Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments.

Showing comments and forms 1 to 12 of 12

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 651

Received: 08/09/2017

Respondent: William Davis

Representation Summary:

Any policy should simply encourage provision rather than impose a "requirement". The accommodation of serviced plots for self or custom build on larger sites presents operational difficulties due to Health and Safety legislation as plots will often be built outside of normal working hours. They also create uncertainty and amenity problems for adjoining areas which may inhibit sales. Not every house builder will therefore wish to commit to such provision

Full text:

RE: BLACK COUNTRY CORSE STRATEGY ISSUES AND OPTIONS QUESTIONS


Please find below the responses from William Davis Ltd:
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?
The adopted core strategy pre-dates the 2012 National Planning Policy Framework (NPPF.) There is a need to re-assess the soundness of the existing and emerging policies against this. Moreover, the acknowledged scale of the housing requirement within the area and the associated Green Belt release forces more than a partial review. The proposals within the Issue and Options paper are fundamental changes and require a full review and re-structure of the document.

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?
The proposed documents to form the evidence base for the Core Strategy are considered sufficient; however it is essential that the Green Belt review is undertaken comprehensively. The Green Belt review should acknowledge that the release of smaller parcels of land for residential use in some areas may be more appropriate. The review should not preclude this approach by only assessing larger sites.

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?
Whilst it is accepted that a Duty To Co-operate to meet Birmingham's unmet need is established within the Issues and Options document which is in-line with paragraphs 156 and 178 of the NPPF; it is considered that due to the proximity of the Black Country to Birmingham and the available infrastructure, employment, and land to accommodate growth, the proposed accommodation of 3,000 of the 38,000 shortfall is too low and should be revisited following the Green Belt review. This sentiment is echoed within the 2017 White Paper "Fixing our broken housing market" where it is discussed plans should incorporate an "honest assessment of the need for new homes." Moreover, the White Paper discusses the need for Local Authorities to "work with their neighbours so that difficult decisions are not ducked." It is considered this direction and strategy needs to be incorporated more closely with any emerging policy and associated housing target.

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?
The NPPF states in paragraph 22 that "policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose." This is acknowledged within the EDNA and therefore is supported. However, the long term goal of placing a residential focus on these sites is not. It is apparent from the Annual Monitoring Reports (AMRs) of Walsall and Dudley (both 2016) that this is failing and housing land should be re-allocated within the forthcoming Green Belt review. Walsall discusses "land being lost from employment to use uses is more gradual than anticipated in the BCCS targets" and within the AMR actually shows an increase from residential land to employment land of 1.47 hectares in 2015-2016. Dudley can only demonstrate 8 Hectares of land from employment to residential between 2011 and 2016 against a target of 57. It is apparent from this evidence that the current requirement is unattainable.

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review?
A Green Belt review is supported as it is considered the only feasible and sustainable way to accommodate the housing need within the area. However, a review of the Green Belt should accommodate all potential sites and not exclusively larger parcels of land suitable for SUEs. Ideally the scoping and approach of the Green Belt review should be open for consultation.

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?
The issues set out in Part 3 require some adjustment as they appear to underestimate the difficulties of retaining the existing strategy whilst acknowledging the need for the release of Green Belt land to sustainably meet residential need.

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate?
Paragraphs 17 and 111 of the NPPF states Local Authorities should "encourage the effective use of land by reusing land that has previously been developed." However, the BCCS sustainability principle states Brownfield land should be put first. This is not consistent with the NPPF and should be altered accordingly.

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate?
As previously discussed, the aim of using redundant employment land to accommodate new residential growth has proved unsuccessful and if past trends continue will leave a significant shortfall in the housing target. Therefore, this should be altered to accommodate a variety of sites within the Green Belt.

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?
It is considered these policies are not in accordance with the requirement to release Green Belt land to accommodate the increased housing need. Therefore, they should be altered to be harmonious with this.

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?
Whilst it is not suggested an alteration of the regeneration corridors is required in order to support the emerging growth within the Black Country, there is a clearly a need to offer a broader focus on infrastructure, employment and housing ; as the geographical extent of the current corridors does not support the sustainable release of Green Belt land.

Question 11a - Do you support Strategic Option 1A?
1A is supported. This is because the previous Core Strategy's attempt to release employment land for housing need has proven to be ineffective and has fallen well short of target. Therefore, committing to extending this over a forthcoming plan period which features a far higher housing requirement would be destined to fail. Therefore Option 1B is unsustainable and unobtainable. 1A however, commits to a review of the existing strategy of Green Belt land which is essential to ensure that housing needs are successfully met by providing a broad portfolio of development opportunities.

Question 12a - Do you support Spatial Option H1?
Yes. Smaller sites should be used to contribute to the unmet need as SUEs often fall short of targets and are slow to deliver, whereas smaller strategic locations effectively and quickly contribute to housing figures by providing a broad portfolio of development opportunities. The use of smaller sites offers wider choice and balance throughout the housing market area contributing to social, economic and employment networks without overburdening infrastructure. Smaller scale Section 106 agreements can benefit communities in a sustainable manner further supported by CIL monies.

Question 12b - Do you think there are any potential locations that should be considered?
Yes-Land off Bromwich Lane, Pedmore. Land off Sutton Road, Walsall. Forms submitted through Call For Sites

Question 13a - Do you support Spatial Option H2
No. As previously mentioned, SUEs are not always the best solution as they can be slow to be delivered.. It is considered for a large area such as the Black Country where such a broad housing and social spectrum exists a mixed portfolio of small, medium and large scale residential commitments are more effective in terms of both delivery and sustainability.

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?
No. A successful Green Belt review, a Core Strategy that embraces a shift in the nature of development and Regeneration Corridor alteration will allow for the HMA to meet its own OAN.

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed?
Paragraph 47 of the NPPF states Local Authorities should "set out their own approach to housing density to reflect local circumstance." It is therefore considered there is a need for flexibility which takes into account individual sites in term of their siting, situation, surrounding area and access. Whilst it is acknowledged a broad density assumptions are required to achieve the housing need, a density set across the board is not in line with National requirements.

Question 41c - Do you support a requirement for large housing sites to provide serviced plots? Yes/No; any further comments?
Any policy should simply encourage provision rather than impose a "requirement". The accommodation of serviced plots for self or custom build on larger sites presents operational difficulties due to Health and Safety legislation as plots will often be built outside of normal working hours. They also create uncertainty and amenity problems for adjoining areas which may inhibit sales. Not every house builder will therefore wish to commit to such provision

Question 42- Do you agree that annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment?
In line with NPPF policy, any affordable housing targets are required to be based on a robust assessment of need and viability

Question 43a- Do you think that the existing Policy HOU3 site size threshold should be kept and 15 homes or more?
The site size threshold should be justified by viability evidence

Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites?
The target should reflect need/viability evidence as discussed above but any policy should not seek to load greater provision on Green Belt sites as this will simply inhibit overall delivery in these areas.
Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
It is apparent from AMR data that the release of employment land for housing is proving unsuccessful. The employment to residential land change progression is insufficient to meet the more demanding housing targets. Therefore it is considered a move toward Green Belt release is more sustainable and DEL2 requires a fundamental review.

Question 99a : Do you think that the national standards for housing developments on water consumption should be introduced in the Black Country?
The adoption of optional higher water efficiency standard should only be applied using the criteria set out in the NPPG (ID 56-013 to 56-017). The Black Country has not been identified as a water stress area in an up to date Water Cycle Study.

Question 99b : Do you think that the national access standards for housing development should be introduced in the Black Country?
No. National accessibility standards should only be introduced in accordance with the criteria set out in the NPPG.

Question 99c : Do you think that the national space standard for housing development should be introduced in the Black Country?
The nationally described space standard should only be introduced in accordance with the criteria set out in the NPPG (ID: 56-020).

Question 99d : Do you think the standards should be different for brownfield and greenfield sites?
No. It is not relevant to whether site is brown or green field.

Question 118: Do you agree with proposals to streamline and simplify the Core Strategy Monitoring framework?
The plan making process in the Black Country should be improved. The existing adopted Core Strategy is over-due for review and second tier Local Plans are still not yet in place six years after adoption of the Core Strategy. Any streamlining and simplification of the monitoring framework should incorporate more effective monitoring mechanisms such as key performance indicators. Currently the Councils are underperforming by 3,000 dwellings against adopted Core Strategy housing targets without triggering any positive policy response.

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1237

Received: 06/09/2017

Respondent: South Staffordshire Council, Planning and Strategic Services

Representation Summary:

Considering the low numbers on the register currently (nine for the entire Black Country), It may be most appropriate to set a target for each authority, rather than a percentage requirement for each large development coming forward. One potential approach could be to extrapolate need evidenced from the base periods to date, in order to determine how many plots each authority should be providing over the plan period.

Full text:

South Staffordshire Council response to the Black Country Core Strategy Issues and Options consultation

Purpose and scope of the review.

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?

It is acknowledged that the existing spatial strategy of focusing urban regeneration at the Growth Network has been successful. This strategy aimed to deliver regeneration in the Black Country and prevents the outward movement of people and investment from the MUA. The South Staffordshire Core Strategy was developed as a counterpoint to this and looked to limit development to meeting locally identified needs. Recent developments in the Black Country have shown this to be an effective strategy and therefore it seems sensible to explore if there is scope to stretch the existing spatial strategy in the first instance.

This acknowledged, it is clear that the challenges now faced are very different from those faced when the current Black Country South Staffordshire Core Strategies were developed. Principally, it is clear that the Black Country housing and employment shortfall (25,000 dwellings and 300ha of employment land) cannot be wholly met within the urban area and that some Green Belt release is inevitable. The NPPF (Paragraph 83) is clear that Green Belt boundaries should only be altered in exceptional circumstances, and as such, all reasonable non-Green Belt options should be fully explored. The Government's recent Housing White Paper makes it clear that demonstrating exceptional circumstances for Green Belt release is a high bar, and Green Belt boundaries should only be amended where authorities can demonstrate they have examined all other reasonable options, including effective use of suitable brownfield sites and estate regeneration. Therefore brownfield sites should be maximised as far as possible - both within and outside the existing Growth Network. Similarly, whilst recognising that estate regeneration is very challenging, if this option is not going to be pursued then the plan should set out the reasons why this is not considered a viable and deliverable option.

Key Issue 1 - Updating the evidence base

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.

The Council agrees that all the key evidence based studies identified with Table 1 are necessary. However, which evidence based documents are required may depend on which options for growth are progressed. It is acknowledged that a Landscape Character Assessment will form part of the HMA Strategic Growth Study however a Landscape Sensitivity Study considering the relative sensitivity of land cover parcels will also be required. The Issues and Options confirms that the Core Strategy will allocate strategic sites, and therefore dependent on which options for growth are pursued, it may be appropriate to undertake an assessment of the impact on heritage assets and their setting. Historic England should be able to offer advice on this matter.

Key Issue 2 - Meeting the housing needs of a growing population

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 housing need for the Black Country for the period 2014-2036 as identified in the SHMA is considered robust and the anticipated supply seems appropriate in line with national guidance; therefore the initial housing requirement of 24,670 is supported. The Council also supports the ongoing work to consider if there are options for surplus employment land to be allocated for housing, as well as considering the potential to increase the density of housing allocations and the limited release of surplus open space. Clearly, the Black Country authorities will need to demonstrate that the potential sources of supply within the urban area have been fully considered in order for Green Belt release to be justified.

Key Issue 3 - Supporting a resurgent economy

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 recommendation that the Black Country should plan for 800ha of employment land (B1 (b), B1(c), B2 and B8 uses) as suggested within the Economic Development Needs Assessment (EDNA) appears robust and in line with national guidance. The Issues and Options paper goes on to confirm that 394ha of employment land is available or is likely to come forward in the Black Country over the plan period, including opportunities to intensify existing employment areas. It is then apparent that the Black Country authorities are seeking to rely on some 100ha of employment land in South Staffordshire when concluding that there is a residual need to identify some 300ha of employment land through the Core Strategy review.

As you are aware, South Staffordshire Council is progressing its Site Allocations Document that seeks to allocate 62ha of additional employment land at proposed extensions to i54 and ROF Featherstone to meet a proportion of the Black County's employment needs. Remaining employment land at our strategic sites is relied upon in the District's employment land supply to meet South Staffordshire needs and therefore any additional supply that South Staffordshire Council can contribute above the 62ha (including a proportion of land at West Midland Interchange should it be consented) would need to be agreed through Duty to Co-operate discussions and a Memorandum of Understanding. We will be undertaking our own EDNA next year which will consider our own need for additional employment land and will provide a clearer picture of how much additional employment land South Staffordshire could contribute towards the Black Country supply, if any. Until this work has been done and agreements have been reached about the amount of existing supply that can contribute to the Black Country need, it is not possible to say if the stated residual requirement for 300ha of employment land is appropriate. The Council would welcome further Duty to Co-operate discussions with the Black Country authorities to establish if any unmet employment land need from the Black Country can be met within the District.

Key Issue 6 - Reviewing the role and extent of the Green Belt

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?

South Staffordshire Council is working closely with the Black Country authorities and others authorities within the HMA as the commissioning authorities for the Strategic Growth Study. In addition to this, the Council supports the Black Country authorities' approach of producing a more detailed Green Belt review to inform the Preferred Spatial Options Report. Currently officers are working with counterparts from the Black Country in ensuring that the more detailed Black Country Green Belt review uses a consistent methodology with the South Staffordshire Green Belt review that will be commissioned to support our Local Plan review at an appropriate stage.

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?

In the context of a partial review of the Core Strategy, the key issues as presented in Part 3 of the Issues and Options Report are considered appropriate.

Vision, Principles, Spatial Objectives and Strategic Policies

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

In the context of a partial review of the Core Strategy, the Core Strategy vision and sustainability principles remain appropriate.

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?

It is considered that most of these objectives remain valid. However, as it is acknowledged that some Green Belt release will be necessary, additional objectives around delivering sustainable urban extensions, or other smaller Green Belt releases (the 'rounding off' option) may be necessary dependent on which growth option is progressed.

Considering the pressure for housing and employment land it may be that a further objective around maximising brownfield opportunities - both within the Growth Network and outside it - is required.

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?

The focus of the existing Core Strategy was to focus the majority of growth at the strategic centres and regeneration corridors, known collectively as the Growth Network and set out in Policy CSP1, and to see more limited growth outside the Growth Network and reflected in Policy CSP2. It is therefore agreed that such overarching policies should be retained and updated to reflect new evidence.

Considering the requirements for new housing and employment land, it is welcomed that the Issues and Options Report acknowledges that Policy CSP2 will be amended and subject to significant change in order to accommodate housing and employment land and to reflect proposed changes to the Black Country Green Belt. As stated in response to Question 1, all reasonable options should be considered and therefore fully exploring development options outside the existing Growth network, both Green Belt and non -Green Belt, is essential.

Reviewing the Spatial Strategy

Stage 1: Strategic Options 1A and 1B - continuing the role of the Growth Network

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?

The Council supports the Black Country authorities in re-examining the boundaries of the regeneration corridors to explore whether this could result in additional sites for housing and/or employment land.

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?

Whilst there may be scope for the release of some occupied employment land for housing in certain locations in the Growth Network (Strategic Option 1B), the loss of employment land would need to be offset in the Green Belt and therefore this option is unlikely to reduce the loss of Green Belt overall. It is also acknowledged that there are likely to be delivery and viability issues around Option 1B. On this basis, the bulk of the remaining housing and employment needs are likely to need to be met outside the Growth Network (Strategic Option 1A). However, before this is concluded, the authorities will need to demonstrate that there are no other deliverable sources of supply (e.g. estate regeneration) within the Growth Network.

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.

No comment.

Stage 2: Strategic Options 2A and 2B - Housing and Employment outside the urban area

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.

It is noted that both options outside the Growth Network (Strategic Option 2A and 2B) would involve Green Belt release. As stated in response to questions 1 and 16, all reasonable non-Green Belt options should be explored, and therefore the authorities will need to demonstrate that there are no other deliverable sources of supply (e.g. estate regeneration and increasing development density) within the urban area outside of the identified Growth Network. Once this has been demonstrated, it is considered that exploring a combination of Spatial Options H1 and H2 will need to be explored.

As Spatial Option H1 would see the 'rounding off' the edge of the Green Belt, including internal Green Belt wedges, it is envisaged that this will see the release of a number of small to medium sized sites. Considering the upfront infrastructure delivery for Sustainable Urban Extensions (SUEs) (Option H2) it is considered that from a delivery perspective, a number of these smaller 'rounding off' sites will need to come forward to ensure housing is being delivered over the short term (0-5 year period). The Issues and Options report confirms that this 'rounding off' option may not yield sufficient capacity to accommodate all the growth needs, and if this is the case, then a combination of 'rounding off' sites, as well as SUEs, are likely to be required to meet the growth requirements.

In terms of what criteria should be used to select such sites, this must be evidence led. Of particular importance will be the outcomes of the Strategic Growth Study and Black County Green Belt Review in terms of the contribution that these site play to the Green Belt. A Landscape Sensitivity Study will also be a key piece of evidence for determining the degree of landscape sensitivity, to ensure that areas of very high sensitivity remain undeveloped where possible. Access to services and facilities will need to be considered, however these sites by their nature will adjoin the urban area, and therefore in most cases there is likely to be adequate access to amenities. It is not considered that a size threshold should be imposed on these 'rounding off' sites; however sites should follow defensible boundaries, such as existing roads, watercourses and hedgerows where possible.

An important consideration when considering options for growth will also be the Cannock Chase SAC. The Council welcomes the continued involvement of the relevant Black Country authorities in the Cannock Chase SAC Partnership through the Core Strategy Review process. Any development proposals in the Core Strategy Review need to come forward in accordance with the most up to date evidence to ensure that development does not have an adverse impacts on European protected sites.

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).

To reiterate, it is important that site selection is evidence led, and therefore crucially, it is essential that all sites/areas with 'rounding off' potential are considered. This includes areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken. Where necessary, land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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.

As set out in response to Question 12a, there is likely to be a requirement to allocate SUEs to meet the identified growth requirements in addition to smaller 'rounding off' sites. However, it is unclear if this option includes options for new standalone settlements in the Green Belt, or will just focus on SUEs that adjoin the urban area. It is suggested that, considering the scale of the housing and employment requirements, new standalone settlements could be considered at this early stage of plan preparation under this option.

It is considered that any SUE would need to provide a mix of house sizes and specialist housing (for example for the elderly) where there is evidence of need, and an appropriate level of affordable housing. The Council also believes there are options for new employment land to be allocated within SUEs. In particular there may be scope for modern industrial units aimed at SME businesses offering supply chain opportunities to serve established businesses in the area. Clearly sustainable development principles should be followed with good access to amenities, public transport, employment opportunities, sport and recreation and other green infrastructure.

An important consideration when considering options for growth will also be the Cannock Chase SAC. The Council welcomes the continued involvement of the relevant Black Country authorities in the Cannock Chase SAC Partnership through the Core Strategy Review process. Any development proposals in the Core Strategy Review need to come forward in accordance with the most up to date evidence to ensure that development does not have an adverse impacts on European protected sites.

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

It is suggested that SUEs would typically need to be in excess of 750 houses to facilitate a primary school and it is likely that developments would need to be larger than this (in excess of 1000) to provide a local centre. A self-contained development is likely to be in excess of 2000 -2500 homes; with 5000 homes the typical threshold to facilitate a new high school.

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?

It is important that site selection is evidence led, and therefore it is essential that all sites/areas with potential to accommodate an SUE are considered. This includes areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken; for example the Strategic Growth Study, any further fine grain Green Belt assessment, Landscape Sensitivity Study and market capacity evidence. Where necessary, land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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?

The Council supports the Core Strategy setting out detailed guidance and broad parameters for design and layout of SUEs, including the type of tenure of housing, employment land requirements, infrastructure and service provision and open space requirements etc. It may be that these requirements are set out in a proforma for each proposed SUE, which then hooks to the relevant SUE allocation policy.

