Policy Area B - Creating Sustainable Communities in the Black Country

1. Introduction
The Futures Network West Midlands (FNWM) comprises individuals from professional and academic backgrounds who have experience of and commitment to strategic and spatial planning with a particular interest in the West Midlands. Its purpose is to provide a voluntary independent network with the aim of opening up and examining key long term issues and potential futures facing the West Midlands. This current response to the Core Strategy consultation has been developed by an FNWM group of professional planners previously engaged over many years in similar strategic planning exercises in the West Midlands. The response has been endorsed by the FNWM Steering Group.
2. An overview of the Core Strategy Review
The Core Strategy (CS) was approved in 2011 and FNWM acknowledges and supports the need for it now to be urgently reviewed to ensure that it provides an up to date 15 year framework for development.
Key principles underpinning the CS were first developed through the Black Country Study in 2004 and it is timely, therefore, for these principles to be re-visited and re-assessed.
A central theme in the CS is the importance of urban regeneration and environmental renewal with a key focus on strategic centres and corridors. With positive progress being made, it is FNWM's view that this emphasis should not only be maintained but opportunities also examined as to how this approach might be further enhanced, taking account of the latest evidence, particularly in key transport corridors.
3. The need for a wider Strategic Policy context
A key issue facing the CSR is whether and to what extent the Black Country has the capacity to accommodate development not only to meet its own growing economic and social needs but also some provision to help meet Birmingham's unmet housing need. Given an anticipated constraint on the scale of brownfield land available, consideration is being given to the release of Green Belt land to meet these needs and a Strategic Growth Study has been initiated to examine this.
Experience shows however that, in order to properly address these issues, background analysis and the consideration of options should relate to a far wider geographical area than just the Black Country (i.e. given that journey to work and housing and labour market areas extend across the wider city-region, including areas such as Telford beyond the Greater Birmingham HMA boundary ). This approach becomes even more important in the light of the WMCA's Super SEPs ambitions for growth and the need to consider the balance of development across the WMCA area in order to achieve this.
FNWM would therefore strongly advocate that, led by the Combined Authority, urgent consideration should be given to the development of a Spatial Policy Framework (SPF) dealing not only with key cross boundary issues across the WMCA area but also providing a context for negotiations with authorities across the wider City-Region.
This is not to suggest that work on the CSR should be halted; indeed, along with the Strategic Growth Study (GL Hearn), it can act as an important input to the assessment of options in the development of the SPF. However, key decisions regarding such matters as urban extensions, key transport corridors and the possible identification of new major employment sites should await this wider strategic policy framework being developed.
In contrast to a number of other Combined Authorities, the development of an SPF is not currently part of the WMCA's 'Devo-Deal' and would therefore need to be viewed as non-statutory guidance. Nevertheless, it would undoubtedly provide an important context for the Duty to Co-operate to operate within and indeed could form the basis for strategic level joint agreement for the WMCA area covering the broad scale and distribution between Local Authorities of housing and employment land provision.
The issue of unmet housing need has been known for a number of years and without real progress on this key strategic issue there must be a real risk that local plans will not pass the Duty to Co-operate legal test. In the longer run, FNWM would strongly urge the WMCA to seek statutory responsibility for strategic planning.
4. Black Country communities - the importance of place-making
One of the enduring features and strengths of the Black Country is that it still contains a range of local communities with separate identities. FNWM believes that, where possible, it is important to retain these identities in a variety of ways. This can include providing support for the enhancement of local/district centres and identifying local brownfield development opportunities for a range of new housing not just to provide for local needs but also to maintain population and spending levels in support of such centres. The retail role of older centres has been severely challenged in recent decades through new trends in retailing and distribution. A key issue therefore is whether to seek to resist these trends or to seek new roles and development opportunities.
In the past, the identity of local communities has also been enhanced through the availability of local employment opportunities. However, this localised work pattern is being diluted as employment opportunities are provided further afield, including in Birmingham. If households are not to be motivated to move closer to more dispersed jobs, then improved public transport accessibility will therefore be increasingly important.
It is for this reason that FNWM believes that the CSR should look to maximising the full development potential of existing rail and metro transport corridors and future enhancements to the network such as the Wednesbury -Brierley Hill Metro extension and the Wolverhampton-Walsall proposals.
Development of the network in this way will therefore not only provide improved access to more dispersed jobs for Black Country communities but will also link up its strategic centres with Birmingham and HS2 stations with a greater chance of 'irrigating' the sub-region with associated economic advantages.


