Policy HOU2 - Housing Density, Type and Accessibility

Our primary concern is ensuring that the Local Plan is informed by appropriate evidence and that where higher levels of growth are identified and policies and sites proposed, that these are informed by up to date and proportionate evidence. Table 1 on page 18 details the range of evidence base and which areas may need updating. Unfortunately, there is no reference to any historic environment evidence base within this table. What evidence base do the Council's have? Does it need updating? Are there areas missing? If sites are proposed through the Black Country Core Strategy review then we would expect a heritage impact assessment to be undertaken, or similar.

I attach a link below to some relevant advice notes to assist in the preparation of the Black Country Core Strategy Review:

Conservation Principles -

https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/

Good Practice Advice Notes -

https://historicengland.org.uk/advice/planning/planning-system/

Site Allocations Advice Note -

https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/

Page 29 looks at the issue of a Green Belt Review and we would want to ensure that the historic towns purpose of the Green Belt is fully considered.

We would support the inclusion of a specific spatial objective for the historic environment.

Where growth is considered and there are options for amending boundaries to regeneration corridors, creating new sustainable urban extensions, allocating development sites, we would need to ensure that appropriate assessment has been undertaken on how this growth will impact the significance of heritage assets, including their setting. Please see advice notes above and also access Historic England's website for further information.

Question 16 raises the idea of what criteria to consider when choosing sites for development - we would request that the Council's consider what the impacts are for the historic environment and consider sites where there is no negative impact or impacts can be mitigated. There are also opportunities for development to positively enhance and better reveal the significance of heritage assets and we would also request that these opportunities are considered. This point is relevant for all types of development.

We would be happy to offer advice and comment on any proposals to amend Policy ENV2 on the historic environment and we are supportive of the policy being updated in line with national policy and guidance.

Page 66 raises the issue of building density and the need to look at increased density. As a result we would be keen to ensure that the Council's have appropriate design and building heights policies to ensure that there are specific policies to deal with issues that may arise because of increased density of sites.

Where sites are identified for Gypsy, Traveller and Travelling Showpeople, alongside other forms of development, we would expect these to be fully assessed against the potential negative impacts for the historic environment.

Where transport initiatives are proposed we would recommend that these are considered against the impact to the historic environment and that relevant avoidance, mitigation and enhancement measures are included within the Core Strategy.

We are content with the proposed amendment to Policy ENV2. We would recommend that a section is included on Heritage Statements and when they are required.

Historic England is currently preparing some additional advice on preparing minerals plans and the historic environment. We would recommend that the Council's consider all appropriate evidence base to ensure that the proposals are appropriate and compliant with the National Planning Policy Framework. Historic England does also have access to a number of studies that have looked at archaeology and aggregate minerals and we would be happy to share the relevant evidence with you

My husband and I have our own home mortgage free. But as its a 3 bedroom its getting to much for us to keep up as I am 63 and my husband is 76. Is there anywhere in the strategy for us, sell our home so we can rent/or part buy with council support a flat for our old age? It would free up a good size family home.

Introduction.

I am writing to you on behalf of Hallam Land Management, which has a long and successful reputation in working with local authorities to promote land for both housing, industrial, commercial and mixed-use development throughout the country. Their approach is to take a positive initiative in promoting land through strategic and local plans to ensure that homes and jobs are delivered for the benefit of local communities and for the wider economy.

For some time, Acres Land & Planning Ltd has been promoting a 10.68ha site (SHLAA site 222) at Sandy Lane in Codsall within South Staffordshire District on behalf of 'Hallam Land'. The site, although currently within the Staffordshire Green Belt nevertheless forms a logical extension to a recently approved housing development to the north of the village which was released from the Staffordshire Green Belt as a 'safeguarded site' in the previous South Staffordshire Local Plan.

The Black Country Issues and Options Document represents a first but very important step in the planning of the area within the wider West Midlands Metropolitan sub-region which also has a critical bearing on the surrounding local authorities including South Staffordshire. We therefore warmly support the integrated approach which the Black Country authorities are adopting and specifically the decision (referred to within paragraph 3.12 of the document) to assess the Black Country and South Staffordshire together as a joint housing sub-market.
The Issues and Options.

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?

The challenges facing the West Midlands (including the Black Country) are critical both in terms of the scale and complexity of housing needs and the changes now being experienced in the local economy. These are influenced by the pressures being felt from Birmingham, triggered in part by the potential growth being stimulated by the forthcoming construction of HS2 and other infrastructure projects but also the uncertainties created by the economic and political changes likely to stem from the decision to leave the European Union.

We broadly support the need for a partial review, retaining the basis of the existing Core Strategy - Hallam Land do not wish to prolong the exercise by starting entirely afresh and re-inventing those aspects of the planning strategy which already work effectively - but we do feel the review needs to be sufficiently far-reaching to challenge the current Core Strategy and to test its robustness thoroughly and also to reflect the changes in policy approach since the NPPF was introduced.

Hallam Land very much welcome the acknowledgement within paragraph 1.19 of the Issues and Options Document that not all growth can and will occur within the existing built-up area. We welcome the pragmatic approach which the Black Country authorities are taking towards the over-reliance on re-used brownfield and derelict sites in the area. The Black Country has a legacy of contaminated land including many sites with old mine shafts and other physical and technical challenges. These will not always be suitable for housing development and hence capping and re-use for commercial or recreational land may be the only viable option. Furthermore, as the Issues and Options report emphasises, the welcome growth in the regional economy means that fewer former industrial sites may be now available for housing.

We applaud the decision to review the Green Belt, jointly in the Black Country and in South Staffordshire. Although it is important to protect the concept of the green belt and to adhere to its principles, the Green belt must be able to respond to the inevitable pressures for urban expansion (unless other options can be delivered instead). Against a background where the GB boundaries have not been reviewed since the 1970's and are very tight (see Figure 5), this is both desirable and essential. There can be no sustainable case for imposing rigid Green Belt constraints which would otherwise impede growth in the Black Country which desperately needs it.

We agree that the existing two-tier forward planning approach should be retained. Most Local Plans are now currently emerging as single-tier plans, but this Core Strategy provides a strategic plan for a large part of the Metropolitan area. The individual Metropolitan Boroughs of Dudley, Sandwell, Walsall and Wolverhampton and those Districts surrounding the Black Country - such as South Staffordshire - will then develop the policies, identify the sites and implement the strategy.
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; 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, please provide details.

Hallam Land acknowledges the list of strategic challenges and opportunities identified as 'Key Issues' in paragraph 3.1 of the Core Strategy document.

Within the first of these - the evidence base - Table 1 provides an exhaustive list of studies, research and evidence which has either been undertaken or is in progress to assist in the preparation of the Black Country Review. This is impressive, but the most important consideration is that the strategy should be consistent, integrated and holistic. The studies therefore need to be considered as a whole and should be compatible with plans and proposals which are emerging within the surrounding areas, especially in the Birmingham housing market and in Southern Staffordshire.
In that context, notwithstanding the reference to 'Working with neighbours' one document which, in our view, is lacking is a draft Duty to Co-operate Statement which shows the relationships between areas and the extent to which pressures for housing and jobs are being accommodated across the sub region.

In the absence of a wider West Midlands Regional Strategy, which places Birmingham and the Black Country in their broader context, it is really important to ensure that the Black Country is planned as part of a functioning sub-region. This may well emerge from the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study (due to be published later in September 2017) and within the WMCA Land Delivery Action Plan published (a few days ago) in early September 2017 and due to be considered by the WMCA Board.

The second document which is not referred to is the recently published WMCA Land Commission report published by the West Midlands Land Commission in February 2017 on behalf of the West Midlands Combined Authority (WMCA). This report attempts to address the pressures for and against delivery of development in the West Midlands Authorities' areas. The WMCA has yet to formally adopt the report, but it is currently being addressed by the GBSLEP and the WMCA.

The third document which is in the list, the West Midlands Combined Authority Strategic Economic Plan (SEP) - completed in 2016 - clearly needs to inform the review of the Black Country. The SEP is much more ambitious than both the statutory plans and the Strategic Housing Needs Survey (undertaken by PBA in 2015). The prospect of creating some 500,000 new jobs and 215,000 additional homes within the region (as advocated by the SEP) needs somehow to be reconciled with the more modest plans currently being pursued by the West Midlands' local authorities. Clearly unless the respective Metropolitan Councils plan for integrated housing and employment growth, it simply won't happen.

Question 3 - 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? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.

The assessment of housing need in the Black Country is extremely complicated, since it is surrounded by local authorities on all sides. The Housing White Paper advocates a standardised approach to housing needs assessment which should narrow the areas for debate in settling OAN (Objectively Assessment Need) figures. This may work where housing markets are relatively self-contained with identifiable economic and housing catchment areas - but this is clearly not the case for the Black Country.

The Black Country housing market tends to operate at two levels - both as a strategic market stretching across the whole West Midlands Metropolitan sub-region with people moving in and out both regionally, nationally and internationally, and also as a complex network of local markets, catering for the many smaller communities which have traditionally constituted the Black Country.

On the demand side, it is not just a case of looking at the consequences of people living longer and families and households breaking down more often, but also a result of stronger in-migration both from elsewhere in this country and abroad which fuels household formation. The Black Country has traditionally become a lower-priced housing market area accommodating households with a wide range of skilled, semi-skilled and unskilled jobs. It therefore tends to act as a 'reception area' for inward international migrants in addition to catering for both intra-regional movement and local demand. The 78,190 does not contain allowances for economic growth or providing additional affordable housing.