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

As set out in previous responses, if Green Belt release is proposed then the authorities will need to demonstrate that all reasonable non-Green Belt alternatives have been considered. This should include exploring funding opportunities to deliver constrained brownfield sites, increasing site densities within the urban area and exploring any opportunities for estate regeneration.

As set out in response to Question 13a, at this early stage of plan preparation, Spatial Option 2a should consider options for new standalone settlement as well as SUEs that adjoin the urban area.

Meeting housing needs outside the Black Country

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?

If it is clearly demonstrated that housing need cannot be met within the Black Country by carrying out a robust and transparent assessment of all non-Green Belt and Green Belt options, then it is acknowledged that some of this housing growth will need to be exported to other authorities within the Greater Birmingham HMA. This could potentially be to neighbouring HMAs should it be robustly demonstrated that the shortfall cannot be met within the Greater Birmingham HMA. The Strategic Growth Study will provide an indication of where opportunities may exist outside the Black Country and these opportunities could then be explored further by the relevant authority through local evidence gathering.

It is clear that there are significant pressures for new housing, employment and Gypsy & Traveller provision and these key cross boundary issues will need to be addressed through our respective local plans. It is the Council's firm view that this is a two-way negotiation and the role that South Staffordshire might play in this regard needs to be very carefully explored. An equitable and fair approach, which recognises the environmental, physical and infrastructure constraints, as well as the availability of sites to meet specific needs, should be robustly evidenced when addressing these issues under the Duty to Cooperate.


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

Potential locations outside the Black Country, similar to considering options for 'rounding off/SUEs within the Black Country, should be evidence led. Therefore, this could include areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken; for example the Strategic Growth Study, any further fine grain Green Belt assessment, Landscape Sensitivity Study and market capacity evidence. Where necessary land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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.

Whether development is delivered within the Black Country or is exported elsewhere it will need to comprise sustainable development that meets the needs of the people who live there. If housing is exported, it will be for the LPA(s) in question to allocate sites through their Local Plan alongside appropriate infrastructure having undertaken a Sustainability Appraisal to ensure that sustainable development is being achieved.

Strategic Option Area 2B - accommodating employment land growth outside the urban area

Question 16 - Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E1 of extending the Black Country's existing employment sites on the edge of the urban area into Green Belt land where it is demonstrated that there is insufficient options for employment land within the urban area. It is considered that there is a need for a mix of employment sites, both in terms of use class, size and quality. Overall, it is likely that the authorities will need to provide a range of employment land from sites aimed at large advanced manufacturing companies, through to small scale modern fit for purpose industrial units aimed at existing SMEs and start-up businesses.

In most instances, good access to the strategic road network is a key criterion, particularly for logistics companies, however for more local quality manufacturing this may be less of a factor. Access to labour markets, including accessibility to employment via public transport is also seen as key site selection criteria.

Question 17 - Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E2 of providing new freestanding employment sites in sustainable locations in the Black Country's Green Belt where it is demonstrated that there is insufficient options for employment land within the Black Country urban area. New freestanding employment sites are more likely to be aimed at larger advanced manufacturing and/or distribution companies and therefore good access to the strategic road network is seen as key. Again, access to labour markets, including accessibility to employment via public transport is also seen as key site selection criteria.

Question 18 - Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E3 of providing new employment land within Sustainable Urban Extensions (SUEs) in the Green Belt where it is demonstrated that there is insufficient options for employment land within the urban area. In particular, there may be opportunities within SUEs to provide modern industrial units on new business parks as part of a sustainable mixed use development. These are more likely to be aimed at existing SMEs and start-up businesses.

Question 19a - Do you support Spatial Option E4? Yes/No; Any further comments?

The Council acknowledges that alongside the other three spatial options, there may be a requirement to export employment growth to neighbouring areas. It is acknowledged that South Staffordshire has strong economic links with the Black Country as demonstrated by the fact that our emerging Site Allocations will provide an additional 62ha of employment land to meet Black Country needs.

The Black Country EDNA concludes that South Staffordshire and Birmingham are the areas with the strongest economic links to the Black Country, but acknowledges that there are also links with other adjoining areas e.g. Lichfield, Cannock and Bromsgrove. Clearly, the employment land requirements for the Black Country are significant, reflecting the growth aspirations of the Black Country and wider West Midlands Combined Authority. Considering the scale of the need, if it is demonstrated that Spatial Option E4 is an appropriate option, then options to export to all neighbouring authorities with an economic relationship to the Black Country should be considered under this option.

Question 19b - Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country)

It is agreed that good access to the strategic road network with good sustainable public transport links are important factors if the export option was to provide large scale freestanding employment site(s). Further, consideration should also be given to which communities in the Black Country the sites will serve. Clearly, sites on the northern edge of the Black Country are less likely to serve residents in Dudley and Sandwell and vice versa. Therefore, if employment sites are provided outside the Black Country then this should be done in a way that avoids the overconcentration of sites in one area.

Question 20 - Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.

No other options are suggested at this stage. It may be the case that a combination of all options is needed to meet the Black Country employment requirements. As set out above, assuming that the export option is required, all neighbouring authorities with an economic relationship to the Black Country should be considered under Spatial Option E4.

Delivering Growth - Infrastructure and Viability
Introduction and scope

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.

It is agreed that the policy may need to be reconsidered. Where Green Belt release for SUEs/employment land is proposed then it may be that there is a hook in the policy to link to site specific proformas/development briefs for these sites. These could clearly set out what infrastructure is required to be delivered, both on and off site.

Social Infrastructure

Question 22 - Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

We have no evidence with regard to social infrastructure needs in the Black Country.

Question 23 - Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.

We have no evidence with regard to surplus social infrastructure provision in the Black Country.

Question 24- Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.

We have no evidence with regard to social infrastructure needs in the Black Country. However, it is acknowledged that new housing will put pressure on social infrastructure both within the Black Country, and the surrounding local areas and therefore the authorities will need to engage carefully with cross boundary social infrastructure providers to ensure that they understand the 'tipping point' at which new development will facilitate the need for additional social infrastructure provision.

Question 25 - Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.

See response to Question 24.

Physical Infrastructure

Question 26 - Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

We have no evidence at this stage with regard to physical infrastructure needs in the Black Country.

Question 27 - Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
We have no evidence with regard to physical infrastructure needs in the Black Country. However, it is acknowledged that large scale new development (for example SUEs) are likely to require substantial upfront infrastructure provision.

Question 28 - Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?

See response to Question 27.

Delivery and Viability

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.

Clearly infrastructure provision through Section 106 and 278 agreements and CIL will be essential. No other tools or interventions are suggested.

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.

It is considered that in order to maintain the urban regeneration strategy, a brownfield first approach should be explored to its fullest extent. Therefore, all funding options should be explored to try and deliver as many problematic brownfield sites as possible.

Funding for Site Development and Infrastructure

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?

Both private and public sector investment will be needed to deliver the Core Strategy. The availability of funding sources will impact on viability, and therefore robust viability, delivery and infrastructure studies will be needed when determining if the proposed Core Strategy policies are feasible.

Review of Existing Core Strategy Policies and Proposals

Policy Area A - Health and Wellbeing

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

It is agreed that spatial planning and place making does have a key role in improving the health and wellbeing of residents and therefore incorporating a health and wellbeing into the Core Strategy is fully supported.

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?

A number of policy areas, e.g. open space and sports provision, affordable housing delivery tie in with the health and wellbeing agenda and these will be picked up in other Core Strategy policies. There may however be a role for overarching health and wellbeing policy that ties these together to ensure it is clear on how development will be expected to contribute towards healthier communities.

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?

Undertaking a Health Impact Assessment for large developments in addition to considering their impact through the Sustainability Appraisal (SA) is supported.

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?

Applying good practice design principles, including provision of on site open space and links to existing green infrastructure will be essential. It is also important that larger schemes to include facilities for children's play and youth development.

Policy Area B - Creating Sustainable Communities in the Black Country

Policy HOU1 - Housing Land Supply

Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

The proposed approach to housing land supply is supported.

Policy HOU2 - Housing Density, Type and Accessibility

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?

The Council supports the proposal to increase the minimum net density of 35 dwellings per hectare to maximise brownfield housing delivery. Densities should be reconsidered through the emerging viability and delivery evidence and efficient use of land be promoted.

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

The authorities should consider lowering or removing the threshold for applying density standards as in many instances high densities may also be appropriate for small sites of less than 15 dwellings.

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?

The site size threshold could be reduced to less than 11 if there is evidence to suggest that this will not impact on deliverability.

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?

It is important that efficient use of land is encouraged so as to limit Green Belt release as far as possible, particularly given the Housing White Paper's requirement to limit the need for Green Belt release by optimising the proposed density of development. Therefore, where Green Belt release has been shown to be necessary, the minimum net density of any Green Belt release should not be set below the standards for the adjacent urban area.

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.

As locations for residential development will principally focus on sites within the urban area or Green Belt locations on the edge of the urban fringe, it is considered that none of these locations will be isolated with fundamental accessibility concerns. Therefore, separate accessibility standards for different types of development are not considered necessary. With regard to affordable housing, this should be provided on site where possible.

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.

Yes.

Question 41a - 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:

Yes.

Question 41b - A target for each authority? Yes/No; Any further comments

Considering the low numbers on the register currently (nine for the entire Black Country), It may be most appropriate to set a target for each authority, rather than a percentage requirement for each large development coming forward. One potential approach could be to extrapolate need evidenced from the base periods to date, in order to determine how many plots each authority should be providing over the plan period.

Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?

See response to Question 41b.

Question 41d - Another approach altogether? Yes/No; If yes, please specify.

See response to Question 41b.

Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.

No comment.

Policy HOU3 - Affordable Housing

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.

It is agreed that the annual affordable housing target should be directly informed by the 2017 SHMA.

Question 43a - 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.

It is agreed that the threshold requiring sites to provide a proportion of affordable housing set out in Policy HOU3 should be lowered to 11 homes or more in line with Government guidance.

Question 43b - If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?

See response to question 43a.

Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?

A requirement for 25% affordable housing seems reasonable considering the viability constraints that may be associated with some sites. This is also in line with the requirement identified in the SHMA.

Question 44b 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?

It may not be necessary to increase the affordable housing percentage requirement in order to increase the provision of affordable home ownership now that the Housing White paper appears to have removed the specific requirement to deliver starter homes (20%) on all sites over a certain threshold. The 10% requirement for affordable home ownership products can be met within the proposed 25% affordable housing policy. The split within this between shared ownership, starter homes and other types of affordable home ownership could then be dealt with by negotiation, considering the comments in 6.37 which note that most starter homes in the Black Country would not necessarily be genuinely affordable in all areas. This would also still leave a 15% requirement for rented products, which is only marginally below the 16.6% recommended in the SHMA.

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.

The SHMA confirms that the Black Country authorities should aim for 28.6% (23.3% if starter homes are excluded) of new housing to be affordable housing; therefore on this basis there may be limited scope to go above 25% on greenfield sites. However, considering that these could be large sites that would need substantial onsite infrastructure provision then a cautious approach should be taken to going above 25%. Setting an appropriate percentage should be directly informed by a high level viability study.

Policy HOU4 - Accommodation for Gypsies, Travellers and Travelling Showpeople

Question 46 - Do you agree with the proposed new gypsy, traveller and travelling showpeople accommodation targets? Yes/No; If no, please explain why.

The targets set out in Tables 4 and 5 are taken from the Black Country and South Staffordshire GTAA 2017 and therefore are deemed appropriate for identifying the Black Country's pitch/plot requirements. However, as you are aware the 2017 GTAA identified a pitch requirement of 87 residential pitches for South Staffordshire for the period 2016-2036, considerably above the pitch requirements for the four Black Country authorities combined. Historically, pitch provision in South Staffordshire has been in the Green Belt as no non-Green Belt options have ever been promoted. Therefore, assuming that this remains the case, there will be a requirement through our Local Plan review to demonstrate that we have explored other reasonable options to amending Green Belt boundaries including exploring whether other authorities can help to meet some of the identified development requirement, as set out in the Housing White Paper. As such, there will be a requirement through Duty to Co-operate discussions to explore whether there may be deliverable brownfield options in the Black Country to meet a proportion of the districts pitch requirements. On this basis, a flexible approach to setting pitch targets and exploring pitch/plot options is suggested.

It is clear that there are significant pressures for new housing, employment and Gypsy & Traveller provision and these key cross boundary issues will need to be addressed through our respective local plans. It is the Council's firm view that this is a two-way negotiation and the role that South Staffordshire might play in this regard needs to be very carefully explored. An equitable and fair approach, which recognises the environmental, physical and infrastructure constraints, as well as the availability of sites to meet specific needs, should be robustly evidenced when addressing these issues under the Duty to Cooperate.


Policy HOU5 - Education and Health Care Facilities

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.

Expanding Policy HOU5 to include a criteria based approach which requires service providers to demonstrate why health care and education facilities are no longer required or viable is welcomed. It is agreed that this approach should be expanded to other types of social infrastructure such as community centres.

Including standards for built social infrastructure to serve major housing developments set out in Policy HOU5 is also considered appropriate.

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.

This policy should be reviewed to reflect a clear criteria based approach to considering the loss of social infrastructure, and should be expanded beyond health and educational facilities where appropriate. One of these criteria could relate to ensuring that the developer demonstrates that there is adequate alternative provision to meet the needs of the community.

Policy Area C - The Black Country Economy

Policy DEL2 - Managing the Balance between Employment Land and Housing

Question 49a - 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.

The existing wording for Policy DEL2 seems very broad, setting out completions to date and how many are expected to come forward within each regeneration corridor. A clearer approach may be to specifically identify areas of Local Quality Employment Land that is considered poor quality and therefore suitable for release for housing, either through a revised Core Strategy policy or through allocation documents.

Question 49b - 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.

A revised policy could set out areas of poor quality employment land that could be suitable for release for housing or alternative uses, providing clarify on what uses may be acceptable.

Policy EMP1 - Providing for Economic Growth and Jobs

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.

It is considered that the authorities themselves are best placed to decide if there is any value in setting a target for the total employment stock within the Black Country. Setting a target for the additional employment land that is required is a clearer approach; however if possible, there may be a need to have a mechanism in place to ensure that any loss of existing high quality sites to other uses is compensated by new provision reflected in updated targets. Robust monitoring and national guidance encouraging authorities to review plans in whole or part every 5 years should ensure that any issues around the loss of existing high quality employment land can be addressed.

Policy EMP2 - Strategic High Quality Employment Land and Policy EMP3 - Local Quality Employment 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?

The criteria used to define High Quality Employment Areas are supported. There may however be scope to slightly amend the accessibility criteria to focus on good access the strategic road network, rather than just focusing on access to the motorway network.

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?

The criteria used to define High Quality Employment Areas are supported.

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?

The High Quality Employment Areas should be focused on advanced manufacturing and logistics and be protected for these uses.

Policy EMP4 - Maintaining a supply of readily available employment land

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?

Removing the requirement to have a 'reservoir' of readily available shovel ready employment land is supported. The provision to review plans in whole or part every 5 years will help ensure that there is a constant supply of employment land, providing scope to allocate additional employment land if required. Ensuring provision for a balanced portfolio of sites is important

Policy EMP5 - Improving access to the labour market

Question 55 - Do you agree with the proposal to retain Policy EMP5? Yes/No; If no please explain why.

Policy EMP5 encourages the use of planning objections to be negotiated with developers of new job creating development in order to support recruitment and training of local people. This approach is fully supported as access to a skilled workforce is a key consideration for businesses.

Policy EMP6 - Cultural Facilities and the Visitor Economy

Question 56 - Do you agree with the proposal to update Policy EMP6 in line with current priorities? Yes/No; If no, please explain why

Updating the list of visitor attractions and facilities in Policy EMP6, which seeks to develop the visitor economy and cultural facilities of the Black Country is supported.

Policy Area D - The Black Country Centres

Policy CEN1: The Importance of the Black Country Centres for the Regeneration Strategy

Question 57 - Do you support the proposal to merge Policy CEN1 and Policy CEN2, given that both policies focus on the overall strategy in the Black Country, including the hierarchy of centres? Yes/No; if you have any comments on Policies CEN1 and CEN2 please provide details.

Merging these policies relating to the town centres seems logical.

Question 58 - Do you think there is any evidence to suggest that the hierarchy of centres is not appropriate going forward in the context of the regeneration strategy? Yes/No; If so, please provide details.

The Council has no evidence to suggest that the hierarchy of centres is not appropriate. However, the Retail Capacity and Town Centre Uses studies should be used to inform the hierarchy. It is recognised that a number of the Black Country centres - particularly the strategic centres - play an important role in meeting the higher order needs of our residents including access to hospitals, retail and leisure. Therefore, their continuing regeneration is fully supported.

Question 59 - Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.

From the Council's knowledge, It appears that all the appropriate centres within the Black Country have been identified.

Question 60 - Is there evidence to suggest that identified centres are no longer performing as a centre or at their identified level in the hierarchy? Yes/No; If yes, do you agree that they should be moved / removed within or out of the hierarchy? Please explain why.

We have no evidence on the performance of centres or relating to their level within the hierarchy of centres.

Question 61 - In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?

As an indicative rule, development of around 1000 houses or more are likely to require a new centre. Therefore, if the evidence suggests a need for new developments around this scale then clear criteria for the creation of new centres will be required. It may however be appropriate to have site specific infrastructure requirements for large strategic allocations (e.g SUEs) identified in the Core Strategy. These would include the requirements for new centres.

Policy CEN3: Growth in the Strategic Centres

Question 62 - Do you agree that the Strategic Centres should remain the focus for large scale comparison retail (clothes, white goods etc), office and major commercial leisure development in the Black Country? Yes/No; Any further comments?

It is logical for the existing strategic centres such as Wolverhampton and Brierley Hill to be the focus for retail, office and commercial leisure development. This is important for their continuing regeneration.

Question 63 - Do you agree that the targets for comparison retail floorspace and office floorspace should be revisited as part of this review to take into account current and future trends? Yes/No; Any further comments?

It is agreed that retail and office floorspace needs should be revisited.

Question 64 - Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?

We have no evidence to confirm if there is a need to set a target for convenience retail floorspace. The proposed Retail Capacity and Town Centre Uses studies should be used to inform this.

Question 65 - Should the Core Strategy set any targets or policy requirements for leisure development in the Strategic Centres? Yes/No; Any further comments?

Targets for leisure development may be appropriate where supported by evidence of need. It may be appropriate to undertake an audit of sports facilities as part of this evidence gathering and consider cross boundary provision dependent on the evidence of need/demand. If this is deemed appropriate then close liaison with Sports England is recommended.

Question 66 - Should the Core Strategy set new housing targets for the Strategic Centres through the review? Yes/No; Any further comments?

The authorities will need to demonstrate that they have fully considered options for additional housing in the strategic centres, whilst recognising that other uses such as retail will also be the focus of these centres. The Council supports the authorities setting new housing targets for the strategic centres.

Question 67 - Do you think there are any other uses and/or developments that should be planned for in the Strategic Centres? Yes/No; Please provide details.

Retail, offices, housing, leisure and cultural facilities should be the focus of the strategic centres.

Brierley Hill Retail Pre-Conditions

Question 68 - Do you agree with the proposal to re-examine the detail and appropriateness of the existing conditions for retail growth at Merry Hill through the Core Strategy review? Yes/No; Do you have any further comment to make on this issue?

The Core Strategy review is considered the correct time to re-examine any conditions relating to retail growth at Merry Hill.

Policy CEN4: Regeneration of Town Centres

Question 69 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country Town Centres? Yes / No; Please explain why.

It is considered appropriate to encourage convenience shopping and other mixed use development (e.g. community centres) to support new residential development within the strategic centres.

Question 70 - Do you think there are any specific developments or uses that should be supported in any particular Town Centre? Yes/No; Please provide details.

No specific suggestions.

Question 71 - Should the Core Strategy set housing targets for the Town Centres? Yes/No; Please explain why.

Policy CEN5: District and Local Centres

The authorities will need to demonstrate that they have fully considered options for additional housing in the strategic centres, whilst recognising that other uses such as retail will also be the focus of these centres. The Council supports the authorities setting new housing targets for the town centres.

