Comment

Representation ID: 43927

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

CSP1 (development strategy)
3.8 As currently drafted the housing (47,837 homes) and employment (355ha) supplies are
identified in the emerging policy. The actual policy should be clearer that this is the
area’s proposed supply only and that the actual overall needs for the Black Country are
76,076 homes and 565ha of employment land. The policy can then be clear on how
much of the need is proposed to be exported to other authorities.
3.9 The overall development strategy is essentially made up of two elements:
• Delivering the majority of growth in the existing Urban Area / Growth Network
(86% in total); and
• Delivering a limited number of Neighbourhood Growth Areas (NGA) outside of
Growth Network (14%). The policy defines NGAs as “areas in highly sustainable
locations on the edge of the Urban Area”. The supporting text to the policy
provides further explanation – they are ‘large sites, or clusters of smaller sites,
which have been released from the Green Belt in sustainable locations on the
edge of the urban area”.
3.10 Given the existing Urban Area / Growth Network reflects the sites identified in the
Councils’ Urban Capacity Study, it is presumed the above represents a hierarchical
approach, with the existing Urban Area / Growth Network favoured over the NGAs.
This point could perhaps be further clarified as part of the justification text to draft
policy CSP1 to ensure it meets NPPF paragraph 20.
3.11 Paragraph 3.7 of the policy supporting text indicates the strategy has been developed
“through a comprehensive assessment of a range of alternative options”. The preferred
strategy reflects Spatial Option J, considered in the Sustainability Assessment (July
2021) (SA). To ensure the plan satisfies NPPF paragraph 35 further evidence will be
necessary to provide clarity as to whether this optioneering exercise reflects the
Councils’ assessment of reasonable alternatives, or whether this assessment is
provided elsewhere in the SA.
3.12 The Black Country’s needs are based on a plan period of 2020-2039. NPPF paragraph
22 states that strategic policies should look ahead over a minimum 15 year period from
adoption. To achieve this the plan would have to be adopted by 31 March 2024. The
current schedule for the BCP is that the plan will be adopted in April 2024, on this basis
the plan would not meet the requirements of NPPF paragraph 22. The plan period
should therefore be extended to reflect this.