Figure 6 adds 3,000 dwellings as a contribution to supply in the wider Greater Birmingham Housing Market Area. This should logically be a demand component but is presented as a one-off contribution to help meet a neighbouring OAN. Whilst pragmatically we understand the way in which these numbers have been devised (as a gesture to help resolve 'Birmingham's needs'), in reality it might be more robust to explore the intra-regional migration patterns to see whether 3,000 is a realistic contribution to the integrated housing market. We are inclined to feel that the Black Country should be absorbing more of the 'Birmingham boom' which is arising in part from the growing attractiveness of Britain's second city. OF course, a West Midlands Regional Plan would have been able to tackle this exercise. Sadly, the Duty to Co-operate mechanism is very blunt instrument in resolving cross-boundary issues.

With that in mind it is difficult to simply 'rubber stamp' the broad assessment outlined in the Issues and Options document. We therefore reserve judgement on the proposed OAN of 78,190 homes (2014-2036) until further work has been undertaken to explore both the sub-regional needs and examine how the Black Country OAN relates to the Districts around it - especially South Staffordshire (and Telford and Wrekin which has historically acted as destination for out-migrants from the Black Country) to determine whether the 78,190 figure is robust.
On the supply side, we acknowledge the broad thrust of the 5 stage assessment within Figure 6, (although it would be logical if the order of the items in the histogram was consistent with the diagram). It's upside down.

A few points are relevant here:-

Firstly, the number of completions (2011-2014) should be a matter of fact, however it may be worthwhile looking at the mixture of dwellings delivered against need to see to what extent they match demand/requirements. Other Districts outside the Black Country may be better placed to provide new family housing,

Secondly, the existing 'supply' registered in the SHLAA may be a helpful guide towards the capacity within the urban area of the Black Country - however it is not clear whether all the SHLAA sites have been tested for availability and constraints and what proportion of those sites are deliverable and at what density. Further work needs to be done on this to clarify the status of 'committed' sites.

Thirdly, paragraph 3.15 states that identified sites and windfall sites have a potential to deliver around 8,335 homes (2026-36) but it is not clear whether there is any overlap between the 'potential' windfalls and the SHLAA sites and/or the scope for increased density housing allocations in town centres.

Fourthly, paragraph 3.16 refers to the scope for the re-use of employment sites of which 300ha (delivering 10,400 homes) may release land over the 10 year period from 2016-2026. However, the document acknowledges that this may reduce as a source of housing land, especially if the West Midlands economy continues to improve. It makes little sense to re-direct employment development onto greenfield land within Green belt (thereby displacing jobs from local communities) if housing is then being steered to sub-optimal contaminated sites within the urban areas which are more expensive to remediate to residential standards.

Fifthly, there is no mention within the assessment of replacement housing to cater for older homes (or sub-standard property) reaching the end of its life. This element is normally built-in to the demand side of the equation, but in the Black Country the decaying housing stock and/or system built housing affected by design and construction problems could further reduce the supply available. (We have not investigated this aspect and more work may need to be done on this).

Finally, the residual figure of 24,670 dwellings which (according to paragraph 3.18) may need to be accommodated within the green belt (in the Black Country or elsewhere) will need to be balanced against other options if the sequential approach towards land allocation within the Housing White Paper is implemented. Against that background, the 'value' of the Black Country Green Belt in meeting the 5 key purposes of green belt will need to be measured against the merits of releasing arguably less sensitive green belt sites in South Staffordshire or indeed negotiating to release non-green belt land in the former New town of Telford, where the infrastructure is already in place and there is a growing industrial base.
Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.

The nature of the economy has changed significantly over the last 10-15 years. Although the Black Country is the traditional home to extractive industries, manufacturing and especially metal-bashing much of this heavy industry has moved to other countries to be replaced by higher value manufacturing and services - including distribution. At the other end of the scale, the economy now encourages smaller-scale initiatives with a sharp rise in small businesses and self-employment.

It is therefore much more difficult to gauge the employment land requirements since the more traditional industrial estate forms only a partial element of employment needs. Employment may also be transient and not necessarily place-based. Recent history has shown that there is a pressing need for readily available large employment sites to meet the one-off inward investment such as JLR which tends to create large numbers of jobs, both in direct and spin-off employment. Similarly, distribution now requires much larger loading bays with high spans which can accommodate the needs of the current market. The West Midlands Strategic Employment Sites Study and the Black Country & South Staffs Sub-Regional High-Quality Employment Land Study will provide an important part of the evidence base.
We therefore support the portfolio approach to the provision of employment sites.

At the more localised level the town and local centres are becoming less attractive to the major retail multiples and more popular with local specialist shops, coffee shops and restaurants and entertainment venues. Disappointingly, despite Birmingham and the Black Country being world famous for the historic canal network, there is no reference at all to the potential of the canals in creating and boosting the local economy. The only reference to canals is within Policy EN4 where a cautionary approach is taken due to the possible ecological implications of restoration. Yet many examples exist within Wolverhampton, Walsall, Dudley and Sandwell where the canals have been at the heart of urban regeneration and others could be in future. There are also opportunity sites elsewhere in Telford where this applies.

The Economic Development Needs Assessment (EDNA) suggests the review should plan for up to 800ha of additional employment land for the Black Country from 2014-2036 which reflects the loss of around 300ha to housing and reflects the economic growth aspirations of the Black Country SEP. This residual figure assumes that a further 90-170ha of employment land is released within South Staffordshire to reflect the needs of the Black Country. Logically this will also have a housing implication within South Staffordshire rather than just within the Black Country despite serving the Black Country's needs. Clearly if this is the basis for the employment target - the same principle must also apply to the housing target. Otherwise we make no detailed comment on the 300ha 'gap' figure which emerges as the employment land requirement within paragraph 3.27 of the document.

Key issue 5 - Protecting and enhancing the environment.

It is self-evident that planning policies should be devised to protect the environment and to avoid damage to Special Protection Areas (SPA's), RAMSAR sites, water quality and other aspects of the natural environment.

We are extremely sceptical however about the outcome of the environmental impact work of the Cannock Chase SAC Partnership. Local authorities involved have sought to impose a levy on house-builders operating within the 15km catchment zone on the assumption that increased 'pressure' will be imposed on Cannock Chase from the building of houses within the area. Having examined this consultancy work in depth previously, we are not convinced that the study undertaken on behalf of Natural England has demonstrated that the 'pressure' on the wildlife necessarily arose from newcomers. Rather it was caused by specific 'user groups' or people acting irresponsibly for example mountain bikers, horse riders, dogs, or people starting fires, some of whom already live locally or are travelling from further afield.

On a more general note, the implication that the use and enjoyment of public open spaces should be discouraged through the imposition of a 'dwelling tax' on housing is counter-intuitive. It conflicts with Local Councils' own tourism strategies (which try to attract people to the Chase) and is contrary to wider public health objectives within planning which promote walking, cycling and taking other forms of exercise. The Cannock Chase SAC Partnership and Natural England therefore need to re-assess their evidence base carefully and review this policy so that it does not impose a burden on builders or indirectly future residents of the Black Country and those people moving to those parts of Districts such as South Staffordshire and Stafford and those places which lie within the 15km catchment of the Chase

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?

We welcome the recognition that the implications of future growth in and around the Black Country will require a systematic review of the Black Country green belt and that this will be done in a consistent way with the other local authorities in the Birmingham and Black Country housing market area. The emerging Greater Birmingham and Black Country HMA Strategic Growth Study, being produced by GL Hearn provides the right context for the Black Country Green Belt review and it is logical (as suggested in paragraph 3.47) that this should also cover the South Staffordshire area which falls into the same general housing market area and maintains strong economic links.

The completion of the Preferred Spatial Option report for the Core Strategy Review in September 2018 seems a sensible timescale in view of the complexity of the task.
Since the development of Green Belt is regarded as a last resort, we think it would be logical to also dovetail the strategic housing and green belt review with the exploration of options to deflect housing provision to Telford which has long served to cater for the needs of people from the Black Country with ambitions to move.

Question 6 - 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? Yes/No; If not, what other key issues should be taken into account?

The key issues outlined in paragraph 3.1 are as follows:

* Updating the evidence base
* Meeting the housing needs of a growing population
* Supporting a resurgent economy
* Supporting strong and competitive centres
* Protecting and enhancing the environment
* Reviewing the role and extent of the green belt
* Keeping the Black Country connected
* Providing infrastructure to support growth
* Working effectively with neighbours.

We agree that, subject to the caveats wish we have listed above, these key issues outlined in Part 3 represent the factors which need to be taken into account through the Core Strategy.

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?

Yes. We broadly support the Core Strategy Vision and sustainability principles. However, although we accept that ideally it may be desirable to 'put brownfield first' in terms of the authorities' priorities, in practical terms this is not always feasible. In any event, a 'brownfield first' strategy for housing is not actually Government policy. Authorities are expected to encourage and promote the development of brownfield sites for housing but this may not necessarily mean putting brownfield before greenfield development. The market would grind to a halt if they did so.

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

The 10 objectives seem broadly sound as a basis for planning and regeneration of the review period. However, although there is a mention of existing housing areas in Objective 4, there is no actual reference to providing an adequate level of new housing, in places where people want to live. Furthermore, the Objective 3 which refers to 'Model sustainable communities on redundant employment land in the Regeneration Areas' does not reflect the change in stance within the review which will now be looking at a wider portfolio of sites, including some Green belt sites both with the Black Country and South Staffordshire. There is also no reference to working in partnership with neighbouring authorities or the private sector, something which is essential to achieve delivery.