Question 72 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country District and Local Centres? Yes/No; Please explain why.

Flexibility of uses is encouraged in the Local Centres.

Question 73 - Are there are any specific developments or uses that should be supported in any particular District or Local Centre? Yes/No; Please provide details.

No specific suggestions.

The Centres Threshold Approach

Question 74 - In the context of the 'centres first' strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of Strategic, Town, District and Local Centres? Yes/No; Please explain why.

No comment.

Question 75 - Should thresholds apply to all main town centre uses (Yes) or just retail uses (No)? Please explain why.

No comment.

Policy CEN6: Meeting Local Needs for Shopping and Services

Question 76 - Is the approach set out in Policy CEN6 appropriate in the context of supporting local community needs? Yes/No; Please explain why.

The approach of protecting local shops and small parades unless it can be demonstrated that they are no longer viable is supported. The authorities may want to consider setting out clear expectations on what evidence would be required to justify the applicants viability case.

Question 77 - Does the wording of the criteria clearly achieve the objectives of the centres strategy? Yes/No; Please explain why.

No comment

Question 78 - Should the policy clarify that this policy applies both to applications in edge-of-centre and out-of-centre locations, and should this also be referred to in the relevant centres policies? Yes/No; Please explain why.

Clarification that the policy applies to edge-of-centre and out-of-centre locations is supported

Question 79 - Should the policy set what types of uses this policy applies to and set out any further types of material considerations that could be relevant for the determination of certain proposals, for example, the location or concentration of hot food takeaways, premises selling alcohol or gambling operations? Yes/No; Please explain why

No comment

Question 80 - Should the policy clarify that those schemes of multiple units, where individual units are below the set figure, but the cumulative figure is above, also need to meet the relevant requirements of other centres policies? Yes/No; Please explain why

No comment.

Policy CEN7: Controlling Out-of-Centre Development

Question 81 - Do you agree that the approach of strong control over out-of-centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Country Centres? Yes/No; Please explain why.

This approach seems appropriate.

Question 82 - Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.

No comment.

Policy CEN8: Car Parking in Centres

Question 83 - Should Policy CEN7 provide more guidance on accessibility? Yes/No; If yes, please explain why.

No comment.

Question 84- Do you think that Policy CEN8 is still appropriate for managing car parking in centres and will ensure the network of Black Country Centres are maintained and enhanced over the plan period? Yes/No; Please explain why.

No comment.

Question 85 - Should Policy CEN8, with regards to pricing of car parks, continue to be applied to Strategic Centres to ensure that pricing of parking is not used as a tool of competition? Yes/No; Please explain why.

No comment.

Other Centres Issues

Question 86 - Do you think that there are other centre uses or centres issues that need to be addressed in the centres policies? Yes/No; Please provide details.

No specific suggestions.

Question 87 - As shopping, leisure and other commercial trends continue to change, should the revised Core Strategy have a policy to reallocate out-of-centre attractions that are no longer viable for town centre uses for alternative uses such as for employment uses or housing? Yes/No; If no, please explain.

As retail trends continue to change with the continued expansion of online shopping it is essential that Local Plan policies on centres strike the correct balance between ensuring that town centres uses cannot be too easily lost, whilst also ensuring there is flexibility to adapt to changing retail trends. Where retail, leisure or other commercial uses are not viable then reallocating these for housing or employment uses would be supported.

Policy Area E - The Black Country Transport Network

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

The overall transport strategy of providing better use of existing capacity as well as providing new sustainable transport capacity to provide an integrated transport system for the West Midlands is supported. Achieving this will help support the Core Strategy Spatial Objectives.

Policy TRAN1 - Priorities for the Development of the Transport Network

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

The updated transport priorities in TRAN1 are generally supported. However, reference of 'development of road to freight interchange facilities to serve the sub region' is vague. It is unclear if this is making specific reference to the development of a Strategic Rail Freight Interchange (SRFI), which by the Governments definition is an Interchange in excess of 60ha and capable of handling 4 trains a day, or a number of smaller RFI facilities within the Black Country. That said, Paragraph 6.1.40 of the Issues and Options makes specific reference to rail freight interchanges proposals coming forward at Bescot and Four Ashes (currently being promoted as West Midlands Interchange (WMI)) which suggests that the transport priority relating to rail freight at Para 6.1.36 may relate specifically to Four Ashes. As you are aware, the WMI proposal is in the Green Belt and is still at the pre-application stage and therefore any transport priorities that relate to this proposal are considered premature.

Policy TRAN2 - Managing Transport Impacts of New Development

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

Proposed changes to reference greater focus on choice of modes of transport for access to new developments, including electric vehicle charging infrastructure, provision for cycles etc. is supported.

Policy TRAN3 - The Efficient Movement of Freight

Question 91 - Do you support the proposed changes relating to the efficient movement of freight? Yes/No; If no, please explain why.

The proposed change to Policy TRAN3 is to remove reference to the 'principle road network' to be replaced with reference to the 'key route network' which is defined in the West Midlands Combined Authority 'movement for growth' plan. It is our understanding that the 'key route network' is a term used to describe the metropolitan main road network. The current reference in the policy is as follows:

Proposals which generate significant freight movements will be directed to sites with satisfactory access to the principal road network.

It is unclear from the Issues and Options report if this change is simply to provide consistent terminology with that used in the WMCA transport plan, or if this will result in a material change to the policy. Specifically, it is unclear if the reference to the principal road network was referring specifically to the road network within the Black Country? Whereas the 'key route network' seems to refer to a wider area across the region. Clarification on this would be welcomed.

Policy TRAN4 - Creating Coherent Networks for Cycling and Walking

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

The approach of providing a coherent network for walking and cycling is supported.

Policy TRAN5 - Influencing the Demand for Travel and Travel Choices

Question 93 - Do you support the proposed changes to Policy TRAN5? Yes/No; Please explain why.

The proposed inclusion of priorities in Policy TRAN5 around introducing new transport technologies such as ultra low emission vehicles is supported.

Policy Area F - The Black Country Environment

Environmental Infrastructure and Place-Making

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.

The proposed changes to environmental policies to reflect adopted DPDs and include new proposals to address the environmental infrastructure needs of new developments in light of up-to-date evidence seems appropriate.

Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?

Good plan making objectives such as providing comprehensive green infrastructure, integrated and accessible transport networks, access to employment and affordable housing provision are amongst those that make up the garden city principles. These requirements will be picked up through applying the relevant individual policies.

Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

The may be more scope to apply the garden city principles on larger greenfield sites. Considering that there may be viability issues on some brownfield sites, it may be less realistic to apply the garden principles on these sites.

Policy ENV1 - Nature Conservation

Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?

Updating the policy in line with the NPPF and the introduction of requirements for new development to incorporate biodiversity features, such as new natural green space, is supported.

Policy ENV2 - Historic Character and Local Distinctiveness

Question 97 - Do you support the proposed changes relating to Historic Character and Local Distinctiveness? Yes/No; If no, please provide details of any other changes that should be made to Policy ENV2.

Updating the policy in line with the latest national policy and guidance is supported.

Policy ENV3 - Design Quality

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.

Removing reference to requiring a specific code of sustainable home in line with national guidance is supported.

Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

This is considered for the authorities to decide in consultation with the water companies.

Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Introducing an access standard so that a percentage of new builds would be usable or easily adaptable for those with disabilities is supported. However, in terms of the threshold of where this percentage is set, this would need to informed by viability evidence. It may be that it would not be viable to apply this policy on certain types of sites e.g. small brownfield sites; again this could be considered in the viability evidence.

Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Applying the Nationally Described Space standard (CLG, March 2015) is supported should the evidence suggest that this would not impact on viability.

Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

It may be appropriate to have different standards for brownfield and greenfield; this could be considered in the viability evidence.

Policy ENV4 - Canals

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.

It is understood that part of the route of the Hatherton Branch Canal is safeguarded in proposed Policy EN4 of Walsall's Site Allocations Document. On this basis it is considered appropriate to remove reference to the restoration of the Hatherton Branch Canal from the Core Strategy, and for this to be considered at the more local level.

Policy ENV5 - Flood Risk, Sustainable Drainage (SuDS) and Urban Heat Island Effects

Question 101a - Do you support the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects? Yes/No; Further comments?

The propose changes to align with national policy and guidance is supported.

Question 101b - Do you think that any other changes should be made to Policy ENV5? Yes/No; If yes, please provide details.

None suggested.

Policy ENV6 - Open Space, Sport and Recreation

Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain

It is not clear what specific changes are proposed, however if the existing policy is in line with national policy then it may be that the changes needed are minimal.

Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No; If no, please explain

It is considered that paragraph 74 of the NPPF offers sufficient protection from development for open space.

Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes should be made. Yes/No; If yes, please provide details.

None suggested.

Policy ENV7 - Renewable Energy

Question 103a - Do you think that Policy ENV7 should be changed to allow increased energy efficiency standards to be accepted in lieu of renewable energy provision for non-domestic buildings? Yes/No; If not, please explain

Increased energy efficiency standards for non-domestic buildings would be supported; however this would need to be supported by plan viability evidence confirming that this is achievable.

Question 103b - Do you think that the 10% requirement should be changed? Yes/No; If yes, please specify what percentage would be more appropriate and to what type of site it should apply.

Any percentage requirement relating to energy demand would again need to be supported by plan viability work.

Policy ENV8 - Air Quality

Question 104 - Do you support the proposed changes relating to Air Quality? Yes/No; If you think that any other changes should be made to Policy ENV8 please provide details.

Rewording the policy to reflect the approach in the more recent Black Country wide SPD on Air Quality and the West Midlands Low Emissions Towns and Cities Programme (WMLETCP) seems appropriate.

Policy Area G - Waste

Question 105 - Do you think that Policy WM1 identifies all of the key waste issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/No; If not, please specify what changes should be made to the Policy. If you have any evidence that can be referred to in the Waste Study, please provide details.

No comment.

Question 106a - Do you support the approach set out in Policy WM2? Yes/No; If no, please explain why.

No comment.

Question 106b - Are there any strategic waste management sites that no longer need to be protected? Yes/No; If yes, please provide details

No comment.

Question 106c - Are there any new sites that do need to be protected? Yes/No; If yes, please provide details.

None suggested.

Question 107 - Do you think that there are any strategic waste management proposals that should either be removed from or added to the list in Policy WM3? Yes/No; If so, please provide details.

No comment.

Question 108 - Do you agree that Policy WM4 provides an appropriate level of control over the location and design of new waste management facilities? Yes/No; If no, what changes do you think should be made to the Policy?

No comment.

Policy Area H - Minerals

Question 109 - Do you agree that Policy WM5 provides an appropriate level of control over resource management for new developments? Yes/No; If no, what changes do you think should be made to the Policy?

No comment.

Question 110 - Do you think that Policy MIN1 identifies all of the key minerals issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/no; If no, what changes should be made to the policy?

No comment.

Question 111 - Do you agree with the proposed change to 'prior extraction' requirements, to maintain a size threshold in urban areas and increase the threshold for green belt sites to 3 ha? Yes/No; If no, what evidence do you have to justify an alternative approach?

No comment.

Question 112a - Are there any key mineral related infrastructure sites that no longer need to be protected? Yes/No; Please provide details

No comment.

Question 112b - Are there any other sites that do need to be protected? Yes/No; If yes, please provide details.

No comment.

Question 113 - Do you think that Policy MIN2 identifies all of the key aggregate minerals issues that need to be addressed in the Core Strategy up to 2036, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

No comment.

Question 114 - Do you have evidence of workable, viable deposits of brick clays outside the areas of search, which could justify defining new areas of search? Yes/No; If yes, please provide details.

No.

Question 115a - Do you have evidence of any realistic possibility of fracking in the Black Country? Yes/No; If yes, please provide details.

No.

Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No; If yes, please provide details.

No comment.

Question 116 - Do you think that Policy MIN5 identifies all of the key issues that need to be addressed in relation to new mineral developments in the Core Strategy, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

No comment.

Policy Area J - Growth Network Detailed Proposals

Question 117 - Do you agree with the proposed approach to updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy? Yes/No; If not, what alternative approach would you suggest?

Updating Appendix 2 and tables 2 and 3 of the existing Core Strategy to reflect proposals in the adopted and merging SADs and AAPs is supported.

Policy Area K - Monitoring and Additional Policies

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

Streamlining the monitoring framework to focus on the key quantitative indicators which relate to the delivery of development is supported.

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.

If the authorities are required to allocate Green Belt sites then a new policy for this will be needed. It is likely that a proforma will be needed for each allocation setting out what will need to be delivered on site that hooks to the policy.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1435

Received: 08/09/2017

Respondent: Home Builders Federation Ltd

Representation Summary:

The HBF is less supportive of a housing mix approach whereby a requirement to provide a proportion of self / custom build plots is imposed on sites above a certain size. Such a policy approach only changes the house building delivery mechanism from one form of house building company to another without any consequential additional contribution to boosting housing supply. If these self-build plots are not developed in a timely manner or remain undeveloped then the Councils have effectively caused an unnecessary delay to the delivery of these homes or removed them from the HLS. Therefore appropriate release mechanisms are essential. The Councils should also give detailed consideration to the practicalities (for example health & safety implications, working hours, length of build programme, etc.) of implementing any such housing mix policy approach. It is considered inappropriate for large sites to provide serviced plots.

Full text:

Introduction
Thank you for consulting with the Home Builders Federation (HBF) on the above mentioned consultation. The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which includes multi-national PLC's, regional developers and small, local builders. In any one year, our members account for over 80% of all new "for sale" market housing built in England and Wales as well as a large proportion of newly built affordable housing. We would like to submit the following responses to specific questions in the Councils consultation document.
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?
The Councils should undertake a comprehensive review of the Black Country Core Strategy (adopted in 2011) because the adopted Core Strategy and its evidence base pre-date the requirements of the National Planning Policy Framework (NPPF). It may be that a wholescale review rather than partial review is necessary. The Councils should test whether or not future development needs of a growing population and economy can be met in full by merely "stretching" the existing spatial strategy. The Councils should also consider the implications of unmet housing needs across the wider Greater Birmingham & Black Country Housing Market Area (HMA) in particular from Birmingham city (circa 38,000 dwellings by 2031) as well as the Black Country unmet need of circa 22,000 by 2036. Whilst the focus on urban regeneration may remain it will not be possible to accommodate all future development needs within the urban area therefore a comprehensive review of the Green Belt will be necessary. It is expected that the Black Country Core Strategy

Review Preferred Spatial Option consultation in September 2018 will take into consideration the conclusions of the Greater Birmingham & Black Country Strategic Growth Study which on its publication (anticipated in October / November 2017) may have profound implications for the Black Country Core Strategy Review and whether or not a full or partial review is necessary. Although a two tiered Development Plan Document format is a reasonable proposal it is expected that strategic allocations will be made in the Core Strategy Review together with the setting of targets for individual authority Local Plans. The spatial objectives and strategy as well as policies should be reviewed. Some existing Core Strategy policies are now out of date and these should be superseded. The brownfield first approach is inconsistent with national policy which should not be retained in its existing form. The Councils should be encouraging the re-use of previously developed land (PDL) by maximising its re-use but should not be prioritising brownfield first. PDL is a finite resource a spatial strategy overly focussed on PDL is a high risk strategy as experienced by past delivery where no as much surplus employment land was suitable for housing development as anticipated because since 2011 the economy strengthened and local firms were more robust then envisaged and sites were more constrained than expected.
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?
It is agreed that previously used evidence is old and out of date. The Core Strategy Review should be prepared using new up to date evidence. The key evidence outlined in Table 1 is a reasonable list of evidence. It is important that there is commonality between timeframes of key evidence and the proposed plan period of 2014 - 2036. Furthermore evidence on compliance with the Duty to Co-operate should be included as key evidence.
Question 3 : Do you agree that the housing need identified in the Black Country over the period 2014 - 2036 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?
The key issue is that the Black Country Core Strategy Review makes provision for the meeting in full of the housing needs of the sub region. The Councils should also have due regard to the proposals in the Housing White Paper for a standard methodology for Objectively Assessed Housing Needs (OAHN) calculation and the housing delivery test. The DCLG Planning Update Newsletter dated 31st July 2017 confirms that if a Plan is submitted for examination on or before 31st March 2018 the Plan may progress using the existing methodology for OAHN as set out in current guidance. However if that Plan is withdrawn from examination or found unsound the new Local Plan would be prepared using the standardised methodology.
The OAHN for the Black Country of 78,190 dwellings (including a notional figure of 3,000 dwellings for unmet needs between 2011 - 2014) for the plan period 2014 - 2036 is set out in the Black Country & South Staffordshire Strategic Housing Market Assessment (SHMA) Final Report dated March 2017 by Peter Brett Associates (PBA) which supersedes the OAHN set out in Greater Birmingham & Solihull Local Enterprise Partnership & Black Country

Local Authorities Strategic Housing Needs Study Stage 3 Report by PBA dated August 2015. The OAHN calculation is based on 2014 SNPP / SNHP with no further adjustments for market signals or economic growth. There is also no proposed uplift to the housing requirement above OAHN to help deliver more affordable housing. It is noted that the OAHN / housing requirement figures have not yet been tested at any Local Plan Examination. Whilst the demographic starting point may be reasonable the lack of adjustments for market signals, economic growth and affordable housing delivery may be contested at Examination. Furthermore the OAHN calculation is likely to be re-worked in line with the Government's proposals for a standard methodology before the Black Country Core Strategy Review is examined. The proposed figures also exclude any unmet needs from Birmingham although it is proposed to test a notional figure for the city's unmet needs of 3,000 dwellings. However there is no evidence to justify this proposed notional figure.
The strategic allocations of the Black Country Core Strategy Review together with non-strategic allocations in Local Plans should meet housing needs in full over the plan period. The desire to regenerate brownfield land should be balanced with meeting development needs. The remaining brownfield capacity does not necessarily exist in the locations with highest housing needs and encouraging housing redevelopment should not erode the existing supply of employment sites. Furthermore the restricting of greenfield opportunities will not make unviable brownfield sites become viable. Currently the Black Country is under performing by 3,000 dwellings against the adopted Core Strategy housing target. The residual Housing Land Supply (HLS) figure of circa 21,670 (or 24,670 including notional 3,000 dwellings of unmet need from Birmingham) dwellings should be met from a mixture of HLS including brownfield, greenfield and Green Belt land releases where appropriate. It is also likely that the residual HLS figure is greater than stated by the Councils as the 10,400 dwellings proposed on currently occupied employment land have viability funding gaps which are not yet resolved (see answer to Q10 below).
The Black Country Core Strategy Review should provide a contingency in the overall HLS. The planning in of some additional flexibility is necessary because not all land is developed and Sustainable Urban Extensions (SUEs) are developed over long periods of time often extending beyond plan periods. The development criteria for SUEs should be set out in the Core Strategy Review. The HBF always recommends as large a contingency as possible (circa at least 20%) to the overall HLS to provide sufficient flexibility to respond rapidly to changing circumstances and in acknowledgement that the housing requirement is a minimum not a maximum figure.
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?
Housing and economic strategies should be fully integrated and aligned. There is a large discrepancy between OAHN / housing requirements in adopted and emerging Local Plans and number of homes needed to support

jobs targets such as the West Midlands Combined Authority (WMCA) Strategic Economic Plan (SEP) which by 2030 forecasts 49,000 jobs above the combined existing targets of the 3 Local Enterprise Partnerships (LEPs) SEPs in the West Midlands and potentially generates 48,000 more dwellings compared to previous OAHN calculations. If housing and economic strategies and spatial planning remain un-co-ordinated then economic growth potential will remain unfulfilled.
Question 5 : Do you agree with the proposed approach to the Black Country Green Belt Review?
It is agreed that the formal review of the Green Belt and any subsequent release of sites including the allocation of specific strategic sites for development by 2036 should be part of the Core Strategy Review. The proposed Green Belt Review should be undertaken at a strategic level and used to inform the review of Green Belt boundaries and the "exceptional circumstances" test for Green Belt release as part of the Core Strategy Review. A rolling back of the Green Belt could be pursued so there is no net loss but long term growth is not stifled. It is appropriate to include South Staffordshire.
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?
The key issues are as set out in Part 3 which should be taken into account in the Core Strategy Review.
Question 7 : Do you think that the Core Strategy vision and sustainability principles remain appropriate?
The Core Strategy vision and sustainability principle of "putting brownfield first" is no longer appropriate (also see answer to Q1).
Question 8 : Do you think that the Core Strategy spatial objectives remain appropriate?
The spatial objectives of the Core Strategy should be reviewed in the context of both a growing population and economy and the meeting of these needs in full. As set out in the consultation document Policies CSP1 - CSP5 will be subject to changes.
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?
Policies CSP1 & 2 should be updated to reflect growth proposals beyond the Growth Network.