5. The evidence base
Supporting documents accompanying the consultation set out key components of the evidence base being used to address key issues in the CSR. Economic and demographic forecasts and projections are far from infallible guides to the future. A particular source of uncertainty surrounds international migration, which is projected to be a major driver of population growth both for the Black Country and for the wider Greater Birmingham HMA. At this stage, FNWM does not choose to challenge the assumptions being made with regard to the analysis of future housing and employment land need but would heed caution as to how such quantitative assessments are taken forward to guide policy.
The attached paper "Evidence Paper for Planning", submitted by FNWM to Mayoral candidates prior to the election, highlights some important perspectives at a WMCA level which are equally relevant for the CSR particularly with regard to housing.
6. Housing
Important points raised in the FNWM Evidence Paper are as follows:
- a large element of the 'real' need for new housing is generated by younger age groups but it is within these groups that people are facing lower and more uncertain income levels and higher living costs;
- it is unlikely that, even under an optimistic economic scenario, many in this group will be able to meet their housing needs by purchase or rent in the housing market;
- at the same time, the majority of the growth in households comes from the ageing population with a 74% increase in households over 65;
- fully meeting the assessed level of need will therefore require the provision of the level of genuinely affordable, non-market housing not seen since the period 1950-1980 accompanied by a significant increase in housing designed to meet the needs of older people. Neither outcome is likely under current national policy;
In these circumstances, and given uncertainty about future volumes of international migration, the premature release of a high level of peripheral housing land around the edge of the Black Country could have a number of detrimental impacts, particularly if it was to be dominated by private house building;
- as the market 'cherry picks' greenfield over brownfield sites, it could weaken the market for developing sites in the inner parts of the Black Country , including provision of attractive owner occupied dwellings, working against key strategic policy principles;
- much of the anticipated housing need will not be met resulting in an unjustified level of land release
- it could accentuate the existing polarised pattern of higher socio-economic groups concentrating around the edge of the Black Country leaving socially unbalanced communities in the inner core.
Against this background, FNWM would strongly advocate that a sequential approach should be taken to identifying and releasing capacity for future housebuilding across the Black Country and indeed the wider WMCA area by:
a. looking to optimise new higher density housing development around stations and stops on the rail and metro network - both existing and proposed such as the Brierley Hill metro extension;
b. examining the potential for high density housing developments in and around centres given the current changes in retailing and the contraction of demand for space;
c. looking for opportunities to improve the quality and quantity of social housing through estate renewal programmes, including increased provision for older and vulnerable people;
d. encouraging the relocation and expansion of businesses on to higher quality employment sites where relocation can provide environmental benefits and existing sites have potential for residential development. One particular feature of the Black Country is that it has many poor quality industrial sites in close proximity to housing, together with premises that have poor access to the strategic transport network. A high level of windfalls could therefore continue to come forward from this source over the longer term;
e. considering potential sources of housing supply in 'overspill' locations; including larger settlements such as Telford, Worcester, Stafford beyond the defined HMA but where migration patterns nevertheless demonstrate a housing market relationship.
If following the completion of this sequential exercise it is evident that peripheral housing may still be required, it is the view of FNWM that options should then be examined across the wider WMCA area (particularly in key transport corridors) as part of a WMCA Spatial Policy Framework process as advocated above. If any urban extensions are subsequently proposed, these should incorporate a balance of housing provision along with appropriate levels of employment, supporting infrastructure and quality access back into the urban area.
7. Employment land
FNWM fully supports the emphasis in the WMCA Super SEP to encourage manufacturing as a key component of the economic strategy. This approach is in marked contrast to the existing BCCS and a major driver behind the need for its urgent review.
One of the recent success stories in the Black Country is clearly the development of i54 and it is important to recognise that this site was identified and brought forward for development through the formal planning system commencing with a proposal in the Regional Spatial Strategy.
The success of i54 demonstrates how the availability of sites of appropriate quality and location will remain important in attracting investment. As recognised in supporting documents, the planning system will therefore have a key role to play in ensuring that an appropriate portfolio of sites is available to meet future needs but recognising that this may have implications for the provision of sites both within the Black Country and in surrounding areas. However, given the increased emphasis on manufacturing, it will also be important to protect those existing sites that are well located and appropriate for industrial activities from competing development.
As with housing, FNWM has chosen not to challenge the assessment of future employment land requirements (i.e. leading to a shortfall 'gap' of 300ha) but, on the face of it, the overall amount required seems to be very high, and appears to ignore the potential of land being recycled. The next version of the CSR will need to be rooted on a robust evidence base and must ensure that it addresses not only the quantity of land required but, most importantly, the quality.
In line with this, from a wider WMCA perspective, FNWM would advocate that consideration should be given to the re-adoption of the employment land portfolio principles set out in the former RSS (i.e. identifying sites and premises to meet all market needs including a range of major strategic sites*). If endorsed, this approach will require a wider study, contributing to the suggested WMCA SP and, if potential sites/locations are identified in or around the Black Country, this will clearly contribute to the identified shortfall 'gap'.
(* The RSS identified Regional Investment Sites, Major Investment Sites and Regional Logistics Sites although the range of sites required will need to be reviewed and updated to meet current and anticipated requirements).
Without a collective study of this nature, there is a danger of an oversupply of competing sites against the interests of the West Midlands especially when other sites, such as Peddimore, are coming on line at the same time. Such a study should include analysis of competing sites within major transport corridors beyond the West Midlands.
This particularly applies to B8 warehousing, where there is a need for a further rigorous analysis of supply and demand and how this might change over time, including the importance of access to rail freight services. In particular, it is noted that only 100ha of the Four Ashes sites are indicated in the Black Country portfolio but another 170ha could come forward at that site.
Environment
Environmental renewal will be crucial to the long term sustainable future for the Black Country and FNWM would fully support the integration of the Garden City concept into the CSR.
It will also be imperative that as the review progresses the implications for carbon emissions and pollution are properly assessed and take account of the latest evidence, some of which may not have been available when the original strategy was developed.