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

Yes. We agree that policies CSP1 and SP2 remain relevant. But they may be rather too prescriptive in trying to direct development to specific centres, locations and corridors. The Review provides the opportunity to gauge to what extent the current
Core Strategy has succeeded both in focusing development on preferred locations but more important in boosting and regenerating the Black Country. These policies may have unintended consequences if they tend to deflect growth elsewhere.

It may also be appropriate to consider whether there are other places in the Black Country which now need a boost other than the main centres and corridors. Since most of the Black Country is within built-up areas there may be a case for more flexibility with a greater focus on design rather than location. We would also suggest that the canal network provides an opportunity for water-based regeneration which can improve the environment through waterside development and create a rich mixture of residential, small scale commercial and recreational development.

Question 10 - In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
If no, do you support Option 1B? Yes/No; If yes, please explain why.
If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question 11b - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.

Yes. The Regeneration Areas will need to be extended. We don't have fixed views about the merits of options 1A and 1B. Indeed a 'one size fits all' approach may lead to a contrived solution which becomes difficult to deliver in practice and stifles development which could otherwise legitimately occur. According to Government policy the use of the Black Country Green Belt should be viewed as a last resort, hence there should logically be a pointer towards Option 1B in preference to 1A. The canal routes could provide employment areas where regeneration could result in more housing as part of mixed used development thereby improving the overall environment and bringing the Black Country's history and culture to life. We agree that using green belt in South Staffordshire rather than the Black Country should be considered where pressure and potential impact may not be as great. The scope for exporting some housing needs to Telford where green belt is not an issue and infrastructure is already in place, should also be seriously considered.
Question 12a - Do you support Spatial Option H1? Yes/No; 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.

Question 12b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).

The designation of Green belt is based on 5 specific purposes, most of which are relevant to the Black Country. However, Green Belt is a strategic policy tool, not an instrument of landscape or recreational policy - although in some cases they may well function as recreational areas in practice. We feel there is a valid case for rounding-off parts of the Green belt in the Black Country and in South Staffordshire. The Black Country, especially Walsall, has a network of green wedges which separate smaller communities which would be hard to justify on current criteria and in some cases are less sensitive as green belt.

The criteria for selection of site review, should be related to the initial reasons for designation of green belt. This is consistent with the findings of the West Midlands Land Commission Report which suggests that there should be review of the Green Belt within the whole West Midlands Metropolitan Area and that it should be consistently applied and related to those areas of land which perform poorly against the five statutory purposes of the green belt.

In defining new areas and boundaries, as suggested within the NPPF (which was unchanged from the former PPG2) local authorities should look for clear defensible boundaries such as rivers, roads, railways and tree lines or field boundaries where the case for striking a green belt edge is stronger.

There may also be a case, as the Government's Housing White Paper suggests for redefining green belt boundaries on their outer edge to retain the width of protection for towns. In addition, although green belts are not intended to be an environmental or landscape policy, there is a strong case (as the Landscape Institute has suggested) to adopt a separate landscape or recreational strategy for some green belt land to strengthen its positive role in providing value for society (including those residents of the urban areas who may lack accessible public open space, rather than being an enclave of protected green land for people who occupy high value or more exclusive homes.

In South Staffordshire there are also areas where green belt could be rounded-off without damaging its purpose, such as north of Codsall on land being promoted by Hallam Land at Sandy Lane (SHLAA site 222) which would extend a recently consented site and where the 5 purposes of the green belt would not be compromised. We have submitted a separate contribution under the 'Call for Sites' including the Sandy Lane, Codsall site.


Question 13a - Do you support Spatial Option H2? Yes/No; 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.

Question 13b - What infrastructure do you think would be needed for different sizes of SUEs?

Question 13c - 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?

Question 13d - 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? Yes/No; Any further comments?

There may well be cases where larger sustainable urban extensions are deemed appropriate. However, comparative assessment work would need to be undertaken and a strong case demonstrated if large areas of green belt were to be sacrificed to development. The Housing Green Paper emphasises that the use of green belt land for development should be a 'last resort' and rightly points towards peripheral rail stations as providing an obvious focus for larger scale development.

Inevitably, larger free-standing settlements in the green belt would take longer to develop albeit they would deliver a broad range of services. Easy access to jobs and public transport would need to be an essential pre-requisite to any sustainable urban extension. Suitable SUE's would need to conform to essential criteria to justify their selection in the first place - though the precise nature of the SUE would no doubt emerge through public and private sector negotiation and partnership.

Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details.

We have already mentioned above that other options rather than encroaching onto the Black Country green belt, do exist. The larger South Staffordshire villages which are served by public transport provide a logical case for growth. In the case of Codsall/Bilbrook there are 2 railways stations and the village is within cycling distance of the new i54 JLS plant and the Pendeford Business Park close by. Carefully selected green belt releases in these locations offer good potential links between homes and jobs whilst exploiting the wide range of facilities which Codsall enjoys. The Sandy Lane site, promoted by Hallam Land will be surrounded on three sides by development, once the adjacent Watery Lane site is built, and is ideally suited for development.
Question 15a - 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? Yes/No; 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?

Question 15b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.

Question 15c - Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.

Telford New Town has long provided an opportunity for a new life for people moving out of the Black Country since its designation in 2017, indeed the original purpose of the New Towns were to serve the wider housing needs of the West Midlands Metropolitan area. Although Telford has since lost its formal New Town designation and no longer has Assisted Area status, it still retains the culture and ambition for growth and enjoys much of the infrastructure needed for growth which has already been provided at public expense. There are potential strategic sites in Telford, for example at Wappenshall to the north of the town, which are well linked to both existing and planned industrial jobs as well as having an attractive environment and close proximity to all the facilities existing in a burgeoning new community.

Strangely, Telford & Wrekin Council currently seems reluctant to continue its natural growth trajectory, or even to reach its original population target, but the Telford Local Plan Inspector has recently rejected the submitted housing strategy within the emerging Local Plan Review, and sought higher housing numbers, a justification for the selection of sites within and an early review within the Proposed Modifications.

Wappenshall provides scope for the delivery of 2,500 new homes within a restored canal-side environment lying adjacent to the built-up area of Telford, close to the major industrial estates of Hortonwood and Hadley and in a location where public-sector land owned by HCA can be levered into the scheme. The Proposed Modifications to the Telford & Wrekin Local Plan now provides a further opportunity to examine new initiatives - such as Wappenshall, which could bring all round housing, economic, recreational and tourism benefits to the town.

Telford provides a natural destination for current residents of the Black Country who could still commute the 15 miles to jobs at i54 or Pendeford Business Park using the M54 motorway or travel by train. Alternatively, there will be further job provision locally which would enable people to start a new life and career whilst retaining their close links with the Black Country - just as previous generations have done before them.

Questions 16 - 20, Spatial Employment Options (E1 - E4).

We have no specific comments to offer on the alternative Employment Options for the Black Country.

Question 21 - 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? Yes/No; If yes, please provide details.

Yes. we would expect Policy DEV1 to be reviewed as a matter of course as part of the review of the Core Strategy, which could include the imposition of infrastructure requirements to meet future community needs, subject to any changes in the CIL regime which may be announced in the coming months, following the CIL review.

Questions 22-28, Social and Physical Infrastructure.

We have no further comments on these aspects.

Question 29 - Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.

Question 30 - Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.

The use of generalised and site-based viability assessments are likely to be important in determining whether schemes can progress and if so, what level of infrastructure - social and physical - they can support. Paragraph 5.28 indicates that some 25% of potential housing sites and 30% of employment sites in the Black Country are unviable to develop. This legacy of contaminated land often precludes the development of sites and makes affordable housing difficult to deliver on others.

In addition to the mechanisms outlined in paragraph 5.24, such as clawback, or phased viability assessments, it may be possible to link or cross-subsidise green belt and brownfield sites. This has been suggested previously albeit often flounders unless the two sites are in the same ownership where delivery can be assured. Green belt sites would (in general) be capable of offering a higher level of infrastructure which could tip the balance in terms of justifying their release. Grant aid, for example through the Black Country LEP, the WMCA or by using the HCA's new £3bn Home Building Fund which is designed to assist with infrastructure could assist.

The West Midlands Combined Authority has just released (September 2017) its Land Delivery Action Plan which includes funding initiatives to assist in the delivery of land for housing.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?

The Black Country is a prime example where additional public funding may be necessary to lever out sites for regeneration. In addition to those areas of support from Government, HCA, LEP's and now WMCA there could be Heritage Lottery funding where for example there are old canal structures are involved. As para 5.38 indicates, the Housing White Paper signals potential changes to the CIL regime which may result in a standardised tariff rather than the present CIL floorspace formula.

It is also possible that the Government may encourage the Black Country to pursue its Garden Village bid, which could then be accompanied by associated funding for development and renewal.

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No; If no, please provide details

Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No; If yes, is a new policy needed to address such issues for example?

Question 34a - 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? Yes/No; Any further comments?

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

Health and Wellbeing is becoming an essential element in the planning process and there are many potential initiatives and measures which could be employed to raise levels of health and wellbeing which could help to stem multiple deprivation in the Black Country, for example:

* Travel modes - including the encouragement of walking and cycling,
* public open space - including facilities to encourage more exercise and improvement of quality of life
* reduction in diesel emissions for example through traffic restraint and pedestrianisation and the possible removal of speed humps,
* the juxtaposition of land-uses to encourage better home/job relationships including the promotion of working from home,
* possible education on diet and exercise - especially for children.