Question 10 : In continuing to promote growth within the Growth Network is there a need to amend the boundaries of the Growth Corridors in the existing Core Strategy?
The existing boundaries of the Growth Corridors should be amended to promote future growth within the Growth Network. However it is known that many large allocated housing sites within the Growth Network have development constraints and financial assistance will be necessary to bring these sites forward. It is understood that 300 hectares of occupied employment land allocated for housing (10,400 dwellings) in the adopted Core Strategy have viability issues associated with land assembly, business re-location and land remediation which despite external funding from the Black Country LEP and WMCA will remain insufficient to cover costs of compulsory purchase to ensure delivery by 2026.
Question 11A : Do you support Strategic Option 1A? Do you support Strategic option 1B?
The current focus for housing growth is within the urban area however this strategy alone will not meet OAHN in full in the future so development in other locations will also be needed. There are also risks associated with an over reliance on brownfield sites within the urban area (see answer to Q.10 above concerning viability of sites). The artificial constraint of housing on greenfield sites will not ensure delivery of unviable brownfield sites. It should also be acknowledged that the availability of brownfield land will decline over time as it is a finite resource. Therefore it is the HBFs opinion that all options should be considered. The most appropriate solution is likely to be a combination of the continuing promotion of growth within the Growth Networks and Growth Corridors together with Options 1A, 1B, H1 and H2.
A broad portfolio of sites will maximise housing delivery and ensure that the Black Country Core Strategy is positively prepared, justified and effective. Therefore large strategic sites should be complimented with smaller scale non-strategic sites. When allocating sites the widest possible range of sites, by size and market location are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. The maximum delivery is achieved not just because there are more sales outlets but because the widest possible range of products and locations are available to meet the widest possible range of demand. The Housing White Paper also emphasises the importance of a wide range of sites because a good mix of sites provides choice for consumers, allows places to grow in sustainable ways and creates opportunities to diversify the construction sector.
Question 12A : Do you support Strategic Option H1?
See answer to Q11A above.
Question 13A : Do you support Strategic Option H2?

See answer to Q11A above.
Question 14 : Do you think there are any other deliverable and sustainable Housing Spatial Options?
See answer to Q11A above.
Question 15 : 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?
The Black Country Core Strategy Review should fulfil the objectives of the Government's Housing White Paper to plan for the right homes in the right places in particular making enough land available to meet assessed housing requirements. It is the HBF's opinion that housing needs should be met where those needs arises if this is not possible then there should be a bigger than local approach involving cross boundary collaboration throughout the wider HMA so the distribution of housing needs is led by a strategic planning process. The Greater Birmingham & Black Country Strategic Growth Study will be a critical piece of evidence which by identifying potential locations will provide important evidence to inform the land use allocations of each of the 14 constituent HMA authorities when preparing Local Plans including the Black Country Core Strategy Review. The West Midlands Combined Authority's proposal for a Land Delivery Action Plan will also commit its constituent and non-constituent authorities to joint action to accelerate the delivery of housing and employment in order to provide enough homes and jobs for people in all the communities of the West Midlands. This commitment will ensure appropriate provision is made within Greater Birmingham & Black Country HMA to accommodate Birmingham's shortfall of circa 38,000 dwellings to 2031 and unmet needs of 22,000 dwellings to 2036 in the Black Country. It is noted that non-constituent authorities such as Telford & Wrekin which is outside the Greater Birmingham & Black Country HMA will also be bound by this commitment indeed the main modifications to the Telford & Wrekin Local Plan identify the potential to contribute to meeting unmet needs (not yet quantified in evidence).
Question 21 : Do you think changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?
Policy DEL1 should be updated in the Core Strategy Review
Question 34A : Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Options stage of the Core Strategy Review through a Health Impact Assessment approach?
The Councils should be working with public health organisations to understand and improve the health and well-being of the local population (para 171 NPPF). The requirement for Health Impact Assessments should be justified on evidence.

Question 35 : Do you support the approach to HLS?
It is agreed that Policy HOU1 should be updated and based on the latest housing requirement figure. It is also agreed that a re-distribution of development should be included and the proportion of development built on previously developed land will change however the prioritising of brownfield first should not continue (see answers to Q1, Q3 and Q11A above). Any proposed reductions to lapse rates / non-implementation allowances should be justified by evidence. Any inclusion of a windfall allowance in the 5 YHLS calculation should be in the latter years to avoid double counting. The proposal to increase high density housing allocations should be treated with extreme caution (see answer to Q36 below).
Question 36 : Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed?
The Councils have already identified that there is no appetite for high density development so a cautious approach should be applied when considering any proposed changes to density standards.
Any proposed changes to the current accessibility standards should only be undertaken using the criteria set out in the NPPG.
Question 37 : Do you think that existing Policy HOU2 site size threshold should be kept at 15 homes or more?
It is known that site viability in the Black Country is particularly challenging 25% of the HLS is not viable under current market conditions. The Councils viability evidence should be updated as part of the Core Strategy Review. Any proposed change to site size thresholds should only be considered on the basis of updated viability evidence.
Question 38 : Do you think that the current accessibility and density standards are appropriate for green belt release locations?
The application of accessibility and density standards for green belt release sites should be based on evidence.
Question 39 : Do you think separate accessibility standards are needed for particular types of housing?
If the Councils wish to apply accessibility standards these should only be adopted using the criteria set out in the NPPG.
Question 40 : Do you agree that the 2017 SHMA finding should be used to set general house type targets for the plan period?
The setting of any house type targets should not be overly prescriptive. Any such targets should be flexible enough to allow variations over time and for differing local circumstances.

Question 41A : Do you support the introduction of a policy approach towards self and custom build in the Core Strategy?
The HBF is supportive of self-build for its additionality to housing supply. However this is not considered a strategic matter which requires the introduction of a new policy approach in the Core Strategy Review. The existence of only 9 entries on the Councils self / custom build register provides insufficient evidence of need to justify a policy in the Core Strategy Review.
Question 41B : A target for each authority?
No.
Question 41C : A requirement for large housing sites to provide serviced plots?
The HBF is less supportive of a housing mix approach whereby a requirement to provide a proportion of self / custom build plots is imposed on sites above a certain size. Such a policy approach only changes the house building delivery mechanism from one form of house building company to another without any consequential additional contribution to boosting housing supply. If these self-build plots are not developed in a timely manner or remain undeveloped then the Councils have effectively caused an unnecessary delay to the delivery of these homes or removed them from the HLS. Therefore appropriate release mechanisms are essential. The Councils should also give detailed consideration to the practicalities (for example health & safety implications, working hours, length of build programme, etc.) of implementing any such housing mix policy approach. It is considered inappropriate for large sites to provide serviced plots.
Question 41D : Another approach altogether?
The HBF is supportive of a positive development management policy approach to self / custom build planning applications combined with allocation of a proportion of small sized sites, land allocation on Council owned sites and exception sites. Therefore the Councils should encourage self / custom build via the aforementioned approaches.
Question 42 : Do you agree that the annual affordable housing target should be increased to reflect the 2017 SHMA?
The annual affordable housing target should be the most up to figure identified in the Councils latest evidence.
Question 43 : Do you think that existing Policy HOU2 site size threshold should be kept at 15 homes or more?
The site size threshold should be justified by viability evidence. It is unlikely that an alternative threshold of less than 15 dwellings could be justified.

Question 44A : Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site?
The Councils viability evidence should be updated to confirm that 25% remains viable. It is understood that 25% of the HLS is unviable under current market conditions. The Updated viability evidence should include robust testing of PDL, greenfield sites and SUEs. The Councils are reminded that development should not be over-burdened the policy requirement should not be set so high that viability negotiations are undertaken routinely rather than occasionally.
Question 44B : If no should the percentage be increased to allow for the provision of affordable homeownership?
The overall percentage should not be increased. The affordable tenure mix should be flexible to incorporate the provision of affordable homeownership products.
Question 45 : Should an increase in affordable housing requirement be set for green belt release sites to reflect the likely financial viability of these sites?
The setting of affordable housing targets should be based on robust viability testing of all sites including previously developed land and greenfield.
Question 55 : Do you agree with the proposal to retain Policy EMP5?
HBF disagree with the proposal to retain Policy EMP5.
Question 98 : Do you support the proposed changes relating to design quality?
The reference to Code for Sustainable Homes in Policy ENV3 is out of date. Policy ENV3 should be updated.
Question 99A : Do you think that the national standards for housing developments on water consumption should be introduced in the Black Country?
The adoption of optional higher water efficiency standard should only be applied using the criteria set out in the NPPG (ID 56-013 to 56-017). The Black Country has not been identified as a water stress area in an up to date Water Cycle Study.
Question 99B : Do you think that the national access standards for housing development should be introduced in the Black Country?
No. National accessibility standards should only be introduced in accordance with the criteria set out in the NPPG.

Question 99C : Do you think that the national space standard for
housing development should be introduced in the Black Country?
The nationally described space standard should only be introduced in
accordance with the criteria set out in the NPPG (ID: 56-020).
Question 99D : Do you think the standards should be different for
brownfield and greenfield sites?
No. It is not relevant to whether site is brown or green field.
Question 118 : Do you agree with proposals to streamline and simplify
the Core Strategy Monitoring framework?
The plan making process in the Black Country should be improved. The
existing adopted Core Strategy is over-due for review and second tier Local
Plans are still not yet in place six years after adoption of the Core Strategy.
Any streamlining and simplification of the monitoring framework should
incorporate more effective monitoring mechanisms such as key performance
indicators. Currently the Councils are underperforming by 3,000 dwellings
against adopted Core Strategy housing targets without triggering any positive
policy response.
Appendix B and C - housing trajectories
The housing trajectories in Appendix B and C should be up dated in the Core
Strategy Review.
Conclusion
It is hoped that these responses are helpful in informing the next stages of the
Black Country Core Strategy Review.

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1991

Received: 17/11/2017

Respondent: Campaign To Protect Rural England

Representation Summary:

We do not have a view.

Full text:

Dear Sirs,
This is a covering letter for CPRE's response to the Black Country Core Strategy. This consists of two documents:
* A response to the various questions ('Options response).
* A detailed report on demographic issues ('Housing and Employment Options').
CPRE is a campaigning charity, which is a coalition of a national charity and branches in most counties, which are mostly independent charities. CPRE West Midlands is a regional group of the national charity, whose scope is the West Midlands region.
Our regional chairmanship is technically vacant. As an interim measure, we have agreed a rotating chairmanship, which I currently hold. You may however like also to note the e-mail address of our regional secretary,
Yours Faithfully,
From the Acting Chairman

Black Country Core Strategy Issues and Options
Response for WM CPRE
Sept 2017

Introduction
1. The West Midlands Regional Group of the Campaign to Protect Rural England (CPRE) welcomes this opportunity to respond to the consultation on the Black Country Core Strategy Review and commend the professional nature of the work done by Officers so far.
2. As a charity with about 60,000 members, a branch in every county, over 200 district groups and more than 2,000 parish council members we work locally and nationally to protect, shape and enhance a beautiful, thriving countryside for everyone to value and enjoy.
3. This response was developed with the Staffordshire and Worcestershire Branches of CPRE, who are responsible for monitoring planning in the Black Country.
4. In developing our response we commissioned an independent consultant to
review the economic and housing evidence base and his report is attached.
5. We note that he has concluded that more clarity is needed on the benefits or otherwise of releasing employment land for housing to reach a firm conclusion and we suggest this is work the authorities may want to progress as they move towards a preferred option.
6. We do have some concerns about the wording of the on-line questionnaire, particularly the first two questions. In effect they ask respondents where extra housing and employment land should go as if the quantity of land required was fixed. This is not the case and, to avoid bias, respondents should have been asked whether they agreed with the assumptions about housing and employment need. We hope that this will be addressed in future consultations.

Overarching Comments
7. CPRE is in favour of a continuation of the centres and corridors approach and the ongoing stress on urban regeneration. This, however, has been put under threat by the assumed housing and employment land need.
8. As set out in the attached report we believe there is additional capacity which reduces (or removes) the need for Green Belt housing. We also believe that the level of employment land needed is not as high. There may be some need for larger employment sites, but this needs to take account of land available in adjacent authorities, including (as it stands) all of Four Ashes.
9. In principle we support industrial land which is no longer suitable being used for housing, but this is a complex issue which requires further analysis.
10. We believe it will be as important what type of housing is provided and there needs to be adequate affordable and social housing. In particular there is a need to address directly both accommodation for the elderly, whose numbers will dramatically increase, and housing for young people who are struggling to enter the market.
11. We are concerned that a review of Green Belt appears to be being driven solely by numbers, rather than by policy considerations and that allocations in the Green Belt could undermine urban regeneration.
12. We are in favour of strong policies to support centres, but these need to be framed within a changing environment where some centres may need to shrink or diversify to meet future needs.
13. We want to see a dramatic improvement in public transport provision which supports the regeneration of the Black Country.
14. We also believe more consideration should be given to air pollution, both from
transport and other sources. The issue with diesel cars has increased the awareness of this and yet it is appears to be only obliquely addressed in the strategy.
15. Lastly, the strategy needs to continue the strong emphasis on environmental improvement, including developing the Garden City idea, and it needs to acknowledge the value of the countryside within the Black Country's boundaries.

Responses to Individual Questions

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?

Yes, we agree that a partial review is appropriate. However, we are concerned that some elements are being dealt with out of context with the wider conurbation. In particular, while accepting there may be a need for some larger high quality employment sites across the Combined Authority Area, the basis for this would be wider than the Black Country. Sites such as Peddimore are already going ahead, and we do not believe it would be helpful to over-allocate competing large sites, which would lead to loss of Green Belt and might not be fully occupied.

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.

Yes, the evidence does provide a basis for the review. However, we do not fully agree with the conclusions drawn on housing and employment land as set out in the attached report. This impacts on our response to later questions. We cannot comment on the Green Belt review as it stands since we do not have details as yet.

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.

No, we do not, as is set out in the attached report. In particular we are concerned in supply terms about the double counting of homes resulting from the market uplift identified in South Staffordshire, the questionable need to provide for under-provision from 2011 to 2014, especially as there was over provision in 2015 and no adverse market signals in those years except in South Staffordshire where there was over-provision. Furthermore the Oxford Economic Analysis which, unlike SNPP, allows population migration based on relative economic success, suggests that, even under the most fortuitous circumstances, that is to say delivery of the SuperSEP, some 6,000 households will migrate out of the conurbation beyond those accounted for in the SNPP figures. Since Oxford's Economic Analysis is being widely relied on, this hypothesis should be further tested.

There is a further problem with the trend analysis because it relies on Unattributed Population Growth which SNPP does not. Further analysis should be done discounting UPC, which results from a variety of causes but may not be indicative of the future to reach a reasonable view on likely housing need.

This is particularly important because, while the majority of household growth comes from aging households, about a third comes from migration. We cannot be sure international migration rates will stay as high in a post-Brexit world while out migration to other parts of the UK may continue unabated.

In terms of the supply we cannot identify reasons to disagree with the position taken except in relation to large windfalls and current industrial land. It is clear that many current industrial sites, if they became vacant, would not be considered suitable for industrial use and become housing sites. In other words there is a large pool of potential windfall sites. The assessment of existing industrial land potentially suitable for housing seems to vary across the four boroughs but is clearly very substantial. In other words, even if the policy to release industrial land to housing is not taken forwards, sites will come forward. That being the case the local authorities should, in our view, be less cautious in their approach to large windfalls and assume a continuation at current rates.

Without including additional industrial land these factors could still add up to some 12,500 more homes available than is being suggested and substantially reduce the supposed deficit.

It also is important to understand these factors, because put together all these elements could mean the proportion of elderly people in the population was higher than currently envisaged making the type of housing created even more important.

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.

No, we don't. There is a broad range of figures for future employment need. Much of what is needed for smaller sites can be found based on the available employment land, even assuming the current trend continues. In terms of larger sites the EDNA identifies a need for larger sites, with none currently available over 20 hectares, (although the extension to i54 in South Staffordshire would fulfil that requirement.) To meet SuperSEP requirements it suggests there is a need for roughly 300 hectares of land not currently identified, the majority for logistics. It then discounts 170 hectares of land out of 270 has total at the Four Ashes site for no obvious reasons since it is clearly within the area and would serve the Black Country. This might leave 130 hectares but even that has to be seen in the light of the SuperSEP as a wider strategy, which includes large sites such as Peddimore in Birmingham.

In our view there may be a need for a very limited release of sites over 20 hectares across the SuperSEP area and these are unlikely to be found in the conurbation but, the result of releasing very large amounts of Green Belt land in the Black Country and competing with Four Ashes, Peddimore and other existing business parks and logistics sites, (both in the West and East Midlands,) is likely to be both oversupply and underused sites, which would severely harm the countryside and encourage unsustainable patterns of travel.

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?

No. The approach to the Green Belt review is consistently wrong. It is identified as being solely to identify enough land to meet the housing and employment figures in the SHMA and EDNA. But this does not justify exceptional circumstances.

The NPPG guidance is clear:

However, assessing need is just the first stage in developing a Local Plan. Once need has been assessed, the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as green belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need.

In other words, even if both the OAN is correct and the housing supply figure is correct, which we question (see answer to Question 2), the Green Belt review should not simply identify land to meet that need, it should seek to establish whether the level of land provision should be lower that the OAN because of the constraint of Green Belt.

In other words, Exceptional Circumstances should only be established if there are strategic justifications for the releases.

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?

We agree with most of them. We do not agree with the assumed figure for housing or that it is 'inevitable' that Green Belt will have to be released. That is a policy choice which needs to be assessed taking account of the high level of proof for 'exceptional' Green Belt release.

The key issues do not address the social impacts of the Core Strategy adequately and in particular fail to place sufficient emphasis on the housing needs of an aging population, which is clearly evident in the demographic evidence.

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 supported the principles of the Black Country Core Strategy. In particular we supported the emphasis on urban regeneration and the importance of environmental improvement and enhanced public transport provision to deliver an area people wanted to live in. We also supported the principle of Corridors and Centres. There is a serious risk in our view that the approach to housing and employment land, driven by theoretical numbers rather than strategy, will undermine this approach and rather than lead to improved delivery will export housing and employment into the Green Belt, encouraging unsustainable patterns of development.

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, they should be retained and updated. Their aspirations need to guide the approach to current needs. They should not be diluted.

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?

We do not have any examples to give.

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?

Even if we accepted the figures we do not believe the evidence is good enough yet to make a fully informed choice. Further work needs to be done in the development of the Preferred Option to identify consistently how much employment land might be available across the boroughs and how likely it would be to remain in employment use. This work needs to come to conclusions as to the relative benefit of either use, so that a realistic figure of land that would be better in housing use can be produced. One important element in achieving this will be to ensure there are up to date registers of brownfield land for all the authorities.

Prior to that we favour an approach somewhere in the middle, albeit we do not believe the need for Green Belt release is likely to be as high as is being claimed.

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.

We have no sites we can comment on.

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.

We do not have a categorical view on either option, although it is important that both are considered on their merits and it may be the choice varies from location to location. While some small sites at the edge of the conurbation may have less impact on the aims of Green Belt, they can represent important community assets, they may have wildlife value and they may act as important Green wedges into the city. On the other hand SUEs can be highly intrusive and may not be close to existing transport networks. We would, therefore, suggest both are considered as options, should such land be needed, and that the criteria for sites should have strong ecological and transport elements as well as addressing the purposes of Green Belt.

