.7 Taylor Wimpey nevertheless supports the general approach set out in Policy CSP1. In particular, the approach to providing Neighbourhood Growth Areas ('NGAs') is supported in that this will assist in delivering the broader range of housing sites necessary to provide choice. However, it is suggested that this key element of this spatial strategy should be given greater emphasis and explanation within CSP1, especially its key role in increasing choice/ flexibility and delivering sustainable mixed communities.