A Health Impact Assessment will be required.
Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

We certainly support the need to update the Policy HOU1 figure and to review the trajectory and the balance between brownfield and greenfield development, now that the Councils in the Black Country recognise that some future housing development will need to go onto the green belt. The maintenance of a generous 5 year housing land supply is an essential element of the NNPF as part of the commitment to 'boosting housing delivery' within paragraph 47 of the document, which should apply to all four local authorities. It is unclear however how the housing provision and housing land supply for South Staffordshire will work, bearing in mind it is outside but integral to the Black Country.

If the Black Country authorities are planning to reduce the degree of flexibility on the delivery of strategic sites (as indicated in paragraph 6.22 and also introduce a 505 per annum small site allowance then there will need to be plenty of leeway in the provision on sites to ensure that targets are met.

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; 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?

Question 37a - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why

Question 37b - If no, should it be reduced to 11 homes or more? Yes/No; If no what other threshold should be used and why?
Question

Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?

Question 39 - Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.

Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.

We are not in favour of applying specific housing mix criteria for sites, unless they are sufficiently large where a mix and variety of dwellings is important. The housing mix should be related to the specific site circumstances and ideally determined through pre-application discussions. They should not be prescriptive.

It is logical to apply higher density expectations to sites close to public transport modes, whether within the green belt or not, but it may be dangerous to impose specific standards which fail to reflect the circumstances of particular sites we therefore support the proposal within paragraph 6.28 to remove this paragraph from the Plan.

Paragraph 6.30 refers to the growing need for Sheltered and Extra Care dwellings, estimated at about 5% of the requirement. The Councils should encourage the delivery of this type of property, but it will not be feasible to expect market sites to deliver an element of extra-care and sheltered accommodation which tend to have
somewhat different locational requirements.

Finally, it may be tempting to apply housing requirements on density, mix and type according to the Council's SHMA but unless the expectations can be supported in terms of viability and deliverability they will not actually materialise.

Question 41 - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
A target for each authority? Yes/No; Any further comments - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
Another approach altogether? Yes/No; If yes, please specify.

Government warmly support the idea of self-building as an opportunity for more people to get onto the housing ladder and a policy encouraging self-build plots would be sensible. However, self-builders tend to want specific isolated plots where they can 'do their own thing' or require custom built homes which are separate from larger standard housing sites. Any idea that builders should specifically reserve plots for self-builders could be self-defeating. In practice, small housebuilders will cater for self-build or custom building if it means selling a plot or a house in a different way.

Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.

Question 43 - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why. If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?

The Councils should set the target for affordable homes at the level which emerges from the evidence obtained from the SHMA. With the definition of affordable homes set to change to include starter homes it is admittedly difficult to pin down exactly what counts as affordable and what doesn't. The Black Country authorities should therefore set the right policy climate to encourage more affordable homes to come through. Where so many sites ae affected by contamination and site stability issues the ability to subsidise affordable housing may be problematic. Affordable housing may therefore need to emerge through public subsidy through Registered Providers and housing trusts, rather than necessarily through cross-subsidy.
Question 44 - 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? If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?

The current 25% quota is probably a helpful guideline, unless evidence from the SHMA demonstrates that a higher (or lower) percentage is justified. The lower level of subsidy now expected from developers (80% of market price) may make a high overall quota easier to achieve. This will be guided by the outcome of the SHMA which may assist in identifying the range and type of affordable housing needed, but this may well change over time and in any event, will need to be determined on a site by site basis.

Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.

There is every likelihood that green belt sites will be capable of delivering higher levels of affordable housing, but on the other hand may not be the most appropriate location for accommodating people without cars or access to employment. If there is a broad overall policy guideline but with a site by site assessment, this is likely to produce the most satisfactory result.

Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing developments? Yes/No; If no, please explain why.

Question 48 - Do you agree that the requirement in HOU5, to demonstrate there is adequate alternative provision to meet the needs of the community served by a facility which is to be lost, should be reviewed? Yes/No; If yes, please explain why.

In a situation where Sandwell and Dudley both have CIL plans and policies but Walsall and Wolverhampton currently don't, creates a difficult situation in terms of producing a standardised policy for the Black Country as a whole.

S106 agreements have the ability to adapt to the circumstances of the specific site and reflect its viability and deliverability. But there are clear advantages of incorporating the funding of 'strategic' facilities through a pooled CIL policy - if the viability of each site is not prejudiced.

In principle, it is right that community facilities should be funded through developer contributions, however public funding for infrastructure is currently being reassessed through the Government's CIL review and it may be sensible to await the outcome of this report before formulating policy on this aspect.

Question 49 - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why. If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.

It is probably desirable to keep Policy DEL2 to enable the authorities to manage the release of poorer quality employment land. The Core Strategy has identified a higher than expected take up of employment land within the Black Country and hence the local economy should not be prejudiced by the lack of employment availability if it is needed. Furthermore, the Black Country needs a pool of poorer and cheaper sites in sub-optimal locations to find places for 'unneighbourly uses' such as scrap yards, storage sites and other uses which need to find a home somewhere.

Question 50 - Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/No; Please explain why.

The scenario described in paragraphs 6.53 - 6.58 paints a very fluid picture on employment supply and need, with the turnover of sites catering for emerging needs but with a lack of larger strategic sites which could provide more jobs for the wider Black Country and south Staffordshire economy. We feel there is a need for a total employment land stock as a general guideline, but that the LEP needs to carefully review the nature of the economy so that growth is not held back by a lack of land.

Question 51 - Do you think that the criteria used to define Strategic High-Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

Question 52 - Do you think that the criteria used to define Local Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

Question 53 - Do you think that Strategic High-Quality Employment Areas should continue to be protected for manufacturing and logistics uses, with the other uses set out in Policy EMP3 discouraged? Yes/no; If not, what alternative approach do you recommend?

This strays outside my client's interests. However, we feel that the policies need to be reviewed against the background of the High Quality Strategic Sites Study (2015) and the practical evidence coming forward from the Black Country LEP and the WMCA on the type of strategic sites which are likely to be needed and the extent to which these need to be 'ring-fenced' from more general employment sites.
Question 54 - Do you agree that the current approach in Policy EMP4 is no longer fit for purpose and should be amended to reflect a portfolio based approach? Yes/No; If no, what alternative approaches would you recommend?

We would support the views of EDNA that there needs to be a broad portfolio of sites rather than a single overall target. This should relate to sites within South Staffordshire as well as the Black Country.

Question 88 - Do you agree that the overall transport strategy supports all of the Core Strategy spatial objectives? Yes/No; Please explain why.

Question 89 - Do you support the proposed changes to the priorities for the development of the transport network? Yes/No; Please explain why.

Question 90 - Do you support the proposed changes relating to managing transport impacts of new developments? Yes/No; If no, please explain why.

Question 92 - Do you support the proposed approach to providing a coherent network for walking and cycling? Yes/No; Please explain why.

The Black Country is at the centre of the national trunk road and rail network, but at the same time has a network of local communications which serve the myriad of localised Black Country communities. It is important that any transport strategy recognises this dual role and that there is a focus on maintaining and improving the metro, bus, cycling and walking networks within the Black Country - also using the traditional canal network as a regeneration opportunity.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place-making? Yes/No; If you think that any other changes should be made to Policies CSP3 or CSP4, please provide details.

Question 95 - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied? Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

It is important that the Environmental networks within the Black Country are developed and improved to boost the image of the area and provide the enhancement in the landscape and environment to support the local economy and provide a platform for residential development.

The promotion of a Garden City for the Black Country was a positive initiative to raise the profile of the area and attract funding, but bearing in mind that the Black Country Garden City proposal incorporated a wide range of disparate and unconnected sites the traditional concept and principles of a Garden City are unlikely to be easily translated into the Black Country context.

Question 98 - Do you support the proposed changes relating to Design Quality? Yes/No; If you think that any other changes should be made to Policy ENV3 please provide details.

We support the proposal to remove the reference to the Code for Sustainable Homes since this has been deleted as a requirement from the NPPF.

Question 99 - Do you think that national standards for housing development on water consumption, national access standards or national space standards should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why. Should any standards be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

We are not convinced that there is a need to apply national standards for water consumption, national access standards or minimum space standards to schemes in the Black Country, unless there is a clear justification, all of which would tend to make housing less affordable. The same principle would apply for both brownfield and greenfield (and green belt) sites. Most builders adhere to Building for Life specifications and Building Regulations are becoming ever more stringent to cater for access and environmental standards.

Question 100 - Do you support the removal of the reference made to canal projects? Yes/No; Do you think that any other changes should be made to Policy ENV4? Please provide details.

Whilst there may be a case for the removal of references to specific canal projects we would expect to see a rather more positive strategy for both canal restoration and for regeneration relating to the canals to encourage exploiting the historic assets which the Black Country is famous for and enjoys.

Question 118 - Do you agree with the proposal to streamline and simplify the Core Strategy Monitoring Framework? Yes/No; If no, please explain why

We have no objection to removing redundant or superfluous monitoring targets and information to simplify and streamline the process. However, since the Black Country Core Strategy is being reviewed in tandem with the South Staffordshire Local Plan there may be a need for a monitoring schedule to link the two, so that South Staffordshire is able to assist in bringing forward sites to meet the Black Country's needs.

Question 119 - Do you think that a new Core Strategy policy is required? Yes/No; If yes, please explain why and provide details of the suggested policy.

We agree that there may be a case, as outlined in paragraph 6.2.6 to address changes to green belt so that they relate to specific sites rather than general areas, since new GB boundaries need to be properly defined and the 'exceptional circumstances' adequately tested.
Appendices B and C.

The monitoring figures within Appendices B and C indicate that the Black Country has fallen a little behind in its housing output (-3039) compared with its overall target for the cumulative plan period so far. Whilst this is not significant, it demonstrates that measures need to be taken to link the availability of sites with Southern Staffordshire where there are sustainable opportunities which are more readily available and to undertake a coherent and consistent review of the green belt to address the shortfall of sites.