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).

We have no sites to offer.

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.

See answer to Question 12a.

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

Clearly it depends on size but access to services would be critical, as well as access to transport. Larger SUEs may be more at risk of poor connectivity so that would need to be addressed both in location and in terms of ensuring the internal design supported sustainable transport.

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?

We have no sites to offer.

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?

Yes, if SUEs are developed there should be policy guidance in terms of tenure and infrastructure. In particular there should be identified provision for older households and their needs should be considered in the overall master-planning as well as affordable housing for young people. Furthermore, such master plans should be given force as planning documents by being adopted as Area Action Plans. This is particularly important where a SUE is involves multiple owners.

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

We have none to offer at this stage.

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?

In most cases exporting homes is likely to exacerbate problems in other Local Authorities. However, where OANs in neighbouring authorities have been increased on the basis of migration trends, and those trends rely on migration from the Black Country, it may be that some of those OAN figures should actually be deemed to reduce need in the Black Country, thus avoiding double-counting.

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

We have none to offers at this stage.

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.

It depends how far out the export is.

Question 16 - Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access)

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

Assuming land is needed, we do not support any one of these options in particular. The approach should be varied according to the landscape and transport impacts, as well as Green Belt aims. It will be important that any sites which are released are not just justified by numbers but serve a strategic need for the sub-region. This may mean restricting such releases to sites over 20 has.

Question 17 - Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links?

See Question 16. Rail Access should be important in this case and access to public transport for employees.

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

We do not offer any sites.

Question 18 - Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access)

See Question 17.

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

See Question 17.

Question 19a - Do you support Spatial Option E4? Yes/No; Any further comments?

See Question 17.

Question 19b - Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country)

See Question 17.

If you think there are any potential locations that should be considered, please provide details.

See Question 17.

Question 20 - Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.

See Question 17.

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.

We do not have any suggestions to offer at this stage.

Question 22 - Do you have evidence of a requirement for new social infrastructure to serve existing needs?

Yes/No; If yes, please provide details of the type of facility and where it should be located.

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 23 - Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 24 - Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No;

If yes, please provide details.

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 25 - Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 26 - Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

See our later comments on transport infrastructure.

Question 27 - Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.

The rail network is under considerable pressure with lines such as the Chase Line carrying large increases in passengers. New development outside the conurbation could exacerbate this. There are issues of parking, for example at Stourbridge Junction, where it has reached capacity restricting passenger growth on that line. A balanced approach to the provision of car parking and public transport access is needed to ensure rail growth is maximised.

Question 28 - Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?

Yes, all types.

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.

No comments at this stage.

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.

Green Belt sites inevitably compete with brown field sites. One of the purposes of Green Belt is to support urban regeneration. We do not believe the need for Green Belt sites is as great as anticipated, but (if they are designated) phasing should be used to control how much land comes forward at once, thus supporting urban regeneration.

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?

No comment at this stage.

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

We welcome the use of health impact assessments of the strategy. We would like to see a strategy to increase the health of the population from cradle to grave, which would include encouraging access to open space and the countryside for all members of the community and improving walking and cycling provision and take up.

We are less convinced of the reliance on sustainability appraisals for new sites, particularly large scale Green Belt incursions. SAs are likely to assume some sort of development will go ahead at the site and then seek the best option. SAs are useful in terms of how individual sites are developed but are not designed to answer the question: is releasing the site at all necessary or desirable?

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?

There are a whole range of interventions which are needed to improve health and well being. The Garden City approach, with its emphasis on environmental improvement and enhancement, is one element. Providing improvements to sustainable transport modes is another key element. Addressing the quality of existing housing stock is also needed. Providing local facilities, for health, education and leisure is also key and ensuring these are accessible to all.

There is also a need to specifically address the needs of the increasing number of older people. This includes policies to ensure there is adequate supply of housing which is suitable for older people in locations where they have access to facilities. This will also reduce the prevalence of loneliness and other health issues among the elderly.

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?

Yes, provided there is a proper assessment of alternative approaches rather than just how to deliver the site.

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

In terms of detailed design, environment, permeability and access to public transport are key. There is also a need to ensure enough housing is with design features for those less able.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

We support the reduction in the discount figure. We support a windfall allowance, although, as set out above, we believe the level of larger windfalls should assume a continuation of current trends. Consideration of how to achieve more mixed used development in centres and a reduction in vacancy rates should also be considered.

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?

Table 8 is useful but, given the issue of an aging population, the table should also include a provision for housing which is designed to meet that specific need.

We would support an increase to 40 dph, provided there was flexibility for sites where environmental or local character meant that was not appropriate.

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

We are content with 15 homes but the policy needs to require all developers to establish that they have sought to use land in an efficient way, even under 15 homes.

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?

While we are content with 15 homes the policy needs to require all developers to establish that they have sought to use land in an efficient way. If that is not deemed practical it may be worth reducing it to 11 homes.

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?

We do not believe that Green Belt sites should have lower access standards. It is important that the inevitable impacts on sprawl and sustainability are mitigated by the provision of local facilities and by the use of good urban design. In particular, Green Belt developments have typically been poorly designed for public transport accessibility and walking and cycling. However, whatever standards are implemented, local character and environmental considerations must also be considered.

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.

There is a need to ensure housing for the elderly and the disabled is fully accessible and takes account of the deterioration in mobility that may lead to people being unable to stay in their own home. However, this might be better resolved with a separate policy which sets out the requirement for housing for the elderly, along with the criteria for ensuring that meets their needs.

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.

They can assist but the need is not only to identify how many houses with a particular number of bedrooms but to ensure new housing is provided to meet specific needs, such as the increase in older residents and the need for affordable homes for young people.

Question 41a - 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:

Yes, a policy is required. This could help in a modest way to ensure small windfall sites come forward for development.

Question 41b - A target for each authority? Yes/No; Any further comments

We do not have a view.

Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?

We do not have a view.

Question 41d - Another approach altogether? Yes/No; If yes, please specify.

We do not have a view.

Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.

This is an issue in some areas of the Black Country, which can undermine an area if there is not the infrastructure to support HMOs. Not only can it lead to traffic congestion, it can overwhelm local health and education provision. Some HMOs appear to be of poor quality and not necessarily managed in a way which benefits the local community. As we understand it Local Authorities have powers to require planning permission where there is a problem with HMOs. While, it is probably not for the Core Strategy to be prescriptive it could refer to those powers.

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.

Yes, we agree there is a need for sufficient affordable homes.

Question 43a - 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.

We are concerned about the way in which thresholds work. If the threshold is 15, it encourages developers to bring forward schemes for 14 houses, so that they do not have to comply with the more onerous requirements above the threshold. Where there is an affordable housing requirement of 35% (and some councils are managing 40%) affordable, and the threshold is 15, the developer of a 15-house site will have to provide 5.25 affordable houses, but the developer of 14-house site will provide zero. Since affordable houses are less profitable, the threshold provides a perverse incentive not to build affordable houses. Given the need a lower threshold might be desirable, (always taking account of local character.) and this would be in line with NPPG but we would like to see consideration of how to ensure affordable homes on smaller sites.

Question 43b - If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?

Given the need a lower threshold would be desirable, taking account of local character. This seems to be in line with NPPG. We share the concerns expressed in the Preferred Option that an increase in the provision of starter homes which are not genuinely affordable may impact on other affordable tenures and would welcome work to try and address this issue within the current regulations.

Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site?

Yes /No; Any further comments?

Consideration needs to be given to the location of the sites. See answer to Question 45.

Question 44b 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?

Consideration needs to be given to the location of the sites. See answer to Question 45.

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.

Yes, we would support this provided those Green Belt sites were also designed to be in sustainable locations with good access to local facilities as affordable housing is likely to be needed disproportionately by people with mobility issues or without access to a car.

Question 46 - Do you agree with the proposed new gypsy, traveller and travelling showpeople accommodation targets? Yes/No; If no, please explain why.

Gypsies and other travelers are as entitled to a home as much as the settled community, but the location of their sites should be subject to the same criteria as for the settled community. The frequency of recent incursions on to public and other open space suggests there is a significant unmet need, which ought to be met. We are not able to comment on the specific figures but agree that sufficient sites need to be supplied to avoid illegal encampments. No Green Belt sites should be released unless exceptional circumstances can be proved.

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.

Yes, there is a need to address the availability and funding of all relevant facilities. There is a need to identify in this policy the impact of provision of housing for the elderly so that locational decisions on facilities are taken in the light of where the less able may be living.

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.

We support the current policy.

Question 49a - 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.

Yes. Since employment land may become vacant that is not allocated and there is a need to examine its potential for release for housing and balance the benefits of alternative uses. In some cases these may not be housing. It may even be the land would be better used for open space or nature conservation. Perhaps the policy should allow for that.

Question 49b - 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.

See answer to 49a

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.

The overall provision of employment land may not be as relevant as the changing nature of jobs today means they are less dependent on land allocations. If land goes out of employment use because a factory closes, for example, it may not be as important to replace that land as to provide the kind of sites needed for new jobs.

Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/No; Please explain why.

Yes, provided the Black Country is seeking to improve the quality of existing sites and not simply relying on new allocations.

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?

We do not have a view at this stage.

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?

We do not have a view at this stage.

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?

Yes, we support this approach. High Quality land should not be squandered, both because it is needed to high quality jobs and because it can lead to environmental and countryside impacts if it has to be replaced

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 agree that a balanced portfolio is likely to be a better approach.

Question 55 - Do you agree with the proposal to retain Policy EMP5? Yes/No; If no please explain why.

Yes.

Question 56 - Do you agree with the proposal to update Policy EMP6 in line with current priorities? Yes/No; If no, please explain why

Yes.

Question 57 - Do you support the proposal to merge Policy CEN1 and Policy CEN2, given that both policies focus on the overall strategy in the Black Country, including the hierarchy of centres? Yes/No; If you have any comments on Policies CEN1 and CEN2 please provide details.

Yes, provided the emphasis is retained and not diluted.

Question 58 - Do you think there is any evidence to suggest that the hierarchy of centres is not appropriate going forward in the context of the regeneration strategy? Yes/No; If so, please provide details.

No. Depending on where new housing goes there may be a need for additional local provision but the main four centres should remain the backbone of the spatial strategy.

Question 59 - Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.

Yes.

Question 60 - Is there evidence to suggest that identified centres are no longer performing as a centre or at their identified level in the hierarchy? Yes/No; If yes, do you agree that they should be moved / removed within or out of the hierarchy?

No.

Please explain why.

Question 61 - In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments

No. Depending on where new housing goes there may be a need for additional local provision but the main four centres should remain the backbone of the spatial strategy.

Question 62 - Do you agree that the Strategic Centres should remain the focus for large scale comparison retail (clothes, white goods etc), office and major commercial leisure development in the Black Country? Yes/No; Any further comments?

Yes, as well as seeking to increase housing provision within and close to those centres.

Question 63 - Do you agree that the targets for comparison retail floorspace and office floorspace should be revisited as part of this review to take into account current and future trends? Yes/No; Any further comments?

We are not able to give a detailed response but in general we consider that the policy should encourage a balance of development in the centres so they are attractive places to visit which serve a variety of needs. This may even mean a reduction in retail and an increase in leisure. It is probably as important to consider the quality of the retail offer and ensure anchor stores remain or are introduced.

A key element in the future of the main centres (and smaller ones) will be masterplanning to ensure there is a balance of provision. The introduction of a variety of uses will help centres to thrive. It is probably not for the Core Strategy to be too prescriptive but it should also not assume the pattern of retail will remain the same.

Question 64 - Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?

We are not able to give a detailled response. A balanced approach is required and in some cases it may be better to reduce retail floorspace on the edge of centres to encourage a balance of uses. In particular the role of larger supermarkets may change in the future and require less land allowing for more mixed use on those existing sites and the introduction of smaller convenience stores.

Question 65 - Should the Core Strategy set any targets or policy requirements for leisure development in the Strategic Centres? Yes/No; Any further comments?

The strategy should encourage leisure facilities to be located in centres where they are accessible to all. This should include night time facilities as long as there is suitable planning to avoid and manage any anti-social behaviour.

Question 66 - Should the Core Strategy set new housing targets for the Strategic Centres through the review? Yes/No; Any further comments?

The strategy should encourage housing in centres. It should not only consider how much is needed but what kind of housing will best support those centres and, more widely, the overall strategy. For example, encouraging young entrepreneurs or professional workers to move into the centres may be key to developing the future economy more widely. In general we would like to see more use of upper stories over shops for housing.

Question 67 - Do you think there are any other uses and/or developments that should be planned for in the Strategic Centres? Yes/No; Please provide details.

There is a need to encourage the greening of centres, including provision of trees and other green features which have been lost in many. Their links to local green space, (for example Walsall Arboretum,) should also be promoted.

There is also a need to ensure centres are walkable with access to centres by sustainable modes from surrounding areas encouraged.

Question 68 - Do you agree with the proposal to re-examine the detail and appropriateness of the existing conditions for retail growth at Merry Hill through the Core Strategy review? Yes/No; Do you have any further comment to make on this issue?

We support the current conditions.

Question 69 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country Town Centres? Yes / No; Please explain why.

Some flexibility is desirable provided it leads to a balance of uses and especially improves the quality of the centres.

Question 70 - Do you think there are any specific developments or uses that should be supported in any particular Town Centre? Yes/No; Please provide details.

We have no examples.

Question 71 - Should the Core Strategy set housing targets for the Town Centres? Yes/No; Please explain why.

Yes, the core strategy should seek housing within town centres but these might exceed any targets.

Question 72 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country District and Local Centres? Yes/No; Please explain why.

This will vary from centre to centre and some flexibility is required. In particular the contraction of the retail area may in some cases create a more viable centre, both by allowing for housing in the centre and other uses which may attract people to the centre, but it must still be able to accommodate sufficient retail needed to perform its function.

Question 73 - Are there are any specific developments or uses that should be supported in any particular District or Local Centre? Yes/No; Please provide details

We have no examples.

Question 74 - In the context of the 'centres first' strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of Strategic, Town, District and Local Centres? Yes/No; Please explain why.

We support the threshold approach but have no comment on individual levels.

Question 75 - Should thresholds apply to all main town centre uses (Yes) or just retail uses (No)? Please explain why.

There is a case for considering thresholds for some leisure uses where these impact on other centres.

Question 76 - Is the approach set out in Policy CEN6 appropriate in the context of supporting local community needs? Yes/No; Please explain why.

Yes, it remains important to provide local facilities.

Question 77 - Does the wording of the criteria clearly achieve the objectives of the centres strategy? Yes/No; Please explain why.

Yes.

Question 78 - Should the policy clarify that this policy applies both to applications in edge-of-centre and out-of-centre locations, and should this also be referred to in the relevant centres policies? Yes/No; Please explain why.

Yes.

Question 79 - Should the policy set what types of uses this policy applies to and set out any further types of material considerations that could be relevant for the determination of certain proposals, for example, the location or concentration of hot food takeaways, premises selling alcohol or gambling operations? Yes/No; Please explain why.

Yes, this is important as the aim is to provide day to day facilities which support the community.

Question 80 - Should the policy clarify that those schemes of multiple units, where individual units are below the set figure, but the cumulative figure is above, also need to meet the relevant requirements of other centres policies? Yes/No; Please explain why

Yes.

Question 81 - Do you agree that the approach of strong control over out-of-centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Country Centres? Yes/No; Please explain why.

Yes, large out of centre retail is not likely to be sustainable and will not provide access for all parts of the community.

Question 82 - Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.

We do not have a view on the exact level.

Question 83 - Should Policy CEN7 provide more guidance on accessibility? Yes/No; If yes, please explain why .

Yes, that would be helpful, provided that guidance is to ensure a development is as sustainable as it can be and the guidance is not considered a justification for development in principle.

Question 84 - Do you think that Policy CEN8 is still appropriate for managing car parking in centres and will ensure the network of Black Country Centres are maintained and enhanced over the plan period? Yes/No; Please explain why.

Yes, in general. There is a need to ensure parking serves the whole of centres and to avoid restrictions, for example, of parking to individual supermarkets or leisure facilities which then harms a centre or adds to traffic movements in the centre. We raised concerns when the plan was originally devised that lower parking standards where public transport is poor could encourage developments which were very car dependent in those locations. We remain concerned about this and the review needs to consider the evidence in relations to this and whether parking standards at out of centre locations are tight enough to ensure there is an incentive to encourage use of alternative modes.

Question 85 - Should Policy CEN8, with regards to pricing of car parks, continue to be applied to Strategic Centres to ensure that pricing of parking is not used as a tool of competition? Yes/No; Please explain why.

Yes. And also to ensure car parks serve the whole of the centre and not a single retailer which reduces footfall across the centre and can lead to additional congestion if people park twice. The control of Long Stay car parking, in particular, remains critical to supporting public transport. Short stay car parking should not be so expensive it puts people off visiting a centre.

Question 86 - Do you think that there are other centre uses or centres issues that need to be addressed in the centres policies? Yes/No; Please provide details.

None come to mind.

Question 87 - As shopping, leisure and other commercial trends continue to change, should the revised Core Strategy have a policy to reallocate out-of-centre attractions that are no longer viable for town centre uses for alternative uses such as for employment uses or housing? Yes/No; If no, please explain.

Yes. The Core Strategy needs to consider this as well as anticipating a reduction in store size from major supermarkets and other stores as they refurbish or replenish their estate. In particular where new facilities in a centre reduce the need for out of centre uses alternative uses of those sites may be desirable.

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

Yes, in general we support the strategic aims. However, we do not believe the ambition is adequate in terms of public transport improvements and support for walking and cycling.

As well as on-road provision for sustainable modes we would support extensions to the network of Green Routes offering links into the countryside (including across into Worcestershire and Staffordshire).

We also believe there is still a case to consider demand management options which will support modal change and also fund public transport improvements. However, without ongoing work on this it is hard to be more prescriptive.

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

We generally support the proposals to improve public transport in the sub-region. However, we consider they lack the necessary ambition. In particular we would like to see a rail network developed systematically across the region, including the links centered round Walsall including to Wolverhampton, Sutton Coldfield, Brownhills as well as the through route from Lichfield to Stourbridge. This would require consideration of additional heavy rail lines on the Wednesbury to Brierley Hill section or alternatively Metro extensions along the whole route. We support improvements to the bus network but these need to be integrated with rail. We agree that rail freight should be encouraged but this needs to be at an appropriate level. We are not in favour of the massive Four Ashes Proposal in South Staffordshire.

We are concerned that hard shoulder running is being progressed simply to deal with congestion on motorways with little consideration of the impact of the additional traffic. While this is in many cases preferable to motorway widening we would like to see analysis of the comparative benefits of investing that money in public transport options.

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

The provision of charging points is welcome. However, this does not address congestion issues so it is important that policies to change behaviour are pursued as well.

Question 91 - Do you support the proposed changes relating to the efficient movement of freight? Yes/No; If no, please explain why.

We support the use of Bescot for a rail freight interchange, taking full account of the impacts on local people. We are not in favour of Four Ashes which we consider is too big. We regret the fact that the proposal is being taken through the NIC process rather than being subject to local scrutiny that would examine how well it fits in with the needs of the Black Country and whether its impact on Green Belt, the environment and local roads is acceptable.

Question 93 - Do you support the proposed changes to Policy TRAN5? Yes/No; Please explain why.
In general terms we support the development of a Key Route Network. The development of new technology is also welcome but should be seen alongside encouraging modal shift.

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.

We support the emphasis placed on environmental enhancement and place making. However, CSP3 and CSP4 do not sufficiently emphasise the rural character of parts of the Black Country. Even if there is some development in the Green Belt the environmental policies should emphasise the value of this remaining countryside in terms of landscape, amenity, farming, environmental and biodiversity .

Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?

We support the Garden City approach in general provided a balance is properly applied between landscape, biodiversity and other aspect of the environment.
Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

In general we would like to see the application of similar approaches to density, character and environmental enhancement. However, this needs to be sensitive to local character and landscape which this may influence how specific sites are developed.

Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?

We welcome the inclusion of ancient woodland.

Question 97 - Do you support the proposed changes relating to Historic Character and Local Distinctiveness? Yes/No; If no, please provide details of any other changes that should be made to Policy ENV2.

We support the need to protect historic assets, including those which are not designated. The review should include an assessment of the effectiveness of the current policy in relation to non-designated assets, for example, the integrity of areas of Victorian terracing. This should be used to review these policies and how they can be enhanced.

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 high quality design but are not able to comment on the details.

Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

We support the need to reduce water consumption but are not able to comment on the details.

Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Yes, there is a need to ensure homes are fully accessible, taking account of local character. This will become more important with an aging population.

Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Yes, there is a need to ensure homes have adequate space standards, taking account of local character. This will become more important with an aging population.

Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

Not in general, but may depend on local circumstances.

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.

No, we do not understand the removal of reference to canal projects. We agree they need to be determined at a local level, but the reference in the core strategy is important because the network is a strategic as well as a local asset. The policy could be up-dated to acknowledge the fine grained nature of such projects and allow flexibility within a broad approach.

The policy should also add that canals act as an important link between town and countryside in the sub-region.

Question 101a - Do you support the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects? Yes/No; Further comments?

Question 101b - Do you think that any other changes should be made to Policy ENV5? Yes/No; If yes, please provide details.

We are not in a position to comment.

Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain

See 102c.

Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space?

Yes/No; If no, please explain

See 102c

Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes should be made. Yes/No; If yes, please provide details.

We support the need for policies to protect and enhance open space across the sub-region. We believe it should be central to the policy for regeneration.

It needs to also be acknowledged that many open space areas on the edge of the conurbation act as links to the surrounding countryside and are often integral with it. Improvements to open space which have countryside benefits (such as the large scale tree planting creating a country park at the Grange in Walsall) should be encouraged as well as promoting planting in gardens and institutional grounds.

It is also important to stress the need to ensure these areas continue to be managed and not allowed to decay.

Question 103a - Do you think that Policy ENV7 should be changed to allow increased energy efficiency standards to be accepted in lieu of renewable energy provision for non-domestic buildings? Yes/No; If not, please explain

We are not in a position to comment.

Question 103b - Do you think that the 10% requirement should be changed?

Yes/No; If yes, please specify what percentage would be more appropriate and to what type of site it should apply.

We are not in a position to comment.

Question 104 - Do you support the proposed changes relating to Air Quality?

Yes/No; If you think that any other changes should be made to Policy ENV8 please provide details.

Improving air quality is critical to the health and well-being of the sub-region. We have no comments on the detail.

Question 105 - Do you think that Policy WM1 identifies all of the key waste issues that need to be addressed in the Core Strategy, in accordance with national policy?

Yes/No; If not, please specify what changes should be made to the Policy.

If you have any evidence that can be referred to in the Waste Study, please provide details.

We support the approach of aiming to reduce waste and deal with waste within the subregion as close to where it arises as is practical. New or extended waste sites should be assessed on their impact on the landscape and countryside.

Question 106a - Do you support the approach set out in Policy WM2? Yes/No; If no, please explain why.
See 105

Question 106b - Are there any strategic waste management sites that no longer need to be protected? Yes/No; If yes, please provide details

Question 106c - Are there any new sites that do need to be protected? Yes/No; If yes, please provide details.

See 105

Question 107 - Do you think that there are any strategic waste management proposals that should either be removed from or added to the list in Policy WM3?

Yes/No; If so, please provide details.

See 105

Question 108 - Do you agree that Policy WM4 provides an appropriate level of control over the location and design of new waste management facilities? Yes/No;

If no, what changes do you think should be made to the Policy?

See 105

Question 109 - Do you agree that Policy WM5 provides an appropriate level of control over resource management for new developments? Yes/No; If no, what changes do you think should be made to the Policy?

We support the approach of aiming to reduce waste and deal with waste within the subregion as close to where it arises as is practical. New or extended waste sites should be assessed on their impact on the landscape and countryside.

Question 110 - Do you think that Policy MIN1 identifies all of the key minerals issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/no; If no, what changes should be made to the policy?

We do not have a comment at this stage.

Question 111 - Do you agree with the proposed change to 'prior extraction' requirements, to maintain a size threshold in urban areas and increase the threshold for green belt sites to 3 ha? Yes/No; If no, what evidence do you have to justify an alternative approach?

We have concerns about raising the threshold in Green Belt. Where development occurs in Green Belt it needs to take account of minerals. The policy does not imply mineral extraction will occur only be considered. The policy could be strengthened to take greater account of both the impact on the landscape/environment of extraction and any benefits to be gained.

Question 112a - Are there any key mineral related infrastructure sites that no longer need to be protected? Yes/No; Please provide details

We are not able to comment.

Question 112b - Are there any other sites that do need to be protected? Yes/No; If yes, please provide details.

We are not able to comment.

Question 114 - Do you have evidence of workable, viable deposits of brick clays outside the areas of search, which could justify defining new areas of search?

Yes/No; If yes, please provide details.

We are not able to comment.

Question 115a - Do you have evidence of any realistic possibility of fracking in the Black Country? Yes/No; If yes, please provide details.

It seems unlikely that fracking sites would be realistic in the Black Country. Should they exist they would inevitably be in areas of countryside and policies to address them should take account of the impact on landscape and biodiversity as well as the safety and suitability of the access to the site (as defined in NPPF), especially given the reliance on OGVs (the heaviest form of HGVs) to carry equipment and waste water to and from the site. Any policy would need to clearly apply to testing and monitoring as well as production.

Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy?

Yes/No; If yes, please provide details.

See 115a

Question 116 - Do you think that Policy MIN5 identifies all of the key issues that need to be addressed in relation to new mineral developments in the Core Strategy, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

We do not have a comment.

Question 117 - Do you agree with the proposed approach to updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy? Yes/No; If not, what alternative approach would you suggest

We do not have a comment.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2362

Received: 08/09/2017

Respondent: Taylor Wimpey UK Limited

Agent: Lichfields

Representation Summary:

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.

Full text:

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.

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2414

Received: 08/09/2017

Respondent: Catalyst Capital

Agent: Savills

Representation Summary:

It is considered that there is currently insufficient evidence to support a requirement for the Core Strategy strategic policies to introduce either a specific policy approach towards self and custom build housing, or a target for each authority, or a requirement for large housing sites to provide serviced plots. Whilst the Core Strategy could encourage the development of self and custom build housing, it should not introduce specific delivery requirements and targets without robust evidence.

Full text:

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 adopted Core Strategy predates the National Planning Policy Framework (NPPF). The Core Strategy should be fully updated to take account of all relevant changes in Government policies and guidance, including the implementation of provisions being brought in through the Housing and Planning Act (2016), such as Starter Homes and the Brownfield Land Register. The Black Country covers four Local Authorities and it is therefore crucial that the spatial strategy is fully reviewed so that all the policies are relevant and up-to-date. Furthermore, the scale of the proposed changes to the existing strategy warrants a full and comprehensive Core Strategy Review. It is also essential that the Review takes account of the Birmingham Housing Market Area (HMA) shortfall.
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.
The existing evidence base is, in part, dated and needs to be brought fully up-to-date in order to provide a sound and robust basis for the emerging Core Strategy.
Our client continues to promote the acceptability of the redevelopment of the previous developed land (including Factory complex AP (UK)) at Heathfield Lane West, Darlaston (Walsall Borough) for housing development (please refer to the Call for Sites submission).
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.
We recognise that there will be a need to release greenfield (including Green Belt) land for development to plug the shortfall between the existing supply identified through the Black Country Core Strategy constituent Authorities' SHLAAs and the final objectively assessed housing need figure for the Black Country. In reviewing the existing supply data we consider that it is important to continue to encourage housing development on previously developed sites, to assist with the delivery of regeneration across the Black Country and to contribute to achieving sustainable development. There should be an appropriate balance between previously developed and greenfield land supply.
The completions and SHLAA housing supply figure of 48,185 homes includes the previously developed land (including factory complex AP (UK)) at Heathfield Lane West, Darlaston (please refer to the Call for Sites Submission). We support the retention of this site, as a suitable site for significant housing delivery, in the housing land supply.
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?
We agree with the essence of the key issues summarised in the first two bullet points. The Black Country Authorities should still retain their focus on supporting the redevelopment of brownfield land for housing, where appropriate, alongside the need to look beyond the existing Growth Network for additional land supply. However we consider that a full review of the Core Strategy should be undertaken, supported by a robust and up-to-date evidence base, to ensure the Core Strategy is sound.
Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
The NPPF (paragraph 17) states that the principles of planning should encourage the effective use of land by reusing land that has been previously developed. The NPPF does not provide a specific hierarchy for the development of land and therefore we recognise that having a sustainability principle that seeks to put brownfield land first could be difficult to justify and enforce. Accordingly we consider that the fourth sustainability principle should more closely reflect the wording of the NPPF. However it is important that the Black Country Authorities still positively encourage the redevelopment of suitable brownfield sites because these are still an important element of having a balanced housing land supply.
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?
We consider that Core Strategy policies CSP1 and CSP2 should be updated to reflect growth proposals beyond the Growth Network.
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?
We consider that the boundary of Regeneration Corridor RC5 should be expanded to include the former AP (UK) and Moxley Tip sites because these are both significant regeneration sites and both included within the emerging Walsall Site Allocations Document.
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.
We continue to support the redevelopment of the former AP (UK) site to housing. This site has extant planning permission (ref. 08/0394/FUL) for redevelopment to housing and is the subject of a draft allocation (HO303) within Policy HC1 of the ongoing Walsall Site Allocations Document. Proposals for the redevelopment of this site for housing are being actively pursued. We therefore strongly promote the inclusion of this site as a housing site within the Core Strategy (please refer to the Call for Sites submission).
Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.
The shortfall in housing land supply means that the percentage of housing development on previously developed land is going to decrease from the 95% target included in current Core Strategy Policy HOU1 due to the need to release greenfield land to meet the Emerging needs. The Black Country Authorities should however continue to positively encourage and support development on previously developed sites, through viability negotiations and through the use of grant funding where necessary. This will enable suitable previously developed sites to come forward for housing development at the earliest opportunity as part of a balanced housing land supply.
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?
NPPF paragraph 58 states that policies should aim to ensure that developments should respond to local character and history and reflect the identity of local surroundings. NPPF paragraph 59 identifies that design policies should avoid unnecessary prescription or detail and infers that the approach to density should be taken in relation to the neighbouring buildings and the local area more generally. The NPPF does not therefore currently set minimum density standards.
Any proposed changes to accessibility and density standards need to be justified with appropriate evidence. Before a review of Policy HOU2 and Table 8 is pursued, further evidence should be provided on whether the accessibility and density standards have been successful. We consider that applying blanket policies on density does not always lead to the most appropriate forms of development that are deliverable, viable, and compatible with the location and meet market requirements. The wording of Policy HOU2 should be sufficiently flexible to accommodate approaches to density to be considered on a site-by-site basis.
We therefore disagree with setting a minimum net density of 35dph and with a possible increase on this figure. Furthermore any proposed changes to the current accessibility standards should only be undertaken using the criteria set out in the Planning Practice Guidance.
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?
Further evidence should be presented on what proportion of housing delivery across the Black Country has been on sites of 15 dwellings or more. The Black Country faces significant challenges over the viability of sites within its housing land supply under the current market conditions. The Core Strategy should be supported by up-to-date viability evidence. Any proposed changes to site size thresholds needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 173 & 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
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.
The proposal for any additional accessibility standards for particular types of housing should be justified by sufficient appropriate evidence that meets the requirements of the Planning Practice Guidance. The NPPF (paragraphs 173 and 174) sets out the need for policies to be supported by evidence, the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and the need to avoid placing the implementation of the plan at serious risk. More evidence is therefore required. We reserve the right to comment further as and when new evidence becomes available.
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.
The NPPF (paragraph 50) requires Local Planning Authorities to take Strategic Housing Market Assessments (SHMAs) into account as part of the evidence base for developing Local Plans. The NPPF also states that local planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community, as well as identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand.
Therefore it is appropriate for the 2017 Black Country and South Staffordshire SHMA should form part of the consideration in appraising the mix of homes to be delivered on individual sites. However the Core Strategy policies should avoid setting prescriptive house type targets for the Plan period to provide the flexibility for a wide range of factors to be taken into account in delivering different types of housing on sites in the Black Country over the course of the Plan period.
Question 41a - 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:
Question 41b - A target for each authority? Yes/No; Any further comments
Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
Question 41d - Another approach altogether? Yes/No; If yes, please specify. Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.
It is considered that there is currently insufficient evidence to support a requirement for the Core Strategy strategic policies to introduce either a specific policy approach towards self and custom build housing, or a target for each authority, or a requirement for large housing sites to provide serviced plots. Whilst the Core
Strategy could encourage the development of self and custom build housing, it should not introduce specific delivery requirements and targets without robust evidence.
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.
Detailed evidence is required to determine, amongst other matters, viability and past delivery across the BCCS area, before any changes can be proposed.
Question 43a - 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.
Question 43b - If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?
Further evidence is required. The Black Country faces significant challenges over the viability of sites within its housing land supply under the current market conditions. The Core Strategy should be supported by up-to-date viability evidence. Any proposed change to site size thresholds needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 174 and 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the Plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
Question 44b 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?
Further detailed evidence is required to support any proposed changes. The Core Strategy should be supported by up-to-date viability evidence, including with respect to whether a 25% requirement remains viable.
Any proposed changes to affordable housing requirements needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 173 and 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
Question 49a - 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.
Question 49b - 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.
Where there is clear evidence that the existing employment use is not required, then such previously developed sites should be released to meet the housing requirement within the Black Country. The NPPF (paragraph 17) encourages the effective use of land by reusing previously developed (brownfield) land. The NPPF (paragraph 22) also states that planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why?
Our client considers that the approach to water efficiency should reflect the outcome of the Housing Standards Review (2015) and therefore seeking a water efficiency target of 125 litres per person per day being the minimum national standard, implemented through building regulations.
The DCLG Written Ministerial Statement (WMS) issued on 25 March 2015 stated that "From the date that the Deregulation Bill 2015 is given Royal Assent, local planning authorities and qualifying bodies preparing neighbourhood plans should not set in their emerging Local Plans, neighbourhood plans, or supplementary planning documents, any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings". The Deregulation Bill was given Royal Assent on 26 March 2015.
Any variation to the national minimum standard would therefore require additional evidence. As acknowledged in paragraph 6.1.52 of the Black Country Core Strategy Issues and Options Report, the Black Country does not currently lie in an area of serious water stress and therefore it does not appear likely that a variation to the national minimum standard could be demonstrated. However we reserve the right to comment further if new evidence becomes available.
The WMS also states that the optional new national technical standards with respect to water should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered in accordance with the NPPF and Planning Practice Guidance. The Planning Practice Guidance identifies that in order for Local Planning Authorities to introduce a new requirement they need to identify a 'clear need' based on: existing sources of evidence; consultations with the local water and sewerage companies, the Environment Agency and catchment partnerships; and consideration of the impact on viability and housing supply of such a requirement.
Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
In accordance with the requirements of the NPPF (paragraph 174), in setting any local standards through Local Plan documents, "local planning authorities should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle. Evidence supporting the assessment should be proportionate, using only appropriate available evidence".
The national accessibility standards are not a requirement. The NPPF (paragraph 158) makes it clear that each local planning authority should ensure that their Local Plan is based on adequate, up-to-date, and relevant evidence. The new Core Strategy should therefore only require developers to meet the national accessibility standards if this can be justified by appropriate evidence in accordance with the criteria set out in the Planning Practice Guidance, with reference to Requirement M4(2) and/or M4(3) of the optional requirements in the Building Regulations. We reserve the right to comment further if and when new evidence becomes available.
Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
In accordance with the requirements of the NPPF (paragraph 174), in setting any local standards through Local Plan documents, "local planning authorities should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle. Evidence supporting the assessment should be proportionate, using only appropriate available evidence".
We consider that space standards should be left to developers to determine in line with market requirements.
Whilst the Housing Standards Review introduces a new national space standard, this has not been incorporated into the Building Standards and is not a requirement. Housebuilders have a vested interest in building products that meet market needs, which will sell and which are viable to build. The policies in the new Core Strategy should be sufficiently flexible to allow this to happen without adding a prescriptive policy burden. If the market demands space standards in line with the optional national standards, then it is more likely that developers will deliver these. These considerations all form part of the need to take account of 'market signals', as required by the NPPF.
The NPPF makes it clear that each local planning authority should ensure that their Local Plan is based on adequate, up-to-date and relevant evidence. The new Core Strategy should therefore only require developers to meet the National Space Standards if this can be justified by taking account of need (evidence provided on the size and type of dwelling currently being built in the area), viability (consideration of the impact of adopting the space standards as part of the Plan's viability assessment) and timing (potential need to factor in a reasonable transition period following adoption of a new policy on space standards to allow developers to factor this into future land acquisitions), in accordance with the requirements of the Planning Practice Guidance. We reserve the right to comment further if and when new evidence becomes available.
Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why
There is currently no evidence presented with the Issues and Options consultation document to use to make an informed decision on whether the standards should be different for brownfield and greenfield sites.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2472

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Pegasus Group

Representation Summary:

There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.3 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.4 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.5 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.6 In terms of the Plan period proposed in paragraph 1.17, whilst a 15 year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.7 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained in the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications on the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* The OAN identified by the SHMA for the Black Country and South Staffordshire is generally supported, however, there are concerns with regard to the methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid 2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
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.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, all except for the principle to 'put brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. The is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is, therefore, suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPF's main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.6 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.
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.
5.7 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.8 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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).
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.
5.9 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.10 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.11 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.12 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.13 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.14 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.15 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.16 Land at Home Farm, Sandhills is a location on the edge of Brownhills in Walsall Borough that could accommodate in excess of 1,200 homes, complete with open space, al local centre and potentially a primary school if required. A Call for Sites form is included at Appendix B, which demonstrates the sites suitability, achievability and deliverability. In addition, a Technical Compendium is included at Appendix C, which includes evidence in relation to landscape and visual matters, cultural heritage and archaeology, transportation, agricultural circumstances, ecology, flood risk and drainage and ground conditions. All of which serves to demonstrate there are no constraints to the delivery of the site and that residential development of circa 1,200 homes can be successfully achieved.
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?
5.17 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.18 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.19 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in both the Black Country and South Staffordshire) across authorities and, therefore, once all options within the HMA have been explored, these could help deliver growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
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.
5.21 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.22 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.23 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.24 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 We are in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals proposed at Home Farm, Sandhills.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with the Core Strategy. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions in the Black Country Core Strategy Review are needed.
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.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of green field and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing green field and Green Belt sites should come forward for development as soon as practically possible. In light of the lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the plan period and the needs are met.
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?
6.11 When delivering green field/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous community.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing
Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete re-assessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter
Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment
Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan Period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment
Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation
Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2592

Received: 08/09/2017

Respondent: Bloor Homes

Agent: Pegasus Group

Representation Summary:

7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
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.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
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?
5.6 No comment.
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?
5.7 Option 1A is considered to be appropriate for accommodating the growth needs of the Black Country over the Plan period to 2036. This option would significantly boost the supply of housing land and help to meet the significant current and future identified need.
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.
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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.
5.10 No comment.
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).
5.11 No comment.
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.
5.12 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.13 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.14 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.15 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.16 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.17 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development. With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.18 No comment.
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?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.20 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.21 Even if all realistically deliverable options have been considered within the Black Country, there will remain an unmet need for housing. Therefore, it is necessary for the Black Country authorities to consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.22 No comment.
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.
5.23 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.24 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.25 No comment.
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.26 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.27 No comment.
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.28 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.29 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.30 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 No comment.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. Committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
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.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
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?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS Housing
Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment.
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2669

Received: 08/09/2017

Respondent: Wallace Land Investments

Agent: Pegasus Group

Representation Summary:

7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
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.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.6 As touched upon above and throughout these Representations, it is clear that given the significant amounts of housing that will need to be delivered across the Black Country, there will be a need for a switch from a sole focus on brownfield regeneration to a need for a dual approach that focuses on both brownfield and strategic greenfield/green belt release. The focus on Regeneration Corridors and Strategic Centres was very much a product of the times and housing needs of when the Core Strategy was first adopted in 2011. In light of the emerging, higher housing requirements, it is clear that there is a need for a fresh approach to the spatial distribution of growth across the Black Country. Whilst reference to strategic centres and regeneration corridors could remain, this remit needs to be expanded to reflect the evident need for urban extensions outside of the existing growth networks. Indeed, Sustainable Urban Extensions both within the Black Country administrative boundaries and within the adjacent South Staffordshire District will be required to meet emerging housing requirements. These policies should therefore be expanded to include references to urban extensions in the form of green field land outside of the defined urban area, to ensure that sufficient certainty is built into the plan that the housing needs of the area will be met. Amending these policies to make it clear that both brown field and green field land is required will ensure that a fresh approach to spatial distribution across the Black Country Area would be secured and delivered.
5.7 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.