1. Introduction
The Futures Network West Midlands (FNWM) comprises individuals from professional and academic backgrounds who have experience of and commitment to strategic and spatial planning with a particular interest in the West Midlands. Its purpose is to provide a voluntary independent network with the aim of opening up and examining key long term issues and potential futures facing the West Midlands. This current response to the Core Strategy consultation has been developed by an FNWM group of professional planners previously engaged over many years in similar strategic planning exercises in the West Midlands. The response has been endorsed by the FNWM Steering Group.
2. An overview of the Core Strategy Review
The Core Strategy (CS) was approved in 2011 and FNWM acknowledges and supports the need for it now to be urgently reviewed to ensure that it provides an up to date 15 year framework for development.
Key principles underpinning the CS were first developed through the Black Country Study in 2004 and it is timely, therefore, for these principles to be re-visited and re-assessed.
A central theme in the CS is the importance of urban regeneration and environmental renewal with a key focus on strategic centres and corridors. With positive progress being made, it is FNWM's view that this emphasis should not only be maintained but opportunities also examined as to how this approach might be further enhanced, taking account of the latest evidence, particularly in key transport corridors.
3. The need for a wider Strategic Policy context
A key issue facing the CSR is whether and to what extent the Black Country has the capacity to accommodate development not only to meet its own growing economic and social needs but also some provision to help meet Birmingham's unmet housing need. Given an anticipated constraint on the scale of brownfield land available, consideration is being given to the release of Green Belt land to meet these needs and a Strategic Growth Study has been initiated to examine this.
Experience shows however that, in order to properly address these issues, background analysis and the consideration of options should relate to a far wider geographical area than just the Black Country (i.e. given that journey to work and housing and labour market areas extend across the wider city-region, including areas such as Telford beyond the Greater Birmingham HMA boundary ). This approach becomes even more important in the light of the WMCA's Super SEPs ambitions for growth and the need to consider the balance of development across the WMCA area in order to achieve this.
FNWM would therefore strongly advocate that, led by the Combined Authority, urgent consideration should be given to the development of a Spatial Policy Framework (SPF) dealing not only with key cross boundary issues across the WMCA area but also providing a context for negotiations with authorities across the wider City-Region.
This is not to suggest that work on the CSR should be halted; indeed, along with the Strategic Growth Study (GL Hearn), it can act as an important input to the assessment of options in the development of the SPF. However, key decisions regarding such matters as urban extensions, key transport corridors and the possible identification of new major employment sites should await this wider strategic policy framework being developed.
In contrast to a number of other Combined Authorities, the development of an SPF is not currently part of the WMCA's 'Devo-Deal' and would therefore need to be viewed as non-statutory guidance. Nevertheless, it would undoubtedly provide an important context for the Duty to Co-operate to operate within and indeed could form the basis for strategic level joint agreement for the WMCA area covering the broad scale and distribution between Local Authorities of housing and employment land provision.
The issue of unmet housing need has been known for a number of years and without real progress on this key strategic issue there must be a real risk that local plans will not pass the Duty to Co-operate legal test. In the longer run, FNWM would strongly urge the WMCA to seek statutory responsibility for strategic planning.
4. Black Country communities - the importance of place-making
One of the enduring features and strengths of the Black Country is that it still contains a range of local communities with separate identities. FNWM believes that, where possible, it is important to retain these identities in a variety of ways. This can include providing support for the enhancement of local/district centres and identifying local brownfield development opportunities for a range of new housing not just to provide for local needs but also to maintain population and spending levels in support of such centres. The retail role of older centres has been severely challenged in recent decades through new trends in retailing and distribution. A key issue therefore is whether to seek to resist these trends or to seek new roles and development opportunities.
In the past, the identity of local communities has also been enhanced through the availability of local employment opportunities. However, this localised work pattern is being diluted as employment opportunities are provided further afield, including in Birmingham. If households are not to be motivated to move closer to more dispersed jobs, then improved public transport accessibility will therefore be increasingly important.
It is for this reason that FNWM believes that the CSR should look to maximising the full development potential of existing rail and metro transport corridors and future enhancements to the network such as the Wednesbury -Brierley Hill Metro extension and the Wolverhampton-Walsall proposals.
Development of the network in this way will therefore not only provide improved access to more dispersed jobs for Black Country communities but will also link up its strategic centres with Birmingham and HS2 stations with a greater chance of 'irrigating' the sub-region with associated economic advantages.