Call for Sites - potential options.

We have already referred above to the Sandy Lane site at Codsall and will be submitting this as a potential opportunity to extend an existing consented site north of the village which was previously 'safeguarded' green belt land and together with the existing built-up area now surrounds the Sandy Lane site on three sides.

We have also referred to a potential strategic site at Wappenshall north of Telford which can be developed in conjunction with HCA land and has been promoted through the Telford & Wrekin Local Plan. Telford provides a genuine opportunity to take-up surplus requirement from the Black Country, to address a shortage of supply where green belt would not be affected.

I trust this submission is helpful in formulating your emerging Core Strategy review.

Yours sincerely

John Acres

ACRES LAND & PLANNING LTD

These representations are made on behalf of Heyford Homes Ltd which has various land interests in the West Midlands and beyond. The representations do not address in any detail the scale or nature of the need for new housing in the Black Country though the right to do so at later stages of the BCJCS Review process is reserved.

However the published evidence & other material which informs the Issues & Options consultation demonstrates that there is a clear need to allocate a substantial amount of additional land for new housing; and that this need cannot be met without releasing for development a significant amount of land that is currently within the Green Belt.

The BCJCS Review's approach to addressing this challenge needs to consider all options available and the potential of releasing land in the Green Belt which is of little functional value or strategic landscape importance should be seriously explored, especially where land is visually enclosed and so where development would have little or no impact on the charactor or openness of the wider landscape and so where development would not prejudice the purposes for which Green Belt is designated.

It should also recognise that new housing in such areas can help sustain currently less than sustainable patterns of development, for example by extending in an organic way existing enclaves of development to enhance their security & conviviality and by making public transport serving the existing network of settlements more viable.

Further, the Review should note that development which meets the above criteria can also contribute to meeting the immediate need to address the shortfall in the supply of new, high quality housing essential to attracting & retaining high skilled workers, as acknowledged by BCJCS Policy HOU 2 (esp para 3.2) and Policy
PL3 Housing of the Black Country Strategic Economic Plan. Such development at a relatively modest scale would not detract from the thrust of whatever overarching spatial strategy is pursued and should be supported as making a positive contribution to achieving wider policy objectives as well as meeting local and
Black Country wide housing needs.

The BCJCS Review process is urged to give positive consideration to taking such an approach in its review of the Green Belt; and also to giving positive consideration to facilitating the grant of planning permissions now where such development can meet immediate needs.

The Strategic Challenges and Opportunities (Questions 2-6)
2.4 Taylor Wimpey generally agrees with the key issues identified but makes specific comment regarding relevant issues below.
Key Issue 1 - Updating the Evidence Base
Taylor Wimpey considers that the Key Evidence set out in Table 1 is broadly sufficient to support the BCCS review but notes that the Government is currently proposing material changes to the Framework and Practice Guidance to make the evidence requirements for Local Plans more proportionate1. Any such changes may lead to further additional work being necessary for the BCCS to be found sound when examined. Taylor Wimpey therefore reserves the right to make further comment on evidence requirements until such time that more detail is available on the proposed changes to national policy and guidance.
Key Issue 2 - Meeting the Housing Needs of a Growing Population
2.6 The CD identifies a housing need of 78,190 for the Black Country for the period 2014 to 2036; 3,554 dwellings per annum [dpa]. Taylor Wimpey considers that this is insufficient to meet the needs of the Black Country's growing population and is not in line with national guidance. The 'Black Country Housing Needs Assessment - Headroom Report' sets out the basis for this view.
2.7 The CD is based upon the March 2017 Strategic Housing Market Assessment [SHMA] which uses the 2014 Sub-National Population Projections [SNPP], with an allowance for vacancy rates and adjustment for past housing under-delivery. Finally the CD uplifts the target by 3,000 dwellings to accommodate some of Birmingham's unmet housing need. The SHMA has a flawed methodological approach, particularly: the lack of alternative household and populations projections such as using long term migration rates and no sensitivity adjustment for historic low household formation rates in younger age cohorts as required by the Framework [§159] and 1 Housing White Paper [§1.10 and A.19] Practice Guidance2; and an underestimate of the need to increase delivery in response to market signals (as recommended by the Practice Guidance3 and in recommendations made by the Local Plan Experts Group [LPEG]4).
2.8 Taylor Wimpey commissioned Lichfields to undertake an independent assessment of the Black Country's OAHN. This involved modelling a number of demographic and economic scenarios to forecast future population and household growth, following the Framework and recommendations of the Practice Guidance and LPEG. This found that the CD significantly underestimates the level of housing required to support the needs of the Black Country's growing population.
2.9 A more appropriate and robust OAHN for the Black Country (excluding South Staffordshire) is 4,518 to 5,473 dpa. This is based upon the long term migration trends seen in the Black Country, with an adjustment to household formation rates for younger age cohorts. The OAHN also includes uplifts to each local authority to reflect negative market signals and an increased affordable housing need in Dudley. Finally the OAHN sets out an increased requirement of up to 955 dpa to reflect the Black Country's proportionate 'fair share' of Birmingham's unmet housing need. The 'Black Country Housing Needs Assessment - Headroom Report' provides further detail on the approach and assumptions used to derive this OAHN.
Key Issue 3 - Supporting a Resurgent Economy
2.10 The Framework and Practice Guidance make it clear that economic growth needs and housing must align to promote sustainable patterns of development. An imbalance between housing and employment land growth could lead to unsustainable commuting patterns or constrain growth. The Practice Guidance5 makes clear that economic forecasts must have regard to the growth of working age population within the HMA, and consider demographically derived assessments of future employment needs6. This is particularly important as the economic growth ambitions of Birmingham will need to be supported by housing provision in the wider HMA, and the Black Country local authorities have an important role to play in supporting this. The Practice Guidance7 goes on to say that a failure to agree housing provision as part of the duty to cooperate would result in unmet housing need. The Framework sets out that Local Planning Authorities [LPAs] should ensure that their assessment of strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals [§158].
2.11 The BCCS sets out the Economic Development Needs Assessment's [EDNA] recommendations for up to 800 ha of additional employment land to meet the Black Country's B1, B2 and B8 needs for the period 2014 to 2036. Taylor Wimpey welcomes the Black Country's aspirations for economic growth, though further evidence is required to ensure that there is sufficient housing provision to support these ambitions. The EDNA is based solely upon economic led scenarios (past delivery rates and economic growth forecasts) and does not consider the needs arising from anticipated housing growth. Further evidence is therefore required to determine the demographically led need for employment land in the Black Country to ensure that employment land supply and housing provision align, as the CD fails to align with national guidance. This evidence would need to demonstrate the anticipated employment land required to support
2 Practice Guidance Ref: 2a-015-20140306
3 Practice Guidance Ref: 2a-019-20140306
4 LPEG (March 2016) Report to the Communities Secretary and to the Minister of Housing and Planning
5 Practice Guidance Ref: 2a-018-20140306
6 Practice Guidance Ref: 2a-032-20140306
7 Practice Guidance Ref: 2a-018-20140306
demographically led scenarios, to ensure that it would not result in an over or under supply of employment land.
2.12 Taylor Wimpey welcomes the recognition in the CD that some employment sites may be unfit for purpose and could be considered for alternative uses such as housing. This aligns with the Framework [§22] which states that allocated employment sites for which there is no reasonable prospect of development should not be protected in the long term. Proposals for alternative uses on such sites should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.
Key Issue 6 - Reviewing the Role and Extent of the Green Belt
2.13 Local planning authorities are currently required by the Framework [§14] to positively seek opportunities to meet the development needs of their area. The Framework [§17] also sets out 12 core planning principles, including how planning should:
"...proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities."
2.14 The Practice Guidance8 states that the need for housing refers to:
"...the scale and mix of housing and the range of tenures that is likely to be needed in the housing market area over the plan period - and should cater for the housing demand of the area and identify the scale of housing supply necessary to meet that demand."
2.15 Furthermore, as set out in Housing White Paper, the Government intends to extend the requirement to accommodate housing need to also include "any needs that genuinely cannot be met within neighbouring authorities."9
2.16 The CD [§3.42] recognises the need to identify new sites outside of the urban area and currently in the Green Belt, to accommodate the housing need of the Black Country. In addition to the housing needs of the Black Country local authorities, any additional identified need from the GBHMA must be accommodated within the Black Country. Housing sites must therefore be released from the Green Belt as there is insufficient available land within the urban areas to meet the requirements.
2.17 The Framework [§§83-85] sets out the need to demonstrate 'exceptional circumstances' when amending Green Belt boundaries and this is reinforced by the Housing White Paper [§§137- 140]. Taylor Wimpey considers that the scale of the housing required and the lack of land outwith the Green Belt constitutes the necessary 'exceptional circumstances' to justify that Green Belt land should be released for housing. The local authorities therefore need to provide a sound evidence base which is robust in demonstrating the 'exceptional circumstances case' and ensure it complies with the Housing White Paper [§139].
8 Practice Guidance Ref: 2a-003-20140306
9 Housing White Paper - Page 79: Box 2
2.18 In this context, Taylor Wimpey fully supports the carrying out of a Strategic Green Belt Review as this is necessary to ensure sufficient land is provided to meet the Black Country's and GBHMA's objectively assessed housing needs over the course of the plan period.
2.19 Taylor Wimpey supports the release of Green Belt sites, including specific allocations for development by 2036 through the Core Strategy review. It is critical that the Green Belt Review process is fully informed by the GBHMA Growth Study and that developers and other stakeholders are fully engaged both in terms of the proposed methodology and any site assessment work.
2.20 Call for Sites forms and Development Statements for the sites at Chester Road, Streetly and Bosty Lane, Aldridge are being submitted on behalf of Taylor Wimpey alongside these representations. The Call for Sites submission in relation to Chester Road, Streetly clearly demonstrates that the site no longer fulfils the purposes of including the land within the Green Belt; should be removed from it; and, should be allocated for housing development in the BCCS.
2.21 Furthermore, in addition to housing allocations, the BCCS should allocate safeguarded land to provide greater certainty over the Green Belt boundaries beyond the plan period.
2.22 Where housing delivery is failing to meet plan requirements, a partial or full plan review should normally be considered to allocate safeguarded land for housing development. However, it is imperative that the BCCS includes clear triggers for such a review to ensure that the plan is transparent and effective.
2.23 In accordance with the recommendations of the LPEG Report, the Council should provide a mechanism for the release of developable reserve sites equivalent to 20% of the housing requirement. Taylor Wimpey considers that reserve sites, to be taken out of the safeguarded land supply if certain triggers are met, should be identified in the BCCS. This approach has been taken by other local authorities in adopted Local Plans and such triggers would include the lack of a five year supply or delivery below the housing trajectory. A good example of this is the West Lancashire Local Plan [Policy RS6] which includes the following mechanism for releasing reserve sites after 5 years of the plan, namely:
"If less than 80% of the pro rata housing target has been delivered after 5 years of the Plan period, then the Council will release land from that safeguarded from development..."
2.24 Similar triggers are included in the policy for low delivery after 10 years or if new evidence emerges that the housing requirement should be higher. An extract of the West Lancashire Local Plan [Policy RS6] is included at Annex 1 for reference.
Key Issue 9 - Working Effectively With Neighbours
2.25 It is acknowledgement that the Black Country authorities are committed to working in partnership with neighbouring stakeholders and meeting the requirements of the Duty to Co- Operate set out in the Framework. However, significant emphasis should be put on the Black Country's role and responsibility for meeting any unmet housing need from the Greater Birmingham Housing Market Area [GBHMA].
2.26 Any additional identified need from the GBHMA must be accommodated within the Black Country and additional sites allocated for housing.
Reviewing the Strategy to Meet New Challenges and Opportunities
Vision, Principles, Spatial Objectives and Strategic Policies (Questions 7-9)
2.27 It is considered that the BCCS vision and sustainability principles remain generally appropriate as they reflect the sustainability principles of the Framework and Practice Guidance. Taylor Wimpey however, reserves the right to make further comment on the specific wording at subsequent stages of consultation on the BCCS.
2.28 It is considered that the BCCS spatial objectives remain generally appropriate but an obvious omission is a specific objective for providing the necessary level of housing in the Black Country, including any unmet housing need from the GBHMA. Such an objective should be added and other relevant objectives (i.e. 1 and 8) also amended to reflect the need to provide sufficient high quality housing in the locations where it is needed.
2.29 Taylor Wimpey agrees that policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the growth network. In particular, the policies will need to reflect and provide for adequate levels of housing based on robust evidence and including any additional identified need from the GBHMA.
Reviewing the Spatial Strategy
Stage 1: Strategic Options 1A and 1B - Continuing the Role of the Growth Network (Questions 10 and 11)
2.30 The adopted BCCS spatial strategy focussed on the Growth Network, which was identified as having the ability to meet the 'majority of long term development needs' [BCCS §4.11]. Taylor Wimpey agreed that the Growth Network no longer has the ability to meet the majority of long term development needs and the CD identifies two strategic options to meeting the housing and employment requirements.
2.31 Strategic Option 1A would seek to meet all remaining housing and employment land growth needs outside the Growth Network, whilst Strategic Option 1B would seek to re-structure the Growth Network, releasing some existing employment land for housing within regeneration corridors.
2.32 The CD makes it clear that Option 1B would be 'very challenging' [§§4.18-4.20] and acknowledges that despite the previous aim to shrink the stock of employment land, the employment land stock has proved to be more resilient than predicted and sites have proved difficult to bring forward for housing [CD §5.19]. The adopted BCCS planned for a contraction in net employment land but there is now a recognised need to increase employment land stock. If any employment land were to be redeveloped for housing within the regeneration corridors, or any amendments to any regeneration corridor boundaries were proposed, the local authorities will need to ensure that any proposed development sites were sustainable and viable.
2.33 Further work is therefore required in order to assess the feasibility of Option 1B in terms of whether it would be viable and/or sustainable and determine how much employment land would realistically be available and developable for housing.
2.34 Any employment land displaced under Option 1B would need to be made up elsewhere
[CD §4.19]. Therefore, whilst Taylor Wimpey does not object to the retention of the Growth
Network, there is a need to provide additional land to accommodate the housing needs of the Black Country and the unmet needs of the GBHMA. The CD identifies that further land will be required to provide 22-25,000 new homes and up to 300ha of new employment land [§4.12]. Additionally, analysis undertaken by Lichfields indicates that the BCCS proposals to accommodate 3,000 dwellings of Birmingham's unmet needs significantly underestimates the proportionate 'fair share' expected of the Black Country based on the size of its population. The requirement could be as high as 955 dpa, though it is recognised that more recent evidence is needed to determine the feasibility of distributing Birmingham's unmet need across the wider GBHMA.
2.35 There is a clear and unquestionable need to provide significant amounts of housing land outwith the Growth Network within the Green Belt. Therefore the BCCS must identify and allocate suitable sites for release from the Green Belt for housing development, whichever strategic option is pursued. Taylor Wimpey however broadly supports Option 1A.
Stage 2: Strategic Options 2A and 2B - Housing and Employment Outside the Urban Area (Questions 12-20)
2.36 There is inadequate land within the Black Country urban area to meet emerging employment and housing needs and there is also a pressing need to assist Birmingham in meeting its acute housing shortfall. Additionally an independent assessment of the Black Country's OAHN indicates a much higher requirement than that proposed by the BCCS (further details are provided in the 'Black Country Housing Needs Assessment - Headroom Report'). This need cannot be met within the existing urban area of the Black Country and therefore exceptional circumstances exist to justify the release of enough sites from the Green Belt to boost the supply of housing to meet the identified needs.
2.37 The CD identifies two spatial housing options to achieve this, namely 'rounding off' (Spatial Option H1) and Sustainable Urban Extensions [SUEs] (Spatial Option H2).
2.38 Taylor Wimpey considers that strategic scale Sustainable Urban Extensions [SUE] would normally comprise approximately 700 or more dwellings and provide new strategic social and physical infrastructure such as major highways improvements, and community healthcare and education facilities such as GPs practices or schools. Sites of around 300-700 dwellings may also constitute SUEs where they would provide substantial elements of social and physical infrastructure but not to the same scale as strategic SUEs.

