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 devel

The definition of healthcare facilities covered by Policy HOU5 should be extended to explicitly include the provision of multi-functional greenspace to allow healthy lifestyle choices as identified in section 6.11 of this report.

Yes - Pubs should be considered built social infrastructure and would certainly count as "community meeting places." Community pubs promote social inclusion, help combat social isolation (the Local Government Association has cited loneliness as a major public health issue) and research from Oxford University, "Friends on Tap," has shown that people with a "local" pub are happier, are more satisfied with their life and have a wider network of friends

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investment market ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investment market ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investment market ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

The definition of healthcare facilities covered by Policy HOU5 should be extended to explicitly include the provision of multifunctional greenspace to allow healthy lifestyle choices as identified in section 6.11 of this report.

Dear Sirs

RE: Black Country Core Strategy-Issues and Options Report (June 2017)
We represent the West Midlands HARP Planning Consortium which includes all the leading Housing Associations Registered Providers (HARPs) across the West Midlands. Our clients' principal concerns are to optimise the provision of social/affordable housing and to ensure the evolution and preparation of consistent policies throughout the region.

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review?

In the context of a limited supply of brownfield and other opportunities within the existing Black Country Core Strategy area to accommodate substantial housing development we welcome the proposal to release some land from the Green Belt. By undertaking a thorough review of Green Belt opportunities and constraints the Council will be meeting the NPPF requirement to promote sustainable patterns of development.

Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy?

Should the Council introduce a policy approach towards self and custom build housing, any requirement should not be in place of traditional affordable housing requirements. Self and custom build has complex requirements for funding and as such is out of the reach of most households who seek affordable housing. Self and custom build is also not within the affordable housing definition of the NPPF. Any policy requirement should be fully tested in terms of its viability when assessed alongside all other policy requirements to ensure that any requirement will not result in affordable housing being reduced on viability grounds.

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

Paragraph 158 of the National Planning Policy Framework (NPPF) requires local planning authorities Local Plan to be based upon adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics of the area. The Council's own evidence document, the Strategic Housing Market Assessment Part 2-Objectively Assessed Need for Affordable Housing (June 2017) (SHMA) states that the authority should aim for 28.6% of new housing to be affordable housing (this figure includes starter homes).

Paragraph 47 of the NPPF clearly sets out the Government's aim to "boost significantly the supply of housing". To achieve higher housing supply local authorities should:

"use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area".
There is a wealth of evidence to demonstrate that there is a national housing crisis in the UK affecting many millions of people who are unable to access suitable accommodation to meet their housing needs.

Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?

With regards to Question 49a, we would encourage the Council to consider the wording of paragraph 22 of the NPPF which asserts that:

"Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities."

Employment land has not been designated in perpetuity so if suitable and more practical uses are available we suggest that the Council takes this into consideration, via a more flexible policy; this will ensure that the Local Plan is in accordance with national policy and therefore passes the tests it will be assessed against in order to be found 'sound' at the eventual examination.

Other comments

The SHMA is clear on the increase in need for all tenures, of all sizes. In translating these needs into suitable policies the Council should look to involve Housing Associations as far as possible in setting a local definition of affordable housing that will encourage delivery of all affordable housing types. As the presumption should always be in favour of on-site affordable housing delivery, the preference for early engagement with local Housing Associations should be emphasised in the Plan policies.

The Council's SHMA highlighted a need for 162 new sheltered and extra care homes every year to meet the needs of the ageing population however there is no policy on older peoples housing within the document. We are of the opinion that a separate policy is needed to fully represent the needs of housing and care for older people.

Example policy wording is:

"Care, Continuing Care Retirement Communities and Extra Care Housing
The Council will, through the identification of sites and/or granting of planning consents, provide for the development of residential care homes, nursing homes, close care, extra care and assisted care housing, and Continuing Care Retirement Communities which encompass an integrated range of such provision.
In identifying sites and/or determining planning applications, regard will be had to:
* Commission for Social Care Inspection and other operational requirements;
* Locational sustainability. Suitable sites at defined settlements will be prioritised, but where such sites are not available regard will be had to the availability of public transport and the potential for developments to be self-contained, thereby reducing travel requirements;
* The potential to co-locate a nursing/residential care home and other care related accommodation on the site where there are demonstrated needs.
The Council will also work with its partners Dudley Metropolitan Borough Council, Sandwell Metropolitan Council, Walsall Council and the City of Wolverhampton Council and the relevant Primary Care Trusts in identifying suitable sites and securing the provision of schemes."

The above comments are intended to be constructive, to ensure the Local Plan is sound. We would like to be consulted on further stages of this document and other publications by the Council, by email only to consultation@tetlow-king.co.uk; please ensure that the West Midland HARP Planning Consortium are retained on the consultation database, with Tetlow King Planning listed as their agents.