5. The evidence base
Supporting documents accompanying the consultation set out key components of the evidence base being used to address key issues in the CSR. Economic and demographic forecasts and projections are far from infallible guides to the future. A particular source of uncertainty surrounds international migration, which is projected to be a major driver of population growth both for the Black Country and for the wider Greater Birmingham HMA. At this stage, FNWM does not choose to challenge the assumptions being made with regard to the analysis of future housing and employment land need but would heed caution as to how such quantitative assessments are taken forward to guide policy.
The attached paper "Evidence Paper for Planning", submitted by FNWM to Mayoral candidates prior to the election, highlights some important perspectives at a WMCA level which are equally relevant for the CSR particularly with regard to housing.
6. Housing
Important points raised in the FNWM Evidence Paper are as follows:
- a large element of the 'real' need for new housing is generated by younger age groups but it is within these groups that people are facing lower and more uncertain income levels and higher living costs;
- it is unlikely that, even under an optimistic economic scenario, many in this group will be able to meet their housing needs by purchase or rent in the housing market;
- at the same time, the majority of the growth in households comes from the ageing population with a 74% increase in households over 65;
- fully meeting the assessed level of need will therefore require the provision of the level of genuinely affordable, non-market housing not seen since the period 1950-1980 accompanied by a significant increase in housing designed to meet the needs of older people. Neither outcome is likely under current national policy;
In these circumstances, and given uncertainty about future volumes of international migration, the premature release of a high level of peripheral housing land around the edge of the Black Country could have a number of detrimental impacts, particularly if it was to be dominated by private house building;
- as the market 'cherry picks' greenfield over brownfield sites, it could weaken the market for developing sites in the inner parts of the Black Country , including provision of attractive owner occupied dwellings, working against key strategic policy principles;
- much of the anticipated housing need will not be met resulting in an unjustified level of land release
- it could accentuate the existing polarised pattern of higher socio-economic groups concentrating around the edge of the Black Country leaving socially unbalanced communities in the inner core.
Against this background, FNWM would strongly advocate that a sequential approach should be taken to identifying and releasing capacity for future housebuilding across the Black Country and indeed the wider WMCA area by:
a. looking to optimise new higher density housing development around stations and stops on the rail and metro network - both existing and proposed such as the Brierley Hill metro extension;
b. examining the potential for high density housing developments in and around centres given the current changes in retailing and the contraction of demand for space;
c. looking for opportunities to improve the quality and quantity of social housing through estate renewal programmes, including increased provision for older and vulnerable people;
d. encouraging the relocation and expansion of businesses on to higher quality employment sites where relocation can provide environmental benefits and existing sites have potential for residential development. One particular feature of the Black Country is that it has many poor quality industrial sites in close proximity to housing, together with premises that have poor access to the strategic transport network. A high level of windfalls could therefore continue to come forward from this source over the longer term;
e. considering potential sources of housing supply in 'overspill' locations; including larger settlements such as Telford, Worcester, Stafford beyond the defined HMA but where migration patterns nevertheless demonstrate a housing market relationship.
If following the completion of this sequential exercise it is evident that peripheral housing may still be required, it is the view of FNWM that options should then be examined across the wider WMCA area (particularly in key transport corridors) as part of a WMCA Spatial Policy Framework process as advocated above. If any urban extensions are subsequently proposed, these should incorporate a balance of housing provision along with appropriate levels of employment, supporting infrastructure and quality access back into the urban area.
7. Employment land
FNWM fully supports the emphasis in the WMCA Super SEP to encourage manufacturing as a key component of the economic strategy. This approach is in marked contrast to the existing BCCS and a major driver behind the need for its urgent review.
One of the recent success stories in the Black Country is clearly the development of i54 and it is important to recognise that this site was identified and brought forward for development through the formal planning system commencing with a proposal in the Regional Spatial Strategy.
The success of i54 demonstrates how the availability of sites of appropriate quality and location will remain important in attracting investment. As recognised in supporting documents, the planning system will therefore have a key role to play in ensuring that an appropriate portfolio of sites is available to meet future needs but recognising that this may have implications for the provision of sites both within the Black Country and in surrounding areas. However, given the increased emphasis on manufacturing, it will also be important to protect those existing sites that are well located and appropriate for industrial activities from competing development.
As with housing, FNWM has chosen not to challenge the assessment of future employment land requirements (i.e. leading to a shortfall 'gap' of 300ha) but, on the face of it, the overall amount required seems to be very high, and appears to ignore the potential of land being recycled. The next version of the CSR will need to be rooted on a robust evidence base and must ensure that it addresses not only the quantity of land required but, most importantly, the quality.
In line with this, from a wider WMCA perspective, FNWM would advocate that consideration should be given to the re-adoption of the employment land portfolio principles set out in the former RSS (i.e. identifying sites and premises to meet all market needs including a range of major strategic sites*). If endorsed, this approach will require a wider study, contributing to the suggested WMCA SP and, if potential sites/locations are identified in or around the Black Country, this will clearly contribute to the identified shortfall 'gap'.
(* The RSS identified Regional Investment Sites, Major Investment Sites and Regional Logistics Sites although the range of sites required will need to be reviewed and updated to meet current and anticipated requirements).
Without a collective study of this nature, there is a danger of an oversupply of competing sites against the interests of the West Midlands especially when other sites, such as Peddimore, are coming on line at the same time. Such a study should include analysis of competing sites within major transport corridors beyond the West Midlands.
This particularly applies to B8 warehousing, where there is a need for a further rigorous analysis of supply and demand and how this might change over time, including the importance of access to rail freight services. In particular, it is noted that only 100ha of the Four Ashes sites are indicated in the Black Country portfolio but another 170ha could come forward at that site.
Environment
Environmental renewal will be crucial to the long term sustainable future for the Black Country and FNWM would fully support the integration of the Garden City concept into the CSR.
It will also be imperative that as the review progresses the implications for carbon emissions and pollution are properly assessed and take account of the latest evidence, some of which may not have been available when the original strategy was developed.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 The adopted BCCS did not release any Green Belt land for development. In stark contrast, the emerging BCCS proposes the release of Green Belt land to deliver a minimum of 14,270 dwellings in order to meet the Black Country's needs. This
represents a significant departure from the approach of the adopted BCCS.

2.5 To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3039 dwellings against the stepped housing delivery trajectory. There is a shortfall of 57 ha of employment land. There is a shortfall of
191,756 sqm of office floor space in strategic locations.

2.6 Therefore a full review of the BCCS is essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs (as opposed to those identified in the now revoked WMRSS).
* All policies and objectives of the emerging BCCS Review are consistent with national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the shortcoming of the adopted BCCS.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 The evidence base currently comprises employment studies that assess strategic sites, high quality employment land and regional logistics sites. Additional employment evidence is necessary to assess the entire supply of employment land across the Black
Country, including the value, demand and characteristics of the existing supply. This will be crucial to informing whether it is feasible to release employment land to deliver approx. 10,400 new homes (Strategic Option 1B which is discussed further at Q11a).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?