2.39 Allocating SUEs of different scales across the Black Country could contribute to a mix of uses and a wide range of house types to significantly boost the supply of housing and could provide for significant investment in new infrastructure. However, relying only on very large scale sites to deliver the housing needed would have associated risks. Strategic scale sites often have more complex issues associated with them such as multiple ownerships and/or significant infrastructure requirements, which can restrict and/or delay delivery. Releasing smaller sites would help promote choice and opportunity for those in need of housing and also for developers to ensure that sustainable developments in the right locations will be viable and actually delivered. Smaller sites would need to be largely supported by existing infrastructure but could also contribute improvements to and therefore boost the existing local infrastructure in appropriate sustainable locations.

2.40 Taylor Wimpey therefore considers that there is merit in both Spatial Options H1 (rounding off) and H2 (Sustainable Urban Extensions) and therefore the most appropriate overall spatial approach in the BCCS should be to combine the two approaches. Specifically, the local authorities should identify deliverable and viable sites of all range of sizes, in sustainable locations where the size of the site and range of house types can reflect the local need for housing and the character of the area.

2.41 The critical challenge facing the Black Country is that whichever approach is adopted, large areas of the Green Belt are required for housing. Any site released from the Green Belt for housing would need to be available, suitable, achievable and viable and well related to existing patterns of development. All sites will also need to be assessed and those which would cause the least harm to Green Belt purposes. The Black Country Green Belt Review (due to be published in 2019) is therefore a crucial piece of work to identify sustainable sites which can be allocated for housing in the BCCS.

2.42 In this context, Call for Sites submissions relating to land at Chester Road, Streetly, and Bosty Lane, Aldridge accompany these representations and set out how each site would; provide a sustainable location for residential development; no longer contribute to Green Belt purposes; and, should therefore be removed from the Green Belt and allocated for residential development.

2.43 Taylor Wimpey objects to the suggestion that the Black Country's housing growth could be exported to neighbouring authorities for a number of reasons:
1 The OAHN should be fully met within the Black Country HMA to meet the needs of its residents and its growing population. However it is recognised that HMAs do not align precisely with local authority boundaries and there are grey areas at the margins in particular. As such, there can be overlaps between HMAs and there are situations where sites fall within multiple HMAs. For example the wider Black Country & South Staffordshire HMA has some overlap between the LPAs of Wolverhampton and South Staffordshire. In such situations where sites abut the borders of HMAs and are well related and accessible to settlements in adjoining districts, they can practically help meet some of the neighbouring needs whilst also meeting the needs of their HMA.

2 The nearby areas in the GBHMA cannot accommodate additional housing growth; for example Birmingham is already looking to neighbouring authorities to accommodate its growth. It is therefore unfeasible to expect neighbouring authorities to also accommodate the needs of the Black Country HMA.