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;
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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).
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.
5.10 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.11 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.12 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.13 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.14 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.15 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.16 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.18 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.19 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
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.
5.20 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.21 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.22 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. Indeed, there is likely to be a significant growth in the need for logistics floorspace to accommodate rapid increases in the dot.com purchasing of goods and demand for next day delivery. Efficient access to motorway junctions and the strategic road network and the availability of large sites will therefore take priority, as well as other considerations such as the ability to operate 24 hours. Placing such sites directly next to the existing urban area may therefore be impractical. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.23 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.2 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.3 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.4 No comment.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.5 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.6 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.7 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.8 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
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.
6.9 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
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?
6.10 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 Figure 11 and Table 6 of the Issues and Options Paper make no reference to Hardwick. We have replicated Figure 11 on the following page [SEE ATTACHED DOCUMENT FOR IMAGE], and labelled Hardwick which we consider should be identified as a Local Centre within the retail hierarchy. There are a number of local facilities in Hardwick, including a cluster of shops, public houses and restaurants centred around the Chester Road/Hardwick Road junction. There are 9 facilities located at this junction, which comprise of 2 no. restaurants, 1 no. public house, 5 no retail units and 1 no. A5 unit. Hardwick is therefore well served by a number of local facilities, and should therefore be a designated centre within the Core Strategy Review. This is particularly the case given that Hardwick is well-suited to accommodate future housing growth as explained in other sections of these Representations, therefore Hardwick should be designated as a centre to reflect future growth in the area.
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 As discussed above, it is suggested that through the Local Plan Review, there will be a need to designate new centres (such as Hardwick) as a result of additional housing growth. Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

8. CONCLUSION
8.1 Wallace Land Investments are actively pursuing land promotion opportunities across the Black
Country. Wallace fully support the Black Country Authorities' decision to review the currently adopted Core Strategy.
8.2 It is clear that there will be a need for Green Belt release to accommodate the housing needs of both the Black Country and indeed the overspill needs of Birmingham. There will therefore be a clear switch from the adopted Core Strategy focusing on development within the urban area, to exploring sustainable opportunities outside of the existing urban area.
8.3 Wallace are of the view that the evidently large housing needs of the Black Country can and should be partly delivered on sites suitable for Green Belt release.
8.4 Wallace look forward to future opportunities to engage with the Black Country Authorities to identify suitable sites for allocation in the emerging Core Strategy Review, in order to ensure that future housing needs will be met.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2783

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 In respect of the Strategic Market Assessment for the Black Country and South Staffordshire Richborough Estates would wish to raise the following key comments:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In respect of the Housing Background Report, Richborough Estates would wish to make the following key comments:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
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.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
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?
5.6 No comment

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?
5.7 No comment.
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No;
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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).
5.11 Richborough Estates considers that land at Pedmore Lane, Stourbridge should be considered. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability. This site would represent sustainable options for meeting housing needs arising from within the Black Country.
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.
5.12 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.13 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.14 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.15 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.16 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.17 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.18 No comment.
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?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.20 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.21 Even if all realistically deliverable options have been considered within the Black Country, there will remain an unmet need for housing. Therefore, it is necessary for the Black Country authorities to consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.22 Richborough Estates considers there are a number of locations within South Staffordshire that provide geographically strong links with the Black Country and would represent sustainable housing sites. This includes land at Sneyd Lane, Essington and land at High Hill, Essington. A call for sites submission has been undertaken in respect of these sites to demonstrate availability, suitability and deliverability. These sites would represent sustainable options for meeting housing needs arising from within the Black Country.
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.
5.23 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.24 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.25 No comment
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.26 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.27 No comment
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.28 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.29 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.30 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. Indeed, there is likely to be a significant growth in the need for logistics floorspace to accommodate rapid increases in the dot.com purchasing of goods and demand for next day delivery. Efficient access to motorway junctions and the strategic road network and the availability of large sites will therefore take priority, as well as other considerations such as the ability to operate 24 hours. Placing such sites directly next to the existing urban area may therefore be impractical. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.31 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 Richborough Estates is in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. Richborough Estates is committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
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.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
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?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

8. CONCLUSION
8.1 Richborough Estates has acquired an interest in a number of sites either within the Black Country or within neighbouring authority areas that are geographically well related to the Major Urban Area. All sites are sustainably located adjacent to the existing urban area as demonstrated on the appended Site Location Plans.
8.2 These sites are promoted as suitable, deliverable and available options, subject to release from the Green Belt. The development of these sites would constitute sustainable development and would assist in meeting housing needs arising within the Black Country and the wider Greater Birmingham Housing Market Area.
8.3 Richborough Estates fully support the Black Country Authorities' decision to review the currently adopted Core Strategy, however wish to raise the following concerns:
* Whilst the OAN is generally appropriate as a starting point, a number of concerns have been identified with the SHMA and it is recommended that it is updated to address the issues raised. Further, evidence is awaited with regard to unmet need in the wider HMA. Once this has been concluded, the Black Country authorities can arrive at an appropriate dwelling requirement for the Black Country.
* It is acknowledged that the housing land supply in the Black Country has not yet been identified as the authorities need to undertake further work upon receiving the Call for Sites submissions. After which, the shortfall in housing supply can be confirmed.
* It is welcomed that the Black Country authorities acknowledge the need to remove land from the Green Belt to meet emerging development requirements and that a Green Belt Review is soon to be prepared.
* In terms of selecting sites for development, it is advised that a range of types sites, of different sizes, in different locations need to be identified to be in the best possible position to deliver the dwelling requirements.
* Land at: Pedmore Lane, Stourbrige; Sneyd Lane, Essington; and High Hill, Essington, represent appropriate locations for residential development as supported by the Call for Sites submissions.
8.4 Richborough Estates look forward to engaging with the Black Country Authorities and providing additional information, as required, to assist the Council in progressing the preparation of an up to date Local Plan.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 3088

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 In respect of the Strategic Market Assessment for the Black Country and South Staffordshire the Palmers Cross Consortium would wish to raise the following key comments:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In respect of the Housing Background Report, the Palmers Cross Consortium would wish to make the following key comments:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
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.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
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?
5.6 No comment

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?
5.7 No comment.
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No;
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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.
5.10 No comment
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).
5.11 No comment
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.
5.12 The Palmers Cross Consortium considers that land West of Codsall Road, Palmers Cross, should be considered as a new SUE. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability. This site would represent sustainable options for meeting housing needs arising from within the Black Country.
5.13 However, given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.14 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.15 As stated previously, The Palmers Cross Consortium considers that land west of Codsall Road, Palmers Cross, should be considered as a new SUE. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability.
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?
5.16 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.17 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.18 Even if all realistically deliverable options have been considered within the Black Country, there will remain an unmet need for housing. Therefore, it is necessary for the Black Country authorities to consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.19 The Palmers Cross Consortium considers that land west of Codsall Road, whilst in South Staffordshire District, has a geographically strong link with the Black Country and would represent a sustainable housing site. A call for sites submission has been undertaken in respect of these sites to demonstrate availability, suitability and deliverability. These sites would represent sustainable options for meeting housing needs arising from within the Black Country.
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.
5.20 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.21 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.22 No comment
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.23 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.24 No comment
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.25 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.26 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.27 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.28 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 The Palmers Cross Consortium is in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. The Palmers Cross Consortium is committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
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.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
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?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

8. LAND WEST OF CODSALL ROAD, PALMERS CROSS
8.1 The Palmers Cross Consortium are collectively in control of land known as Land West of Codsall Road, Palmers Cross, as shown on the Site Location Plan appended to this representation (Appendix 1). The site comprises approximately 23.17 hectares and is currently in agricultural use and is currently accessed from Codsall Road to the east.
8.2 This land represents a logical and sustainable extension to the existing urban area that provides an opportunity for delivering approximately 500 new homes with associated supporting infrastructure, as shown on the Illustrative Masterplan included at Appendix 2 of this Representation. The Illustrative Masterplan introduces an initial proposal, providing an indication of how the site could be delivered and function as a natural sustainable, urban extension, having regard to the landscape strategy (Appendix 3).
8.3 There are no significant physical features which would prevent the development coming forward. There are, however, a number of physical features which serve to shape the development shown on the Illustrative Masterplan, including existing hedgerow boundaries and existing public footpaths. Furthermore, a Grade II Listed structure (sewer ventilation pipe) is located immediately opposite the site on Codsall Road. This structure is set within the context of existing residential development and, as such, would not be subject to harm through the development of the site. 8.4 The Illustrative Masterplan identifies the following key features:
* Provision of up to 500 dwellings;
* Two points of vehicular access proposed via Codsall Road;
* Existing on-site public footpath incorporated into new streets and green infrastructure (no diversions proposed);
* Existing treed frontage to be retained;
* New pedestrian footpath network joining with existing public footpaths;
* Linear housing frontage replicating contextual characteristics;
* Low density housing patterns with verdant plots (drawing on character of Links Avenue);
* Landscaped edge, retaining existing trees and hedgerow as new Green Belt boundary;
* Site low point for sustainable drainage; and
* Equipped children's play spaces (LEAP/LAP).
8.5 To date, a range of high level technical work has been undertaken in respect of the site. This indicates that there are no constraints which would preclude development, including environmental or heritage constraints. This technical work has informed an illustrative masterplan for the site, that is attached at Appendix 2 to this representation.
Sustainability
8.6 The site is sustainably located immediately adjacent to the major built up area of Wolverhampton. In terms of services, Palmer's Cross Primary School is located approximately 230m to the east of the site, whilst Aldersley High School is located approximately 750m to the north east. A local shopping parade exists on Pendeford Avenue, approximately 600m south-east of the site, which includes a Co-op, Post Office, butchers, takeaways, hardware store, card/gifts shop, hairdressers and dental practice. A number of other shopping opportunities existing in nearby Codsall and the City of Wolverhampton.
8.7 The site is therefore well sustainably located in terms of access to local facilities and services.
8.8 In terms of public transport, the number 5/5A bus service runs along Codsall Road (with stops immediately opposite the site) connecting Wolverhampton with Codsall Town Centre. These services begin at approximately 6:00 and end at 23:30 in both directions, running at 20-30 minute intervals throughout the day. Regarding rail services, the site is located approximately 1.5km away from Bilbrook Station, with services running between Birmingham, Shrewsbury and Wolverhampton at approximately hourly intervals.
8.9 The site therefore benefits from significant and genuine opportunities to utilise transport modes other than the private car.
Demonstrating Deliverability
8.10 Footnote 11 to Paragraph 47 of the NPPF states that in order to be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. The paragraphs below demonstrate how the site is suitable, available and achievable to accommodate residential development.
Availability
8.11 As a collection of landowners, the Palmers Cross Consortium has demonstrated, through the submission of this site through the Call for Sites consultation, that they are supportive of the development of the site to deliver much needed new homes.
8.12 As such, this call for sites submission confirms that there is nothing to prevent this site from being delivered immediately upon its removal from the Green Belt and the receipt of the necessary consents. The site can therefore be considered to be available.
Suitability
8.13 Despite its location in South Staffordshire District, the site is geographically located immediately adjacent to the Wolverhampton conurbation. The site benefits from a highly sustainable location and is therefore well placed to meet the current and future development needs of the Black Country area.
8.14 As identified above, the site is well served by public transport and a number of local services and facilities are within a short walking distance or short public transport journey from the site. The site would therefore be well placed to ensure that future residents would have excellent sustainable access to a diverse range of services and facilities, representing an opportunity to deliver a cohesive, sustainable community that acts as a natural urban extension to Wolverhampton and the wider Black Country.
8.15 The site is located within an area surrounded by residential land use to the east and south-east. Whilst the site is located in the Green Belt, its development would not result in encroachment towards Codsall beyond the established edge of the Wolverhampton conurbation (as defined by Coniston Road to the north-east). Given the above it is respectfully suggested that the site be considered to be suitable for development.
Achievability
8.16 The site is located within Flood Zone 1, the area at lowest risk from flooding. A Grade II Listed structure is located immediately opposite the site. The presence of this structure would be carefully considered when drawing up proposals for the site. However, the presence of this structure does not preclude development.
8.17 It is not known at this stage whether any of the trees on site are subject to a tree preservation order, however, the site is not located within a conservation area. There are no other known environmental or historical designations which affect the site.
8.18 In terms of access, new accesses would be required from Codsall Road, subject to detailed highways assessments.
8.19 The site is therefore not subject to any major physical constraints which would prevent development from being achieved.
Green Belt
8.20 As noted above, the site is located within the Green Belt. It is understood that a Green Belt Review is being progressed at the Greater Birmingham Housing Market Area level in conjunction with the Black Country Core Strategy Review.
8.21 A brief assessment of the site against the five purposes of the Green Belt as set out within NPPF is included below.
Checking the Unrestricted Sprawl of Large Built-Up Areas
8.22 Whilst it can be argued that the development of the site would result in the sprawl of the built area of Wolverhampton, the same can be said for any site released from the Green Belt for residential development. It remains that there is an overwhelming housing need within the GBHMA which can only be met through Green Belt release adjacent to the existing conurbation.
Preventing Neighbouring Towns Merging into One Another
8.23 The existing edge of the Wolverhampton conurbation runs parallel with the northern boundary of the site. As such, the development of the site would not diminish the existing separation distance between the Black Country conurbation and Codsall. A Green Belt buffer beyond the site would remain along Codsall Road to prevent merging of Codsall with the urban area.
Assisting in Safeguarding the Countryside from Encroachment
8.24 Similarly, whilst it can be argued that the development of the site would result in encroachment into the countryside, the same can be said for all sites located within the Green Belt. It remains that the surrounding land uses are predominantly residential and therefore the release of the site would not result in significant encroachment into the countryside.
Preserving the Setting and Special Character of Historic Towns
8.25 The site is not located in a conservation area and there is only one Listed Structure in the vicinity of the site. Whilst Wolverhampton is undeniably an historic City, this history is predominantly based within the City centre, rather than the edge of the conurbation. As such, the release of this site from the Green Belt will not impact upon the setting and special character of historic towns.
Assisting in Urban Regeneration by Encouraging the Recycling of Derelict and Other Urban Land
8.26 It is recognised through the Core Strategy Review that there is a deficiency of suitable brownfield sites to accommodate the prevailing housing need. As such, the release of this site from the Green Belt would not prejudice the recycling and redevelopment of urban land.
9. CONCLUSION
9.1 The Palmers Cross Consortium collectively have an interest in the land known as Land West of Codsall Road, Palmers Cross. Whilst the site is within South Staffordshire District, it shares a sustainable, functional relationship with the Wolverhampton conurbation, as shown on the appended Site Location Plan.
9.2 The site is as promoted as suitable, deliverable and available, subject to its release from the Green Belt. The development of the site would constitute sustainable development and would assist in meeting housing needs arising within the Black Country and the wider Greater Birmingham Housing Market Area.
9.3 The Palmers Cross Consortium fully support the Black Country Authorities' decision to review the currently adopted Core Strategy, however wish to raise the following concerns:
* Whilst the OAN is generally appropriate as a starting point, a number of concerns have been identified with the SHMA and it is recommended that it is updated to address the issues raised. Further, evidence is awaited with regard to unmet need in the wider HMA. Once this has been concluded, the Black Country authorities can arrive at an appropriate dwelling requirement for the Black Country.
* It is acknowledged that the housing land supply in the Black Country has not yet been identified as the authorities need to undertake further work upon receiving the Call for Sites submissions. After which, the shortfall in housing supply can be confirmed.
* It is welcomed that the Black Country authorities acknowledge the need to remove land from the Green Belt to meet emerging development requirements and that a Green Belt Review is soon to be prepared.
* In terms of selecting sites for development, it is advised that a range of types sites, of different sizes, in different locations need to be identified to be in the best possible position to deliver the dwelling requirements.
* Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Palmers Cross Consortium, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District.
* Land West of Codsall Road, Wolverhampton, represents an appropriate location for a new SUE as supported by the Call for Sites submission.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 3145

Received: 08/09/2017

Respondent: Taylor Wimpey

Agent: Pegasus Group

Representation Summary:

7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.