2.12 The consultation on a standardised approach to the calculation of OAN is scheduled for September 2017 and, according to correspondence from DCLG (dated 31st July 2017), any Plans which have not been submitted by March 2018 (as will be the case for the
BCCS Review) will be required to apply the new standardised methodology.

2.13 In terms of the SHMA, the Objectively Assessed Housing Need ('OAHN') is derived from the 2014 Sub National Household Projections which PPG confirms represents the starting point for calculating need.

2.14 We reserve the right to comment further on the OAHN once the standardised methodology has been published, and used to calculate the Black Country's needs.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is
unnecessary to be kept permanently open.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? If not, what other key issues should be taken into account?

2.20 The nine key issues identified at Part 3 of the I&O Report represent the matters which will be integral to the BCCS Review achieving its ambitious plans for growth.

2.21 Mindful of the ambitious levels of growth proposed for the Black Country, the three key issues relating to housing and employment needs, and reviewing the Green Belt, are the most important to take account through the BCCS Review.

2.22 The need to review the role and extent of the Green Belt in order to meet the housing and employment needs of the area should be seen as a golden thread throughout the BCCS Review, reflecting issues specific to the Black Country. The key to unlocking this
significant level of growth will be providing sufficient infrastructure (including highways, education etc).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 In Q1 we make the case for a full review of the BCCS. This would also necessitate a review of the vision and sustainability principles underpinning the Plan. This is particularly relevant as to date the current vision has not delivered the necessary
housing and employment growth required by the BCCS.

2.24 The adopted BCCS vision and sustainability principles reflect the area's need at that time (i.e. February 2011). Since then the NPPF has been published and the WMRSS revoked. A new vision is therefore necessary to reflect the area's needs now, which are
much higher than at the time the BCCS was adopted, which is demonstrated by the admission that Green Belt land will be necessary. In contrast no Green Belt was released by the adopted BCCS (indeed the boundaries have not been altered for over
30 years).

2.25 Furthermore, the adopted BCCS' vision is underpinned by three 'major directions of change', none of which specifically refer to meeting the Black Country's housing needs. The BCCS Review vision would be more robust if it was underpinned by the nine key
issues set out at Part 3 of the I&O Report.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 Similarly to the BCCS' vision and sustainability principles, the spatial objectives must be reviewed to ensure they are up to date. The BCCS Review will be produced in a completely different planning context to that of the adopted BCCS. In particular the
existing objectives will not form a sound basis to deliver the anticipated levels of growth of the Black Country, let alone the current levels proposed by the BCCS.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 We set out in response to Q1 that a full review of the BCCS is necessary given the change in the planning policy, namely the publication of the NPPF and the revocation of the WMRSS. Policies CSP1 and CSP2 therefore need to be reviewed and updated as
appropriate. This is particularly relevant given neither policy reflects that a proportion of the Black Country's growth needs cannot be met within the urban area (which is explicitly acknowledged at paragraph 3.17 of the I&O Report), necessitating the release
of land from the Green Belt.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 At the current time there is an established requirement for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both are pressing needs which will require significant
land.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas. Whilst some of the businesses may not be 'friendly' to neighbouring uses, these types of units form the back bone of
the Black Country economy and their loss would negatively impact business in the area. The loss would also remove local, sustainable job opportunities.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 The Councils should also be mindful of the viability of regenerating employment land for residential use, and whether the market could sustain development on these sites. This is demonstrated by the number of previously developed sites in the Black Country allocated for housing but are yet to be delivered, and show no sign of doing so in the near future.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 Any site selection criteria should reflect the NPPF, recognising that planning should actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). Firstly, any site's performance against the Green Belt purposes is separate to any site selection process. The Green Belt Review is a separate exercise to determining the sustainability of a site. Secondly, SUEs in the Green Belt can have many environmental benefits, including delivering significant public open space (it is widely recognised the Black Country Green Belt is largely inaccessible), as well as biodiversity enhancements.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment needs, the NPPF has been published and the WMRSS has
been revoked, and the adopted BCCS has not been delivering the required level of
growth. As such the approach to housing land supply should be reviewed in full also.
2.88 Given there is a shortfall of 3,039 dwellings against the targets set in the adopted
BCCS, largely as a result of brownfield sites not being developed due to viability issues,
the Review should include a 10% lapse rate should be applied to the requirement to
ensure flexibility in deliverability should sites in the supply not come forward.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Black Country Core Strategy Issues and Options Consultation Response

Dear Sir / Madam,

Thank you for the opportunity to comment on the black Country Core Strategy Review Issues and Options. It should be noted that the comments below are officer comments which have been endorsed by the Portfolio holders at Wychavon and Malvern Hills District Councils and the Chair and Vice Chair of the Place and Economic Development Committee at Worcester City Council. This response is made in the context of the on-going Duty to Co-operate.

As background, Malvern Hills District Council, together with Worcester City Council and Wychavon District Council adopted the South Worcestershire Development Plan (SWDP) in February 2016.

Development Strategy
The South Worcestershire Councils are concerned that the issue of the considerable unmet housing need arising within Birmingham is not sufficiently resolved. Whilst the Black Country authorities recognise that this is a significant issue and have agreed to test capacity for an additional 3,000 dwellings, there is a significant shortfall remaining and therefore, should the on-going evidence base find that there is capacity over and above that currently being tested, consideration should be given to whether or not there is any potential to meet a greater element of the shortfall within the Black Country given its close proximity to Birmingham.