Note: questions numbers are those in the full strategy document.
Question 2 Evidence
Housing
The Housing studies do not seem to adequately examine migration flows. In considering options for addressing any shortfall in housing supply, it would be helpful to have information on flows of migrants between the study area, Birmingham and other parts of the former west Midlands region. The Black Country receives many migrants from Birmingham but exports people to other areas including Telford and Shropshire. Thus there are important links to areas outside of the HMA. The EDNA contains useful analysis of commuting flows. indicating the wider area to which the Black Country relates.
The analysis should examine the age composition of different migration flows. Previous studies indicated that people moving from the Black Country into nearby areas tended to have higher proportions of families with children and be from higher paid backgrounds. Understanding of these flows will help to plan for house types and supporting facilities and transport that will be required if more development is needed in the Green Belt and beyond.
Much of the projected housing growth stems from net international migration; this is reflected directly in the ONS projections for the Black Country and also indirectly in the projected migration flows from Birmingham. This is a topic of great uncertainty. Flows since 2014 have been higher than in the ONS projections, but post-Brexit policies may reduce flows greatly. Given the scale of growth envisaged, some assessment of the range of uncertainty is required by sound planning.
Transport
The collection of evidence on traffic impacts should not just focus on peak flows into the major centres, given the dispersed pattern of employment across the Black Country and the increase in traffic associated with the school run. Traffic congestion is apparent through many parts of the Black Country and for longer periods of the day than in the past. Delays and pollution as key junctions should be monitored.
If new peripheral housing is proposed then the impacts on the whole network should be considered, not just in the vicinity of the proposed developments, as residents in existing built-up areas already
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suffer the effects of increasing congestion. Many residents of new developments will travel back into the Black Country and Birmingham for work and other purposes. For example, do you have any data on the effects of the development on the former Baggeridge site on peak flows on the already congested routes between Gospel End, Sedgley and into the Black Country?
Health
The effects of traffic and congestion and proximity to existing polluting industries health should also be examined.
Question 3: Housing Need
At this stage I would not wish to offer an opinion on methodology in relation to Government guidance. My view is that Government's requirements for methodology are flawed; it remains to be seen if the new standard method improves the situation.
The scale of housing need is very large but it is wise to have a strategy for the projected growth as this may be required in the longer term even if the projections are too high. However, I have two reservations about planning for this level of growth under current planning rules, which are naive, deterministic and inflexible.
Firstly, my experience as a user and producer of demographic, housing and employment information has shown the severe limitations of knowledge and the difficulties of forecasting the future with any precision or certainty. As to economic forecasts, it seems that even at national level, these amount to little more than guesswork even in the short-term. Forecasts can easily be revised, and often have been, and even information about past trends is recast (e.g. after the 2011 Census) . Long-term development decisions are not that easily undone, and the real impacts can be very large and enduring. The estimation of housing 'need' and the adoption of policies to meet that need should ideally be based on weighing evidence, taking account of its quality and reliability, against real impacts on the ground, together with an understanding of risks.
Secondly, a sensible planning system would provide long-term direction with flexibility and phasing to reflect changes in demographic trends and economic conditions. However, current planning rules are deterministic and inflexible. My concern with policies to meet the large projected housing growth is whether and how the release of a vast amount of greenfield land can be controlled without jeopardising the regeneration of the core Black Country. The focus on new development can lead to a failure to consider the implications for the economic, social and environmental interests and needs of most Black Country residents. Once Green Belt land is made available, it will be developed first unless strong phasing policies can be put in place.
Question 4. Employment Land Requirements
It is very important to allow scope for major employment developments. The i54 site is a good example of the benefits of long-term planning. That said, the amount of land proposed seems large in relation to what is likely to be achieved. My concern is that much land originally identified for industry or offices in the past has gone for some form of retail or more recently distribution: valuable land close to Motorway junctions has gone for retail or logistics. These uses are important but generate lots of traffic on strategic routes and provide jobs that are either low-paid or don't
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contribute much to the local economy. This may simply happen again if too much land is identified for industrial or office use.
I am also concerned about the seeming reluctance to tackle the undesirable legacy of the Black Country's long mining and industrial past (paragraph 3.9). This area's long and complex industrial history has left a juxtaposition of dirty, low value uses close to housing. Unless this is addressed, the area will not attract higher income residents, whose spending is vital to improving the local economy and its shopping and cultural facilities. Queen Victoria is supposed to have drawn the curtains as her train travelled between Brum and Wolverhampton; the view today is not so bad but the image that is presented to the millions who traverse the motorway, rail and canal routes through our area is far from appealing.