3 As detailed in the 'Black Country Housing Needs Assessment - Headroom Report' there is a significant need for housing growth in the Black Country HMA, above the target proposed by the CD. Homes need to be built in locations that meet the needs of the residents living within and moving to the Black Country HMA. Additionally the Black Country HMA has an important role to play in helping to accommodate the unmet needs of Birmingham that must be shared by neighbouring authorities. Housing growth must be physically accommodated somewhere and it is not realistic or feasible for the Black Country HMA's needs to be exported to neighbouring authorities, particularly in addition to Birmingham's needs being exported.
4 The CD does not provide sufficient evidence to demonstrate that it would not be able to accommodate its housing growth needs within the Black Country HMA.

2.44 Taylor Wimpey considers that there are sufficient sites and locations within the Black Country to accommodate housing growth and sustainable development, albeit not within the existing urban area.

2.45 Taylor Wimpey considers that exporting housing needs would not be realistic as it would primarily rely upon increased levels of commuting. This would fall on journeys by car, increasing traffic flows between authorities within and outside the Black Country HMA. This is considered to be both unsustainable and undesirable, exacerbating existing pressures on the road network. The proposed Wednesbury to Brierly Hill Metro extension is expected to be open for passenger services in 2023, providing connectivity to regional and national rail services and Dudley Town Centre10. The Metro extension would improve capacity, journey times and accessibility for residents and people working in Dudley and Sandwell.

2.46 Whilst Taylor Wimpey does not wish to comment in detail on the spatial options for accommodating employment land growth, it notes that the Practice Guidance11 requires that potential job growth is considered in the context of potential unsustainable commuting patterns and as such plan-makers should consider how the location of new housing could help address this. Ensuring a sufficient supply of homes within easy access of employment sources represents a central facet of any efficiently functioning economy and can help to minimise housing pressures and unsustainable levels of commuting (and therefore congestion and carbon emissions).
Delivering Growth - Infrastructure and Viability

2.47 The local authorities should ensure that any proposed changes to policy DEL1 accord with the Framework [§§173-177] and do not place any unnecessary additional burden on smaller development sites as a result of attempting to be applicable to SUEs. Requirements relating to infrastructure needed in association with SUEs could be detailed in a separate policy or policies specific to each SUE.

2.48 Taylor Wimpey reserves the right to provide a further response on any changes to policy DEL1 or other policies dealing with infrastructure requirements at later stages of the preparation of the BCCS.

Social Infrastructure (Questions 22-25)

2.49 Taylor Wimpey does not have any specific comments to make on social infrastructure at this time but accepts that new social infrastructure is often required in relation to housing developments in order to achieve sustainable, high quality development. However, the local authorities must ensure that the BCCS accords with the Framework [§§173-177] and does not place unnecessarily burdensome requirements on developments to the point that viability and deliverability is impacted. Taylor Wimpey reserves the right to comment on such issues at the next stage of preparing the BCCS.

Physical Infrastructure (Questions 26-28)

2.50 Taylor Wimpey does not wish to make detailed comments on physical infrastructure at this time but accepts that new physical infrastructure is often required in relation to housing developments in order to achieve sustainable, high quality development. However, the local authorities must ensure that the BCCS accords with the Framework [§§173-177] and does not place unnecessarily burdensome requirements on developments to the point that viability and deliverability is impacted. Any infrastructure requirements should be proportionate to the scale of development proposed. Taylor Wimpey notes that the requirement of new physical infrastructure to serve any needs should be based on robust evidence.

10 http://www.metroalliance.co.uk/wednesbury-brierley-hill/
11 Practice Guidance Ref: 2a-018-20140306
2.51 Taylor Wimpey reserves the right to comment on such issues at the next stage of preparing the BCCS.
Delivery and Viability (Questions 29-30)
2.52 The CD [§§5.22-5.23] states that the Black Country has a good track record of working with developers to address viability issues and deliver sites and that delivery work will be undertaken in relation to Green Belt sites to understand what is required to make them viable and deliver the necessary infrastructure. A pro-active approach to ensure that any sites released from the Green Belt are viable and deliverable is welcomed.
2.53 In terms of the possible impacts of Green Belt release on the deliverability of brownfield sites, Taylor Wimpey notes that the Housing White Paper sets out clear policy proposals which the Council needs to consider in terms of ensuring that its Local Plan evidence base is robust. This includes the Housing Delivery Test [Housing White Paper §1.10] and a need to ensure that it has examined fully all other reasonable options when considering the release of land from the Green Belt [Housing White Paper §1.39-1.40].
2.54 Taylor Wimpey reserves the right to comment on the appropriateness of infrastructure delivery mechanisms either through conditions, planning/highway obligations or CIL until the Government provides further advice following the publication of the White Paper and any amendments to CIL and S106 obligations which are anticipated in the Autumn Budget.
Funding for Site Development and Infrastructure (Question 31)
2.55 The mechanisms listed in the CD [§§5.35-5.38], for funding infrastructure associated with developments are considered appropriate.
2.56 Taylor Wimpey does not wish to comment on the specific sources of funding to make developments viable [CD §§5.26-5.32] but notes that 25% of the existing Black Country housing land supply is not viable under current market conditions [CD §5.28]. The CD states that the sources of funding identified 'should' provide enough support to ring forward a sufficient supply of land to meet short to medium term needs as set out in the existing local plan [§5.32]. However, housing needs in excess of those in the existing BCCS have now been identified including additional need from the GBHMA and the release of Green Belt land is needed to meet those needs. If the identified sources fail to deliver the anticipated level of funding, there will be extra pressure for viable and deliverable sites to provide for the increased levels of housing need.

