Object

Representation ID: 43853

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.8 Policy CSP2 sets out the growth network and identifies this as comprising the Strategic Centres and Core Regeneration Areas. This approach is not considered consistent with the Vision and Spatial Strategy set out previously nor with the strategy in CSP1. In particular, the Neighbourhood Growth Areas, which are a fundamental part of the overall Spatial Strategy, are not mentioned in Policy CSP2 or referred to as forming part of the overall growth network. This is an inconsistency, and the Neighbourhood Growth Areas should be given equal importance to the Strategic Centres and Core Regeneration Areas currently mentioned in CSP2. Failure to do so means the Strategy falls back on a polarised approach towards meeting development needs targeted predominantly on existing brownfield sites within the urban area. A more balanced approach is needed, in accordance with the vision identified for the Black County and overarching spatial strategy defined in CSP1. This is particularly significant bearing in mind that the Plan identifies a shortfall in the provision of both housing and employment land.
4.9 Furthermore, the justification for the approach set out in CSP2, focusing growth solely in the Strategic Centres and Core Regeneration Areas, refers to supporting balanced growth taking account of environmental, climate change, accessibility and social requirements. In fact, the approach merely focuses development options on areas of the Black Country which require regeneration rather than taking a more balanced and holistic approach to delivering the most sustainable and deliverable solutions, which would also involve Green Belt release to broaden choice in housing and employment development options. The narrow focus set out in CSP2 also conflicts to an extent with paragraph 3.15 which acknowledges that Green Belt status should not be the sole criteria in assessing the suitability of a site’s ability to deliver sustainable development
4.10 The justification of CSP2 refers to the Core Regeneration Areas particularly reflecting the large parcels of employment land found in the Black Country and the opportunity it has to release poor quality and underused land for housing. The justification to CSP2 actually highlights the failings of such a narrow approach, in that it would only deliver housing on 'poor quality and underused land' which will not deliver a range of housing opportunity sites nor reflect the need to provide choice in both types of accommodation but also location.