The south Worcestershire councils agree that the review should be a partial review which retains and stretches the existing spatial strategy and reviews the relevant policies.

The south Worcestershire councils agree that the evidence base listed is sufficient and is pleased to see consideration being given to the on-going work being undertaken to address the Birmingham shortfall. It is pleasing to see that the Green Belt review for the Black Country will sit within the context of the Strategic Growth Study and will be carried out in conjunction with South Staffordshire.
The key issues identified are considered to be appropriate issues for the plan to consider.

The first preference is for the Black Country to accommodate all of its need within its own administrative area. However, should exporting growth be necessary consideration should be given to the outcomes of the Strategic Growth Strategy and the growth should be accommodated within the Housing Market Area or within those authorities that have a strong connection with the Housing Market Area. Additionally, access by public transport and the potential to enhance existing links as well as create new ones should be prioritised to encourage sustainable commuting patterns. Employment and housing should be located within easy access of each other.

Careful consideration should be given to the specific types of housing needed and where the evidence base justifies it a target for particular housing types should be included in order to ensure that all needs are being met. With regard to affordable housing, it is important to ensure that viability isn't undermined by increasing the target, to the extent that overall delivery falls, however, the use of a higher target supported by site by site viability appraisals at the development management would ensure that delivery of affordable housing is maximised. Where the viability evidence supports doing so, higher targets should be imposed on particular types of sites for example greenfield or green belt sites, however, where these sites are significant in scale the infrastructure demands may render this unviable.

Brierley Hill Retail Pre-Conditions
With reference to paragraph 6.83 and question 68, the south Worcestershire councils would have concerns about the relaxation of the pre conditions for retail growth at Merry Hill. The introduction of parking charges would make the Merry Hill Centre comparable to other strategic centres within the Black Country and beyond, all of which have parking charges in place. Without this pre condition being met, the south Worcestershire councils would be concerned about the impact of retail growth at Merry Hill on the centres within south Worcestershire, particularly Droitwich and Worcester City.

In conclusion, notwithstanding the concerns relating to the unmet need arising from the conurbation, the south Worcestershire councils raise no objections to the plan at this stage and welcome the opportunity for further discussions with the Black Country authorities as the Core Strategy Review progresses in order to comply with on-going requirements associated with the Duty to Cooperate. Consequently the SWCs wish to continue to be consulted on subsequent stages of the Black Country Core Strategy review.

Please do not hesitate to contact me should you require any clarification with regard to this matter

The role of public health is to improve the health of our residents, prevent risks to public health and reduce health inequalities to help people live longer and healthier lives.
Public health works to improve the health and wellbeing of our communities by identifying the risks that affect different people, in different places, at different stages of life, and finding the best way to minimise them.
By working with external agencies and local communities we aim to:
* Keep people well
* Prevent people that are showing the early signs of poor health from becoming ill
* Improve the quality of life of those affected by ill health
Walsall is one of the 20% most deprived districts/unitary authorities in England and about 30% (17,000) of children live in low income families. Life expectancy for both men and women is lower than the England average.
Life expectancy is 10.5 years lower for men and 6.4 years lower for women in the most deprived areas of Walsall than in the least deprived areas. In Year 6, 25.5% (833) of children are classified as obese, worse than the average for England. Levels of teenage pregnancy, GCSE attainment are worse than the England average. Estimated levels of adult obesity and physical activity are worse than the England average.

The Health Foundation states that as little as 10% of the population's health and wellbeing is linked to access to Health Care. The population's health and wellbeing is influenced by a wide range of other factors including housing, transport, employment, green space, where we live.
The review of the Black Country Core Strategy provides real opportunities to improve the health and wellbeing of the population of Walsall and the below details the response from Walsall Council Public Health to this consultation.
The review document is quite a difficult document to navigate. It is long, not very user friendly and includes a large amount of jargon. The document includes a lot of questions, many of which are quite specific and make it difficult to respond to directly. Our comments as such, while not directly answering all of these, do provide information that will cover more generally some of the questions in each of the sections to follow:
A. Health and Wellbeing
PHE Spatial Planning for Health, an evidence resource for planning and designing healthier places, 2017 identifies five aspects of the built and natural environment as the main characteristics that can be influenced by local planning policy:
* neighbourhood design
* housing
* healthier food
* natural and sustainable environment
* transport
Many of the above are covered within this strategy.
In addition, the health and wellbeing of the local population can also have a huge impact on a local area. From an economic perspective a healthy population will have a reduced need for acute and long term health and social care services and will also be more likely to contribute to an active workforce - with improved productivity and less sickness absence.
Health and Wellbeing is not considered as a separate policy in the current Black Country Core Strategy. Therefore, as part of this review health and wellbeing should be given its own policy and be embedded into the other strategy policies.
Moving forward we would like to see:
* Further acknowledgement of the wider determinants of health
* Needs assessments that give due consideration to the health needs and demographics of the local area for example, the local Joint Strategic Needs Assessment (JSNA)
* Design standards that promote healthy lifestyles and environments across the life course. This should include 'lifetime neighbourhoods; identification of an ideal high street retail offer; consideration to fully pedestrianzing town centres; sustainable transport and green infrastructure networks
* Ensure potential health impacts are considered through a Health Impact Assessment that includes involvement from the Public Health team