2.57 It is essential therefore that viable, deliverable Green Belt sites are allocated through the BCCS and the local authorities should also consider identifying further safeguarded land as set out in the Framework [§85] in order to meet development needs stretching well beyond the plan period (see §§2.21- 2.24 above).
Review of Existing Core Strategy Policies and Proposals
Policy Area A - Health and Wellbeing (Questions 32-34)
2.58 Taylor Wimpey does not have any specific comments to make on health and wellbeing at this time but in terms of design features of new developments, the local authorities must ensure that the BCCS accords with the Framework [§§173-177] and does not place unnecessarily burdensome requirements on developments to the point that viability and deliverability is impacted. Taylor Wimpey reserves the right to comment on such issues at the next stage of preparing the BCCS.
Policy Area B - Creating Sustainable Communities in the Black Country (Questions 35 - 48)
HOU1 - Housing Land Supply
2.59 The Framework [§47] is clear that there is a need to boost significantly the supply of housing in order to deliver a wide choice of high quality homes and ensure that Local Plans meet the full and objectively assessed needs for market and affordable housing in the relevant housing market area.
2.60 The BCCS should plan for a level of housing growth to support the economic aspirations of the local authorities, align with their growth objectives, and accommodate the unmet need from the GBHMA. The local authorities should ensure that the relevant evidence base documents and studies have regard to each other, and that the objectively assessed need [OAN] for employment land is aligned with the OAN for housing. Demand for housing land and demand for employment land are inherently linked, and provision of both should be well planned and promote sustainable travel.
2.61 There are substantial negative economic and social implications of not providing sufficient housing to meet identified needs and demand. It is therefore crucial that enough housing land is allocated in the BCCS for residential development.
2.62 In order to ensure robustness and flexibility, the BCCS must ensure that the local authorities are able to demonstrate a deliverable 5 year supply of housing land throughout the life of the plan. It is therefore important that the spatial distribution of development allows all sites identified for development to conform with the deliverability criteria set out in the Framework [§47 and footnote 11].
2.63 Taylor Wimpey has not carried out a detailed assessment of any sources of supply or had the opportunity to review any evidence on which the housing supply in the BCCS will be based but notes that the housing target for the new plan period (2014-36) will be established through the BCCS review. Taylor Wimpey therefore reserves the right to comment on these issues at a later stage but notes that the BCCS will need to accord with the Framework [§47] and meet the full, objectively assessed needs for market and affordable housing in the housing market area. In particular:
1 Any sites identified in the BCCS land supply will need to meet the tests set out at footnotes 11 and 12 of the Framework and if a small sites windfall allowance is to be included, it must be based on robust evidence of past delivery of such sites;
2 The CD [§6.22] proposes a reduction in the levels of discount for non-delivery on sites within the Growth Network. Taylor Wimpey notes that the levels of discount should not be reduced unless robust evidence on past delivery can be presented in support of this. The housing needs of the Black Country and GBHMA can only be met by releasing sites from the Green Belt, outside of the growth network where there will be less certainty and therefore an appropriate discount is necessary; and,
3 The housing requirement in the BCCS should be treated as a minimum rather than a maximum figure and an adequate surplus should be provided to give flexibility to deal with changing circumstances as required by the Framework [§153].
2.64 In summary, the BCCS must provide the necessary land to accommodate both the housing needs of the Black Country and the additional need from the GBHMA. The BCCS must also provide flexibility to deal with changing circumstances as required by the Framework [§153] and for the longer term needs of the Black Country. The local authorities therefore need to identify significant amounts of Green Belt land and allocate sites such as those at Bosty Lane, Aldridge and Chester Road, Streetly, through the BCCS.
HOU2 - Housing Density, Type and Accessibility
2.65 Taylor Wimpey supports parts of the existing text to policy HOU2 in so much as it recognises that the density and type of new housing provided on each site will be informed by:
1 The need for a range of types and sizes of accommodation to meet identified sub regional and local needs;
2 The level of accessibility by sustainable transport to residential services, including any improvements to be secured through development; and,
3 The need to achieve high quality design and minimise amenity impacts, taking into account the characteristics and mix of uses in the area where the proposal is located.
2.66 Taylor Wimpey supports the removal of the final paragraph of policy HOU2 [CD §6.28] which currently requires local plan documents to prescribe the density and house type mix for each allocation.
2.67 The Housing White Paper signals the Government's intention to minimise the use of local standards (through the Housing Standards Review) and therefore Taylor Wimpey does not support accessibility standards applied on a 'blanket' policy basis as this can lead to viability issues on developments.
2.68 Higher density development will be more appropriate in town centres and close to public transport nodes and local services but the current policy wording was adopted in the context of a spatial strategy which did not require substantial Green Belt release, as is now required. The policy should be updated to allow for the density and house type mix of any housing development site should reflect the local context in which the site is located.
2.69 The balance of new housing types and sizes should be based on an appropriate evidence base such as the 2017 SHMA findings. It is important however to also maintain a degree of flexibility to respond to changing local circumstances and more up-to-date evidence as time goes on.
2.70 Taylor Wimpey would not support a policy requirement for serviced plots on large housing sites if it threatened the viability and/or deliverability of the site. If such a requirement was introduced, there must be a mechanism to relax the requirement if it proved to not be viable on any given site.
2.71 Taylor Wimpey reserves the right to make more detailed comments on the specific wording of policy HOU2 at future stages in the preparation of the BCCS.
Policy HOU3 - Affordable Housing
2.72 The Council is querying whether the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment. Such an increase should only occur if the SHMA is robust.
2.73 Taylor Wimpey generally supports the provision of affordable housing, particularly in light of the Housing White Paper which sets out the Government's commitment to helping to support people to buy their own homes. Taylor Wimpey is supportive of the inclusion of starter homes as defined affordable housing provision and the Council should amend any evidence within the SHMA to meet emerging National Guidance. The White Paper [§4.15] states that there is a desire to deliver starter homes as part of a mixed package of affordable housing that can respond to local needs and markets.
2.74 The threshold in Policy HOU3 of sites of 15 or more dwellings should be reduced to sites of 11 or more dwellings to reflect the Practice Guidance12 and ensure that all major housing development proposals that can contribute to the provision of affordable housing, do contribute, particularly if the overall annual affordable homes target is increased.
2.75 Taylor Wimpey strongly objects to the proposal to increase the affordable housing requirement on future Green belt release sites. The 25% affordable housing requirement on private housing sites should not be increased, nor should a higher requirement set for Green Belt release housing sites, unless robust evidence shows that his would be viable and deliverable. The local authorities must ensure that the BCCS accords with the Framework [§173-177] and does not place unnecessarily burdensome requirements on developments to the point that viability and deliverability is impacted. In any case therefore, the final paragraph of Policy HOU3 must be retained so that on sites where the policy requirement for affordable housing is proven not to be viable, the maximum proportion of affordable housing will be sought which will not undermine the development's viability.
Policy HOU5 - Education and Health Care Facilities
2.76 If Policy HOU5 were to be expanded to include any other types of built social infrastructure, they would need to be adequately evidenced and viability tested to ensure that they would not place additional burdens on housing development sites to the point that viability and/or deliverability is threatened.
2.77 Taylor Wimpey reserves the right to comment further on this matter and any specific policy wording at subsequent stages in the preparation of the BCCS.
Policy Area B - Creating Sustainable Communities in the Black Country (Question 49)
Policy DEL2 - Managing the Balance between Employment Land and Housing
2.78 Taylor Wimpey does not wish to provide detailed comments at this point on whether policy DEL2 should be retained and/or amended as this will depend largely on the overall spatial strategic and strategic option pursued. Taylor Wimpey reserves the right to comment further on this matter and any specific policy wording at subsequent stages in the preparation of the BCCS.
Policy Area F - The Black Country Environment (Questions 94-103)
Policies CSP3 and CSP4 - Environmental Infrastructure and Placemaking
2.79 The proposed changes to Policies CSP3 and CSP4 set out in the CD [§6.1.46] are supported as they will simply make the policies consistent with the local authorities' adopted Development Plan Documents.
12 Practice Guidance Ref: 23b-031-20161116
2.80 If Garden City principles were to be introduced they would need to be fully viability tested so as not to threaten the viability and/or delivery of housing sites.
2.81 Taylor Wimpey reserves the right to make further detailed comments on the specific wording of these policies at subsequent stages in the preparation of the BCCS.
Policy ENV3 Design Quality
2.82 Taylor Wimpey agrees with the proposed change to Policy ENV3 to remove the requirement to meet Code for Sustainable Homes Level 3 or above for residential development as this no longer accords with national policy and guidance.
2.83 Taylor Wimpey acknowledges the need to provide accessible accommodation but given the Government's intention to minimise the use of local standards (through the Housing Standards Review), Taylor Wimpey would not support the introduction of any additional accessibility standards introduced on a 'blanket' policy basis as this would lead to viability issues on developments. The same would be true for water consumption and space standards. The BCCS must accord with the Framework [§§173-177] and not place unnecessarily burdensome requirements on developments to the point that viability and deliverability is impacted.
2.84 Taylor Wimpey reserves the right to comment on these issues at the next stage of preparing the Local Plan.
ENV5 Flood Risk, Sustainable Drainage (SuDS) and Urban Heat Island Effects
2.85 Taylor Wimpey generally supports the proposed change to policy ENV5 to prioritise natural green space SuDS where it is "practical and viable" [CD §6.1.58]. The BCCS should also go further and define what is meant by 'practical' (i.e. where natural green space SuDS would not prevent the efficient use of land or achieving an overall high quality, well designed development).
2.86 Taylor Wimpey reserves the right to make further detailed comments on the specific wording of these policies at subsequent stages in the preparation of the BCCS.
ENV7 - Renewable Energy
2.87 Taylor Wimpey acknowledges and agrees with the recognition [CD §6.1.64] that any change to the % requirement would need to be justified with evidence. Taylor Wimpey therefore reserves the right to make further comment on any changes proposed at subsequent stages of the preparation of the BCCS.
Policy Are J - Growth Network Detailed Proposals (Question 117)
2.88 Taylor Wimpey agrees in principle with the proposed approach of updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy but reserves the right to make further comment on any specific changes proposed at subsequent stages of the preparation of the BCCS.
Policy Area K - Monitoring and Additional Policies (Question 118-119)
2.89 Taylor Wimpey supports the proposals to streamline and simplify the Core Strategy Monitoring Framework and focus on the key quantitative indicators, in particular 'net new homes'.
2.90 There is a clear and over-riding need to release sites from the Green Belt to meet the housing needs of the Black Country and GBHMA. Taylor Wimpey fully supports the recognition that a new section in the BCCS should allocate specific Green Belt sites for housing development [CD §6.2.6]. Taylor Wimpey reserves the right to make further detailed comments on such a section and the policies it contains at subsequent stages in the preparation of the BCCS.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered that for the second stage EDNA to be effective it must be informed by far wider
consultation with landowners, developers and employers than appears to have been the case with
the first stage exercise.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should be informed by far wider consultation with landowners,
developers and employers than appears to have been the case with the first stage exercise. The
Stage 1 report appears to have been informed by a fairly narrow range of consultees, and unless this
is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly
assessed.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
There is considerable potential for "rounding off" and relatively modest incursions into the Green
Belt for small to medium sized housing sites, and the "opportunities" identified in this regard in the
table under paragraph 4.29 of the Issues and Options Report should all be recognised. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The only circumstances in which any housing growth should be exported elsewhere in the HMA is if
there is compelling evidence it cannot be accommodated within the Black Country, and there is a
robust and certain framework in place to ensure that the homes will be required. An ongoing and
open ended general process of discussion around this issue is not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. Agreement needs to be reached in terms of how need across the HMA is going
to be met, and the BCCS Review provides an ideal platform in this regard.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, and unconstrained sites with immediate access to the
Strategic Road Network are required to contribute towards meeting the need for employment land,
particularly in relation to logistics led requirements; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of brownfield sites to contribute towards meeting employment land needs, but
this will not meet the requirements of the highly location sensitive large space occupiers that the
Black Country should be seeking to attract.
It might be that sites within Sustainable Urban Extensions (Spatial Option E3) can also make some
contribution in this regard, but this cannot be relied upon, particularly in the short term, and it is
unlikely that SUEs will provide an effective mechanism to accommodate large scale requirements.
Exporting growth to neighbouring areas (Spatial Option E4) should only be entertained as a last resort
and if there is compelling evidence it cannot be accommodated within the Black Country.
This again speaks to the point made elsewhere in these representations that for the second stage
EDNA to be most effective it should be informed by far wider consultation with landowners,
developers and employers than appears to have been the case with the first stage exercise. The
Stage 1 report appears to have been informed by a somewhat narrow range of consultees, and unless
this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly
assessed.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The type of approach set out in Policy HOU2 and Table 8 is appropriate in general terms, although
greater clarity should be provided to confirm that the standards are general ones, that their practical
application is highly location specific, and will be considered on a site by site basis to reflect local
circumstances. There is no requirement to increase the density standards, and again it should be
clarified that these (and indeed the accessibility standards) should be regarded as indicative only.
For Green Belt releases, site specific standards should be formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. There should be no
separate standards for particular housing types; this would add an unnecessary level of complexity
and risk hindering the delivery of such units where they might have been provided as part of schemes
otherwise broadly acceptable for their provision.
The SHMA should be used as a general guide to the types of houses to be delivered, but must be
applied generally, rather than rigidly, or again this will hinder delivery.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.