Object

Representation ID: 45862

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

2. THE SPATIAL STRATEGY


2.1 This section of the representations addresses matters raised by the Spatial Strategy of the emerging BCP, including in the context of how this can guide development more effectively than the existing Black Country Core Strategy (BCCS). There is necessarily an overlap between these strategic matters and questions raised by their translation into the detailed policies of the plan. Detailed points, for example about the derivation and application of the housing requirement, are attended to in the following section.

Comments on: Policy CSP1 – Development Strategy


Nature of comment: Objection


2.2 The fundamental purposes of a strategic plan of this nature include to ensure that development needs, for housing and other activities, are fully and properly identified and then met. An important part of this involves providing a policy framework to meet housing needs, in the case of the BCP through to 2039.

2.3 A different strategy to that advanced in recent years by the BCCS is now required. The BCCS placed great emphasis on the re-use of brownfield, often previous employment, land to meet development needs, including for housing. However, the demand for such land for employment use has remained robust, and the market has consistently shown a requirement for choice and variety in sites for residential development. The experience during the BCCS period has shown that whilst making best use of existing brownfield land within the urban area is important, a strategy that focuses too heavily on this, particularly in seeking to meet the need for residential development, will not succeed.

2.4 It is important that the BCP strategy recognises and responds to this, rather than simply seeking to continue an approach which has only been partly successful. This point is amplified in the context of the pandemic, which has changed the ways in which communities live, work and travel, placing greater emphasis than ever on the importance of the quality and character of the home environment. This in turn drives a requirement for a flexible approach to housing land provision and securing choice and variety in the supply. It invites a more balanced approach, rather than one that is excessively urban and brownfield focused.

2.5 These themes are reflected (Table 1) in the Objectives of the BCP which include the provision of, “housing that meets all our needs” (emphasis added). The Strategic Priorities in seeking to meet that objective include, “to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents”, and, “to improve and diversify the Black Country housing offer”. These points
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– around comprehensively meeting need; providing range and choice; and delivering improvement and diversification in housing provision – are of crucial importance, should be encouraged, and must be supported by the policies of the BCP.

2.6 The BCP also rightly recognises (paragraph 1.43, and elsewhere) that the key challenges and issues it faces include the provision of good quality housing to meet the needs of a growing population and accommodating significant housing and employment needs. It acknowledges that to meet those needs there is a requirement to assess and review the Green Belt to help identify potential areas of growth in the context of a deficit in the supply of brownfield land. The position is rightly taken (e.g. paragraph 3.15) that exceptional circumstances exist such that Green Belt land should be released for development; that policy threshold has been crossed.

2.7 The tone in this regard should be set by Policy CSP1 – Development Strategy. However, for the reasons set out elsewhere in these representations (see Section 3, below) there are fundamental misgivings in terms of the extent to which the BCP seeks to meet the housing requirement within the BCA area, and in terms of the extent to which the delivery of any exported requirement is secured. These points are expressed in detail in relation to submissions on Policy HOU1, but also have a fundamental bearing on the Development Strategy.

2.8 There is also a disconnect between the Objectives and Strategic Priorities, and the Development Strategy, in that the latter does not commit explicitly to meeting housing needs in full. Instead, it refers to meeting “strategic planning targets based on the needs of local communities”. Points around range, choice and flexibility are overlooked.

2.9 Moreover, whilst the BCP very clearly relies on the release of Green Belt land (to accommodate 7,720 homes and 48ha of employment land in the Plan as currently formulated) this is not explicitly acknowledged in the Development Strategy. This is fundamental. Reference is made to, “delivering the majority of development in the existing urban area”, and that remains relevant, but as discussed above the BCP must also acknowledge that a change in strategic direction away from the BCCS is necessary and this will include the delivery of development in other areas. This is implicit in the reference to growth in locations on the edge of the Urban Area, but the only explicit mention of the Green Belt in Policy CSP1 refers to its protection.

2.10 In a similar vein, the BCP very clearly relies on exporting a significant amount of its development requirement – some 28,239 new homes, and 210ha of employment land – to other authorities through the Duty to Co-operate. Again, the detail and composition of the requirement is considered in more detail in Section 3, below, but as a matter of
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principle any significant reliance placed on exporting development need must be reflected and made absolutely explicit in the Development Strategy.

2.11 Plainly, a development strategy that relies on Green Belt release to help meet development needs must refer and commit to that release, but Policy CSP1 is effectively silent on the point. Similarly, a development strategy that relies on exporting very substantial development needs – as currently framed equivalent to some 37% of the overall requirement – must refer and commit to that reliance, but Policy CSP1 is also silent on this point.

2.12 To remedy these deficiencies Policy CSP1 should:


 In part 1), make explicit that the BCP will plan to meet the full housing need, including a commitment to the manner and extent to which this will be achieved through exporting development requirements, and a further commitment to an early review if that level of export is not achieved;

 In part 1a), include a commitment to deliver a greater proportion of the housing requirement within the BCA area (see Section 4 below in terms of a proposed strategic site to assist in this regard);

 Also in part 1a), make explicit that the provision of new homes will include a range and choice of dwellings, with flexibility in the way those are delivered; and

 In part 2a), confirm that whilst the majority of development will be in the existing urban area, there will also be a Green Belt release to help meet development needs.

2.13 For clarity, the contribution of the Green Belt to meeting development needs should also be recognised and made explicit in Table 2 (“Black Country Development Strategy 2020
– 2039”).