Full text:

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?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the Objectively Assessed Housing Need (OAHN) has been undertaken by Lichfields on behalf of Taylor Wimpey (Appendix 2) which identifies the following conclusions:
* 3,545 dpa equates to the 2014-based SNHP. With suitable adjustments to include an allowance for second/vacant homes; the latest 2016 MYE; and necessary adjustments being made to headship rates in the younger age categories, this would generate a need for 4,077 dpa. Factoring in long term migration rates would increase this further to 4,201 dpa (4,057 dpa without South Staffordshire). It is considered that this represents the suitable demographic starting point for the Black Country HMA.
* A modest worsening of some market signals and consistent under-delivery of housing in the Black Country HMA suggests the need to improve affordability to stabilise increasing house prices and high affordability ratios. This would justify an uplift to the figures over and above the level suggested by the demographic projections. The Practice Guidance23 states that this should be set at a level which could be reasonably expected to improve affordability. A modest 10% uplift is considered appropriate in this instance. Applying this level of uplift to the demographic starting point would indicate a minimum demographic OAHN of 4,622 dpa (4,462 dpa without South Staffordshire).
* The scale of affordable housing needs, when considered as a proportion of market housing delivery, implies higher levels of need over and above the OAHN figure for Dudley and South Staffordshire. It is considered that to make a meaningful contribution to addressing the level of affordable housing need identified by the SHMA (770 dpa), a further 10% uplift should be applied. This would increase the OAHN to 4,692 dpa (4,518 dpa without South Staffordshire); significantly above the SHMA's proposed OAHN of 3,824 dpa and the CD proposed target of 3,554 dpa.
* In addition to the Black Country HMA's OAHN there is a need to accommodate Birmingham's unmet housing need. The CD proposes to accommodate 3,000 dwellings of Birmingham's needs up to 2031. However, a proportionate 'fair share' approach based on the population distribution across the wider HMA, and accounting for fixed commitments made by Solihull, North Warwickshire and Stratford on Avon, suggests that the Black Country HMA should accommodate up to 20,931 dwellings for the period to 2031 (19,107 without South Staffordshire). This equates to an additional 1,047 dpa above the OAHN, giving a revised OAHN of 4,692 dpa to 5,473 dpa (4,518 dpa to 5,473 dpa without South Staffordshire).
4.4 In addition, consideration of the Housing Background Report is also contained in set out below. Taylor Wimpey's comments are as follows:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
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
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
4.10 In respect of Green Belt, the two-stage approach of considering Green Belt, both locally and as part of the Greater Birmingham and Black Country HMA Strategic Growth Study, is supported by Taylor Wimpey.
4.11 Consideration of the Green Belt should identify Green Belt 'parcels' around the Black Country which do not fulfil Green Belt purposes as strongly as others. As part of this two-stage exercise, it will be important to have regard to proposals submitted through the call for sites process to ensure the parcels identified as fit for purpose.
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.
4.12 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.13 The dwelling requirements arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.14 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.15 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.16 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.17 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.18 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared.
4.19 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.20 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.21 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
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.
4.22 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030. The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis.
4.25 Growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
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?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
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?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised. These include:
* The need for the Core Strategy to continue to plan for a growing population
* The need to address the significant housing shortfall identified within the Black Country and the wider Housing Market Area, which will need to be considered through the Duty to Cooperate; and
* The urgency to look beyond the Growth Network in the short term in accommodating housing growth, which will inevitably require the release of land from the Green Belt to meet needs in the longer term.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
5.1 Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.2 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.3 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
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?
5.4 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.5 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
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?
5.6 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.7 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.
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?
5.8 No comment

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?
5.9 Taylor Wimpey wishes to emphasise the importance of selecting the most appropriate approach, given this will be the basis for the site allocations which emerge through the Core Strategy review.
5.10 Whilst there are opportunities and challenges presented by both Option 1A and 1B, Taylor Wimpey supports Option 1A as the appropriate approach for meeting housing needs.
5.11 Option 1A is considered to be more appropriate for accommodating the growth needs of the Black Country over the Plan period to 2036. There are many opportunities provided by this option, particularly that it can provide for a sustainable pattern of development, close to the urban edge of existing settlements, and close to where needs arises in the Black Country. This option would significantly boost the supply of housing land and help to meet the significant current and future identified need.
5.12 Option 1B is rejected by Taylor Wimpey. In accordance with previous comments and concerns raised in these representations, there are sufficient not opportunities to meet housing needs on brownfield land. As Option 1B would not have sufficient capacity to accommodate all future growth needs, it is entirely inappropriate for this to be the sole basis for a new Development Plan.
5.13 Other key challenges posed by Option 1B include the difficulty of delivering housing on brownfield land given the costs associated with site assembly and land remediation and that delivery on larger sites may be towards the latter years of the Plan period.
5.14 Option 1A would provide a more immediate response to the housing growth crisis within the Black Country and would cater for more rapid delivery of suitable sites.
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No;
5.15 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.16 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
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.
5.17 Please see response to Question 13a below.
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).
5.18 Please see response to Question 13a below.
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.
5.19 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.20 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.21 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.22 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.23 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.24 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.25 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
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?
5.26 Land off Linthouse Lane, Wolverhampton, should be considered as an available, suitable and deliverable location for growth, that would represent a logical Sustainable Urban Extension to the Major Urban Area. Further information is set out at Chapter 8 to these representations to evidence the site as a 'sound' locations to meet current and future housing needs arising within the Black Country and wider Greater Birmingham Housing Market Area.
5.27 It should be noted that an emerging proposal makes an allowance for the provision of infrastructure and Taylor Wimpey is committed to further dialogue with the relevant authorities and infrastructure providers to determine the infrastructure required to support the delivery of this proposed SUE..
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?
5.28 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.29 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
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?
5.30 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in both the Black Country and South Staffordshire) across authorities and, therefore, once all options within the HMA have been explored, these could help deliver growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.1 Land off Linthouse Lane, Wolverhampton, should be considered as an available, suitable and deliverable location for growth, that would represent a logical Sustainable Urban Extension to the Major Urban Area. Further information is set out at Chapter 8 to these representations to evidence the site as a 'sound' locations to meet current and future housing needs arising within the Black Country and wider Greater Birmingham Housing Market Area.
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.
5.2 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.3 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.4 No comment
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.5 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.6 No comment
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.7 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.8 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.9 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.10 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
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.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 Taylor Wimpey is in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that development of approximately 2,500 homes on land off Linthouse Lane will give rise to the need to deliver supporting infrastructure. Taylor Wimpey is committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
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.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
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.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
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?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
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?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
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
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
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?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
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.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
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.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: 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:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
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.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: 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.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: 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?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
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.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: 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.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
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.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.
8. LAND OFF LINTHOUSE LANE, WOLVERHAMPTON
8.1 Taylor Wimpey is currently in control of the land to the north of Linthouse Lane and to the south of the dismantled railway line as shown on the Site Location Plan appended to this representation (Appendix 1).
8.2 This land represents a logical and sustainable extension to the existing Major Urban Area that provides an opportunity for delivering approximately 2,500 new homes with associated supporting infrastructure.
8.3 As demonstrated on the attached Site and Contextual Analysis Plan (Appendix 3) there are no significant physical barriers to development. There are, however, a number of physical features which serve to shape the development shown on the illustrative masterplan. These include the power lines which traverse the site in a north-west to south-east direction as well as the localised topography of the site, existing vegetation and public rights of way.
8.4 An illustrative masterplan (Appendix 4) has been prepared to introduce an initial proposal, providing an indication of how the site could be delivered and function as a natural sustainable, urban extension to Wolverhampton. This includes a 20m offset to the existing power lines, retention of the existing public rights of way and vegetation.
8.5 The Illustrative Masterplan identifies the following key features for land to the north of Linthouse Lane on land where Taylor Wimpey has secured an interest:
* Circa. 2,500 dwellings;
* Provision of land for the delivery of a number of potential community uses, including the provision of a new Primary School;
* Significant provision of Green Infrastructure to include a landscape mitigation strategy;
* Provision of SuDS through the delivery of new attenuation features; and
* A new enduring Green Belt boundary defined by the route of the dismantled railway line.
8.6 Further consideration of the site is set out below having regard to the Council's evidence base and the technical information prepared on behalf of Taylor Wimpey to date. This analysis concludes that land to the north of Linthouse Lane, within the control of Taylor Wimpey, is both suitable and deliverable and would represent a 'sound' location for meeting housing needs within the Black Country to 2036.
Landscape Sensitivity
8.7 Pegasus Environment has undertaken a Preliminary Landscape and Visual Appraisal (LVA) to the determine the various landscape and visual constraints and opportunities of the wider site area and its context. This includes how these factors might serve to influence the potential for development in respect of an illustrative masterplan, and to influence an inherent landscape strategy as part of that masterplan.
8.8 The local landscape context comprises the wider pattern of agricultural land to the north, the topography of which is generally falling to the south towards the site, from a localised ridgeline between Essington and Westcroft. The site is located on gently sloping land between ca. +170m AOD and ca. +145m AOD. To the south, the existing settlement edge of Wolverhampton provides a townscape setting to the site and there are some near distance views into the site from this edge. Longer distance views towards the site are available from the southern edge of Essington and from higher ground to the north. The site is currently included as part of the West Midlands Green Belt. There are no landscape specific designations which cover the site or the immediate area.
8.9 The LVA identifies the key constraints and opportunities present in the site and surrounding landscape, and also the nature of the likely impacts that may arise from the proposed development. The LVA has analysed the baseline information in the context of the proposed development and has informed the proposals for landscape mitigation.
8.10 The development consequently incorporates a landscape mitigation strategy which will avoid, reduce or remedy adverse impacts. The development of the illustrative masterplan has been informed by an initial appraisal of the local landscape and visual constraints and opportunities. As such, the illustrative masterplan:
* Addresses near distance views from the edge of Essington across the Green Belt 'gap' between Essington and the edge of Wolverhampton, to maintain separation and deal with potential 'coalescence' issues;
* Includes a set-back of the development envelope away from the more elevated area of the site to the north-east;
* Utilises the well-vegetated dismantled railway line as a new Green Belt boundary;
* Provides a central linear open space in response to the offsets required to existing powerlines;
* Ensures an appropriate offset to the public right of way passing through the site along the existing hedgerow running north-south between Linthouse Lane and Blackhalve Lane; and
* Addresses longer distance views from the more elevated ground to the north by providing space for additional planting to strengthen the new Green Belt boundary in this location.
8.11 These over-arching principles set the framework for the areas which are proposed for development. Each of these can be subject to a greater level of detail regards masterplanning to identify constraints and opportunities at a more detailed level.
Ecology
8.12 Technical work has been undertaken by the Environmental Development Partnership Ltd to guide initial proposals on land off Linthouse Lane having regard to ecological sensitivities pertaining to the site, and identifying opportunities and constraints which may influence development.
8.13 The study confirmed that there are no statutorily designated nature conservation sites within the red line boundary shown at Appendix 1, however, there is a Special Area of Conservation (SAC) of European importance within 10km and two Local Nature Reserves (LNRs) of local importance within 2km.
8.14 Cannock Extension Canal SAC lies 6.3km northeast of the site and contains good water quality supporting floating water plantain and a diverse dragonfly and damselfly assemblage. Identified threats to the quality of this SAC that could occur are: pollution to groundwater, air pollution, air-borne pollutants and invasive non-native species.
8.15 Due to the spatial separation of the SAC from land off Linthouse Lane, it is unlikely that the proposed development would result in any of the identified threats to the SAC arising.
8.16 Rough Wood Chase LNR lies 2km east of the site. There is no ecological connectivity to this woodland and wetland area, being separated from land off Linthouse Lane by the M6. In addition, there is no hydrological connectivity. The proposal is not considered to have a potential impact on this LNR.
8.17 Waddens Brook LNR lies 2km south of land off Linthouse Lane and is regionally important for its great crested newt population and populations of other amphibians. As there is no hydrological or ecological connection netween the LNR and the site and the 2km of separation contains residential development and and Wyrley and Essington Canal, the proposal is not considered to have a potential impact on this LNR.
8.18 Land off Linthouse Lane is not covered by any non-statutory designations, however there are a number of non-statutory sites within 2km of the boundary. With the exception of Ashmore Lodge Biodiversity Alert Site (BAS) and Oakley Farm Potential Site of Importance (PSI), the nature of the designation of each site and the intervening distance means that a potential impact on them from the proposed development is unlikely.
8.19 Oakley Farm is designated due to the presence of field margins on historic maps. During the Extended Phase 2 Survey, no habitats of importance were noted, with the grassland and hedgerows being species poor. Therefore, in ecological terms, development in this area would not result in a significant loss in biodiversity either within the proposal site or within the PSI at Oakley Farm.
8.20 Ashmore Lodge is the dismantled railway which runs through the proposed site. A majority of this dismantled line is lined with trees with some parts covered in semi-improved grassland, providing a linear feature of local ecological value. The proposal offers the opportunity to include:
* Additional planting of native tree species;
* Creation of diverse wildflower meadows in open areas on the line and in the buffer to this line; and
* Removal of the giant hogweed by an experienced and qualified contractor.
8.21 If these opportunities were delivered, this would ensure no significant impacts would occur on any of the non-statutory designations within the p0otential zone of influence of the site and may result in an overall enhancement in line with local and national policy.
8.22 The remaining habitats within the site are predominantly of low intrinsic ecological value and present good opportunities for enhancement. They are not a constraint to development capacity in their own right, but have the potential to support protected species.
8.23 The possible presence of breeding birds, bats and great crested newts will need to be determined through further surveys, however, it is considered that, even if these protected species were found to be present, the populations could easily be safeguarded through sensitive scheme design and appropriate mitigation measures, and would not represent an 'in principle' constraint to development.
8.24 The initial technical work considers the site provides sufficient flexibility to ensure compliance with planning policy at all levels and to avoid 'significant harm' to biodiversity. Furthermore, a sensitively designed development incorporating appropriate mitigation and enhancement has the potential to deliver a significant net gain in biodiversity.
Heritage & Archaeology
8.25 An archaeological and heritage assessment has been prepared by Environmental Dimension Partnership Ltd to inform the proposal and to assess the potential effects arising from development within the site.
8.26 The report confirms that the site does not contain any designated heritage assets such as world heritage sites, scheduled monuments, registered parks and gardens, registered battlefields or listed buildings, where there would be a presumption in favour of their physical preservation in situ and against development.
8.27 Only one potentially sensitive designated heritage asset has been identified outside of the site. This is the scheduled ancient monument of Moat Farm moated site, which lies some 160m north of the site, to the north of Blackhalve Lane. The assessment concluded that whilst there is some potential for a low level of harm to the heritage significance of the monument through the change to its setting, this would need to be weighed against the public benefit of the proposed development, with harm being further mitigated through the detailed design of any proposal.
8.28 There are no listed buildings or other designated heritage assets in close proximity to the site, although there are a number of listed and locally listed buildings in the wider area. The assessment concludes that no opportunity for harm to these or any other heritage assets outside of the site is predicted as a result of development at land off Linthouse Lane.
8.29 The archaeological potential of the site is assessed as being low. Should any below ground archaeological remains survive, there is no reason to believe or expect that the site will contain archaeology of such significance that it would require preservation in situ and therefore constrain development of the site. The site has been intensively farmed and if any below ground deposits are found, they are likely to be poorly preserved due to this agricultural activity, thereby reducing their significance.
Highways and Transportation
8.30 The site is well placed in terms of accessibility to existing pedestrian and public transport networks. The site is also located in close proximity to local facilities including shopping, medical services and education facilities.
8.31 There are good public transport links in the area, with 7 two way buses per hour operating along Linthouse Lane and Cannock Road on a weekday and Saturday and, 4 two way buses per hour operating on a Sunday.
8.32 Travel by rail is achievable as part of a multi-modal trip i.e. park and ride and cycle and ride. There are hourly services to local destinations including Birmingham New Street which provides onward travel opportunity to destinations across the country.
8.33 Access to the site can be achieved from the surrounding highway network, including Linthouse Lane, Blackhalve Lane, Cannock Road and Kitchen Lane. towards the south-western end of the site. There are a number of options and significant potential in terms of achieving safe, controlled and appropriate vehicular access to the site.
8.34 The Illustrative Masterplan identifies the following access points, but it should be noted that these are not necessarily exclusive locations:
* Proposed vehicular access via Linthouse Lane;
* Proposed vehicular access via Kitchen Lane;
* Proposed vehicular access via Blackhalve Lane;
* Proposed vehicular access via Cannock Road; and
* Proposed change of priority along Wood Hayes Road through the introduction of a new junction providing east west vehicular connectivity.
8.35 The illustrative masterplan also identifies the incorporation of existing Public Rights of Way (PRoW) within green corridors and proposes a network of new primary pedestrian routes maximising opportunities to create sustainable transport links (walking and cycling) to existing and potential new amenities and facilities.
8.36 In the longer term, to support a planning application, a Transport Assessment will be completed to assess impacts across the wider network, this will include speed survey work. The Transport Assessment will take account of any local committed development sites and any committed highway improvements. Suitable mitigation will be provided as part of the development proposals including any identified off site highway works and contributions.
Flood Risk and Drainage
8.37 The site lies in Flood Zone 1, the area at least risk from flooding.
8.38 Surface water drainage is proposed to be accommodated through the provision of a series of balancing ponds located around the site. The Illustrative Masterplan, included at Appendix 4, identifies the provision of balancing ponds through a network of green infrastructure.
Noise & Air Quality
8.39 Noise is unlikely to be a significant issue for the proposed development, however it is likely to have some impact on the form of any proposal. The northern boundary of the site lies adjacent to Blackhalve Lane (B4156), which also passes through part of the site. The eastern boundary is adjacent to Essington Rugby Club and Kitchen Lane. The southern boundary is adjacent to Linthouse Lane and the western boundary is bounded by properties off Woodent Road and Cannock Road.
8.40 It should be noted that landscaping would be included throughout the development in conjunction with carefully orientated and sited dwellings and associated gardens to minimise noise impact and preserve residential amenity.
8.41 Consequently, it is unlikely noise will have a significant adverse impact on the development of this site.
Ground Conditions
8.42 A full Phase 1 Environmental Risk Assessment has been completed for the site. The British Geological Map for the area indicates the site is underlain by superficial deposits of Glacial Till (variable but predominantly cohesive strata), which overlay solid strata that vary across the site.
8.43 The Phase I Environmental Risk Assessment for the site has been undertaken which identifies that it is unlikely that the site would be classified as contaminated land.
Utilities
8.44 Sewers are present in the vicinity of the site, including within the southern verge of Kitchen Lane, residential streets to the west of the site, within the eastern verge of Wood Hayes Road and along Blackhalve Lane. Accordingly, diversions are likely to be required in order to connect the site to the network. Whilst no sewers are located within the site, surface water outfalls into the watercourse along the western boundary are noted and a foul sewer is located to the west of the watercourse.
8.45 It is envisaged that foul flows from the land to the north of Blackhalve Lane could drain via gravity to an existing foul sewer located within Wood Hayes Road or to that which exists within Blackhalve Lane. Land to the south of Blackhalve Lane has the potential to drain via gravity to a number of the public foul sewers located within Linthouse Lane.
8.46 Similarly, water mains are present in the vicinity of the site, including the northern verge of Kitchen Lane, the northern verge of Linthouse Lane, the western verge of Wood Hayes Road and Blackhalve Lane and therefore diversions are likely to be required. No water mains are located within the development area.
8.47 Further discussion with Severn Trent Water will determine suitable connection points and capacity within the network.
8.48 Regarding electricity cables, gas mains and phone lines, no apparatus is present within the development area. As a result, diversions will again be required.
8.49 The capacity of all of these utilities need to be determined but are unlikely to present any issues of deliverability in respect of the site.
Agricultural Land Classification
8.50 Natural England's Land Classification Map for the West Midlands Region (ALC004) shows that the majority of the site comprises undefined Grade 3 'Good to Moderate' quality agricultural land. It is noted that the majority of land around Wolverhampton and the wider Black Country urban area also comprises Grade 2 and 3 agricultural land.
8.70 Whilst it is acknowledged that the loss of any best and most versatile land is undesirable, the majority of the site comprises Grade 3 land, and that the scale of development required to support needs arising within the Black Country will necessitate the loss of an amount of Grade 3 land or better under any reasonable option.
Suitability
8.71 The information set out above, read in conjunction with the appended illustrative masterplan, demonstrates that land off Linthouse Lane is a suitable site.
Deliverability
8.72 There is an agreement in place between the landowner and Taylor Wimpey to facilitate the development of the site.
8.73 A considerable amount of technical work has been undertaken to demonstrate the deliverability of land off Linthouse Lane. Taylor Wimpey can confirm that this work concludes that there are no physical or other constraints likely to render the site undeliverable within the proposed Plan period to 2036. The site is available now.
8.74 There are no existing uses that would require relocation and no issues of contamination that would require remediation. Many of the potential impacts of the development of the site can be mitigated through design and in many cases a positive outcome can be achieved, such as the strengthening of Wolverhampton's north eastern boundary through landscaping and utilisation of the dismantled railway line as an enduring new Green Belt boundary.
8.75 The site is deliverable and immediately available and, subject to allocation and removal of the land from the Green Belt, could start to deliver homes and associated community benefits within the next 5 years.
9. CONCLUSION
9.1 Taylor Wimpey is in control of land at Linthouse Lane, Wolverhampton. The land is sustainably located adjacent to the existing urban area of Wolverhampton.
9.2 Land off Linthouse Lane is promoted as a suitable, deliverable and available site, subject to its release from the Green Belt. The development of the site would constitute sustainable development.
9.3 Taylor Wimpey fully support the Black Country Authorities decision to review the currently adopted Core Strategy, however wish to raise the following concerns:
* The Black Country Core Strategy Review consultation document significantly underestimate the level of housing needed to support future population growth within the Black Country. An independent assessment of OAHN undertaken by Lichfields indicates that the actual need is 4,692 to 5,473 dpa. This is based upon the high levels of migration seen in the Black Country over the long term, the need to adjust household formation rates for younger age cohorts, and an uplift to reflect market signals on house prices, affordability and concealed families. Additionally, the OAHN range includes an allowance of up to 955 dpa to accommodate Birmingham's unmet need, based on the Black Country's proportionate 'fair share'.
* The scale of the housing required in the Black Country and GBHMA, along with the lack of sufficient land outwith the Green Belt constitutes the necessary 'exceptional circumstances' to justify that Green Belt land should be released for housing. The Council therefore needs to provide a sound evidence base which is robust in demonstrating the 'exceptional circumstances case'.
* 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 objectively assessed housing needs over the course of the Plan period. This should include consideration of land within South Staffordshire District.
* Informed by this process, sufficient Green Belt land should be released and allocated for housing development to meet the needs of the Black Country and GBHMA.
* Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District..
9.4 Taylor Wimpey look forward to engaging with the Black Country Authorities and providing additional information, as required, to assist the Council in progressing the preparation of an up to date Local Plan.