B. Creating Sustainable Communities in the Black Country
Housing should aim towards 'lifetime neighbourhoods'. Rather than have separate accessibility standards, housing needs to consider the life course approach and be accessible to people of all ages. It also needs to be broader than just accessibility, for example, well-connected and walkable and design standards that promote healthy lifestyles and environments, considering the Ten Principles of Active Design (2015): Activity for all; walkable Communities; Connected walking and cycling routes; co-location of community facilities; network of multifunctional open space; High quality streets and spaces; appropriate infrastructure; active buildings management , maintenance; monitoring & evaluation; activity, promotion and local champions.
The housing plan needs to take into account any additional demand on associated local amenities of education, health, transport and leisure facilities. The needs assessment should be sensitive to changing local demographics e.g. extended family occupancy, Eastern European migration and multiple occupancy, which has a particular disproportionate impact upon local faith specific schools and local parking/transport. The plan should attend to the needs of marginalised groups and their specific needs e.g. single adults, young people, people with disabilities and the frail and elderly as well as the hidden homeless. Attention should be given to the travellers/gypsy and showman plans and how this relates to the challenge of unauthorised encampments.
There is a plan to increase high density housing allocation in Walsall which is a particular challenge.
A Health Impact Assessment should be undertaken for any major housing developments with the support of Public Health.

C. The Black Country Economy
Setting targets for employment land is important however, this needs to have the balance particularly in terms of where the Greenbelt is located. For example, much of the Greenbelt is located in the East of the borough and is difficult to access for people in more deprived areas in the West. This is an opportunity to link with the transport policies to look at how this can be addressed.
Building social housing, as part of housing developments, planned for the Greenbelt could also help address this.
Priority sectors require highly trained staff. Does the local population have these skills or will the new development create 'commuter workers' from other areas who invest very little to the local economy? Unemployment in Walsall is higher than the England average. Training needs to be made available for the local population if local people are going to be able to access these jobs. This needs to include a focus on those from the most deprived areas of the borough.
Design considerations to promote healthy living also need to be considered in building developments.
D. The Black Country Centres
Whilst the importance of business rates is noted, there is a need for this to be balanced with a more mixed retail offer in Walsall town centre. PHE has found that hot food takeaways per 100,000 population in Walsall is higher than the England average, 93.7 per 100,000 compared to 78.3 per 100,000. In 2014 in Walsall, there were 654 licensed premises, which is 312 per 100,000 population (aged 18+) .
There is an opportunity to develop a profile of the retail offer currently available in Walsall for different categories of outlets, and what the ideal profile might be. The Royal Society of Public Health: Health on the High Street (2015) recommends measures to include:
* Local authorities to use planning powers to prevent the proliferation of betting shops, payday lenders and fast food outlets
* Public health criteria to be a condition of licensing for all types of businesses
* A limit of 5% of each type of business on a high street in order to avoid oversaturation and provide affordable choice.
Consideration should be given to fully pedestrian town centres with more sustainable forms of transport and design giving full consideration to accessibility for all e.g. people with disabilities. This will improve the health and wellbeing of the population and community safety.
Consideration should be given to community safety partnership data to avoid the adverse effects of town centre planning (proliferation of issues associated with substance misuse and street workers).
E. The Black Country Transport Network
There is strong evidence that motorised road transport provides clear benefits to society and improving the road networks across the region should provide wider economic benefits, however there is a potential cost to society (Public Health England, 2016 ). Increased car journeys can lead to a rise in the disease burden due to reduced physical activity and in addition it is expected that there will be an increase in road accidents, air pollution, noise and even reduced social cohesion and increased social isolation (Public Health England, 2016 ).
Walking and cycling should be the easiest and preferred option and the strategy should give consideration to inverting the hierarchy of transport e.g. walking, cycling, public transport car, share and private car. In doing so it is reflective that investment in walking and cycling infrastructure and behaviour change programmes can deliver low cost, high-value dividends for the transport system, the whole economy as well as individual benefits. In addition to support, an increase in the number of people walking and cycling, community protection and safety should be considered within the strategy. Small improvements can make a difference to encouraging people to be active including good street lighting or improved road crossings.
In relation to health inequalities those who live in more deprived areas tend to travel less than those in more affluent areas but bear the greatest burden of other peoples travel (Public Health England, 2015). It is important that the core strategy does not increase unfairness in communities (Sustainable Development Commission, 2011).
There is a requirement to ensure good access to services in the most sustainable way possible. It is important that vulnerable groups including individuals with disabilities and older people including those with dementia are consulted in the planning and development of their communities, as they can often provide local solutions that address areas of potential conflict. The street environment and transport interchanges need to be designed to meet the needs of individuals - including an interlinking of the different modes of transport.
The strategy details improvements to public transport but clarification is required that this means that there will be less cars on the road which should improve air quality and see a reduction in the number of accidents. Public transport needs to be easy and accessible for all to use but it is important that the costs are not passed down to the consumer as this could be a barrier to usage. It also needs to be incentivised to use or made easier and more accessible for all to use and more cost effective.
There is a growing body of evidence that is supportive of 20mph speed limits (Cairns, J et al 2014 ) and repeated national surveys (Department of Transport ) demonstrates that there is strong public support for these in residential streets.
Will the detailed improvement to freight access include measures around air quality/ noise quality? This should improve economic growth and the flow of lorries on the motorway.

Consideration should be given to;
* Closing streets to allow active play for children and for residents to come together as a community. Areas outside of the Black Country (Hackney etc) have successfully demonstrated this approach.

