Comment

Representation ID: 47031

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

CSP1 (development strategy)

As currently drafted the housing (47,837 homes) and employment (355ha) supplies are identified in the emerging policy (we are of the view that the actual housing supply is much lower – we discuss this further in response to draft policy HOU1).

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. The policy should also be clearer on the extent of the supply proposed on land to be released from the Green Belt.

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”.

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 should be further clarified as part of the justification text to draft policy CSP1 to ensure it meets NPPF paragraph 20.

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.

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.