* Impact of electric car policies (new government legislation)

* Car Share

* Community infrastructure levy - reinvestment back into communities to encourage active participation.

The Black Country Environment
We support the principles of a Garden City and recommend that these are applied. These are: sustainable transport and green infrastructure networks; bio-diversity gains; carbon emission reductions and climate change resilience.
Design quality (including space and accessibility) needs to be considered as above, housing needs to consider the life course approach and be accessible to people of all ages.
Walsall canals are an asset which can be developed to enhance active travel within the area. We would not support the removal of the reference made to canal projects. We consider canals to be important in contributing to emotional health and wellbeing.
We support the proposed changes relating to open space, sport and recreation but we believe the policy needs additional criteria to be added to provide sufficient protection form development of open space.
It states that development that reduces open space will be resisted and that increases will be encouraged. We suggest the use of the Natural England Access to Natural Greenspace Standard to provide a quantifiable measure of the importance of particular areas of open space is required. Further clarification on what constitutes open space is needed as the policy does not specify publically accessible open space.
Air Quality
West Midlands has the poorest air quality outside of London.
We support the proposed changes. ENV08 also needs to be updated to reflect:
* West Midlands Pollution Group (which in-turn works within the framework of the Central England Environmental Protection Group).
* West Midlands Combined Authority (CA), (including Transport for West Midlands in respect of a range of issues that encompasses proposals for Clean Air Zones and the uptake of Low Emission / Ultra-Low Emission Vehicles).
Walsall Council additionally works specifically with the Black Country councils, and has produced the Black Country NO2 road emission concentrations model. This is a workstream that is subject to on-going review as long as resources permit, and an updated model output is scheduled to be released later this year. Other Black Country work streams include the Black Country Ultra-Low Emissions Vehicle Strategy and the Black Country Air Quality Supplementary Planning Document.

We represent the West Midlands HARP Planning Consortium which includes all the leading Housing Associations Registered Providers (HARPs) across the West Midlands. Our clients' principal concerns are to optimise the provision of social/affordable housing and to ensure the evolution and preparation of consistent policies throughout the region.
Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review?
In the context of a limited supply of brownfield and other opportunities within the existing Black Country Core Strategy area to accommodate substantial housing development we welcome the proposal to release some land from the Green Belt. By undertaking a thorough review of Green Belt opportunities and constraints the Council will be meeting the NPPF requirement to promote sustainable patterns of development.
Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy?
Should the Council introduce a policy approach towards self and custom build housing, any requirement should not be in place of traditional affordable housing requirements. Self and custom build has complex requirements for funding and as such is out of the reach of most households who seek affordable housing. Self and custom build is also not within the affordable housing definition of the NPPF. Any policy requirement should be fully tested in terms of its viability when assessed alongside all other policy requirements to ensure that any requirement will not result in affordable housing being reduced on viability grounds.
Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any Further comments.
Paragraph 158 of the National Planning Policy Framework (NPPF) requires local planning authorities Local Plan to be based upon adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics of the area. The Council's own evidence document, the Strategic Housing Market Assessment Part 2-Objectively Assessed Need for Affordable Housing (June 2017) (SHMA) states that the authority should aim for 28.6% of new housing to be affordable housing (this figure includes starter homes).
Paragraph 47 of the NPPF clearly sets out the Government's aim to "boost significantly the supply of housing". To achieve higher housing supply local authorities should:

"use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area".
There is a wealth of evidence to demonstrate that there is a national housing crisis in the UK affecting many millions of people who are unable to access suitable accommodation to meet their housing needs.
Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
With regards to Question 49a, we would encourage the Council to consider the wording of paragraph 22 of the NPPF which asserts that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities."
Employment land has not been designated in perpetuity so if suitable and more practical uses are available we suggest that the Council takes this into consideration, via a more flexible policy; this will ensure that the Local Plan is in accordance with national policy and therefore passes the tests it will be assessed against in order to be found 'sound' at the eventual examination.
Other comments
The SHMA is clear on the increase in need for all tenures, of all sizes. In translating these needs into suitable policies the Council should look to involve Housing Associations as far as possible in setting a local definition of affordable housing that will encourage delivery of all affordable housing types. As the presumption should always be in favour of on-site affordable housing delivery, the preference for early engagement with local Housing Associations should be emphasised in the Plan policies.
The Council's SHMA highlighted a need for 162 new sheltered and extra care homes every year to meet the needs of the ageing population however there is no policy on older peoples housing within the document. We are of the opinion that a separate policy is needed to fully represent the needs of housing and care for older people.
Example policy wording is:
"Care, Continuing Care Retirement Communities and Extra Care Housing
The Council will, through the identification of sites and/or granting of planning consents, provide for the development of residential care homes, nursing homes, close care, extra care and assisted care housing, and Continuing Care Retirement Communities which encompass an integrated range of such provision.
In identifying sites and/or determining planning applications, regard will be had to:
* Commission for Social Care Inspection and other operational requirements;
* Locational sustainability. Suitable sites at defined settlements will be prioritised, but where such sites are not available regard will be had to the availability of public transport and the potential for developments to be self-contained, thereby reducing travel requirements;
* The potential to co-locate a nursing/residential care home and other care related accommodation on the site where there are demonstrated needs.
The Council will also work with its partners Dudley Metropolitan Borough Council, Sandwell Metropolitan Council, Walsall Council and the City of Wolverhampton Council and the relevant Primary Care Trusts in identifying suitable sites and securing the provision of schemes."