Other businesses thrive but are now badly located, making them less efficient and often generating traffic and environmental problems for local residents. I live near an oil-mixing plant that brings in tankers from across Europe. Unfortunately it is close to housing, quite noisy at night and a source of traffic congestion as the access is poor. It is also in a key canal-side location which could be an environmental and economic asset, being close to the major museums of the Black Country.
Given the amount of land that is being set aside for employment, it is important that a proportion is set aside for businesses that should relocate. This will include areas for 'dirty' uses.
Key Issue 5: Green Belt Review
If the required amount of development cannot be accommodated within the existing built up area, then some Green Belt Land will be needed. However, such a review should be undertaken as part of a wider investigation of options as peripheral development may not be the most desirable in terms of environment, sustainability and the well-being of the population.
The investigation should be wider in terms of
 geography - involving councils in Shropshire, Staffordshire and Worcestershire, as well as those in the Grater Birmingham HMA
 history - being informed by lessons from the past about new and expanded towns and peripheral developments on the edge of the conurbation.
 full impacts - not only on the immediate localities but also on the wider conurbation, for example through increased traffic flows back into employment and shopping areas.
 the proper role and value of the Green Belt - We live in the heart of the Black Country, but Green Belt allows us access to open countryside within about two miles of our house. It provides a breathing space, somewhere to walk and a visual relief from the congested and busy metropolitan area. Green Belt development would not affect my immediate living environment but it would make living where I am less desirable.
Question 6 Key Issues
No
Transport (or keeping the Black Country Connected).
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This fails to properly acknowledge the widespread problems of existing traffic congestion within the Black Country and on the national motorway routes. HS2 offer opportunities but also threats to the Black Country's rail connectivity. Congestion, coupled with the still poor environment in many areas is a barrier to building a more prosperous and liveable Black Country.
The plan needs to be informed by the Transport Strategy, but the large amounts of development will require the Transport Strategy to change. The scale of development envisaged will have major impacts on traffic flows across the whole area. It should not be assumed that the proposals in the Transport Strategy are all that will be required. The horse pulls the cart but the driver should be in charge of both.
Economy. The same point as for transport. The relationship with the economic strategy should be two-way. Planning is about balancing competing priorities. The economy, and aspirational economic strategies, can change rapidly - will the Midlands Engine still be working in 5 years time? The impacts of development and changes in the environment are more enduring.
Question7: Vision and principles
Agree that these values remain appropriate.
Question8: Spatial Objectives
1. Major centres. Trends in retailing and services have changed rapidly with the increased use of internet and direct delivery of goods and the decline in local banking and other public and commercial premise-based services. These add to the long-term challenges that have afflicted centres over previous decades. It is necessary to reappraise their role perhaps looking to increasing residential and leisure uses.
2. Employment is key but the emphasis on logistics may need to be reviewed and increased attention paid to innovative manufacturing. HGV drivers report and call at West Midlands' depots but they may live far away; manufacturing can provide well-paid jobs for local people.
8. Should include educational facilities at all levels. Sustain role of the universities and allow for expansion of schools to meet the growing child population ( a 26,000 increase 2014-2039 according to ONS).
9 and 10. Significant stocks of re-usable minerals and construction material will continue to become available through redevelopment of older sites. The recovery of this and conversion into new products or energy should take place within the Black Country, subject to environmental and health standards.
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Question 11
Neither, but 1B preferable. The strategies should commit to exploring sustainable options beyond the Green Belt as part of a major strategic review across a broader geography.
Release of existing employment sites: improve local amenity for nearby residents; do they suffer poor location and access in relation to nature and amount of vehicle movements; vacant for a long period; appearance.
Question 12A.
Some 'rounding off' may be acceptable but not supported as a major contributor to needs. This is a soft option, which is easiest to deliver for authorities and builders, but very unsatisfactory. Developers will build these sites first, unless strict phasing is imposed, and this will undermine regeneration and the more sustainable options.
Internal wedges can be very valuable in providing access to open space for a large number of residents. If land is released in this way, developments must be required to provide a substantial amount of accessible open space and footpaths to maintain and improve local amenity.
The cumulative wider impact on services and traffic locally and across a wider area would be large but would be difficult to relate to any specific development. This would create problems in securing developer contributions.
In reviewing the peripheral boundaries it is vital to consider the visual impact on the perception of sprawl and separation between settlements. The mere physical distance between built-up areas is not the sole criterion for assessing boundaries. In some cases it may be possible to allow expansion if new development is shielded by woodland etc. In other cases a proposed development might leave a physical gap, but through placement (e.g. on a ridge) may erode the perception of separation.
Question 13a
If Green Belt land is needed then this option could satisfy that need in part. Strategic infrastructure (transport) should be specified as should the employment content. Ideally should make provision for affordable housing, most realistically through shared ownership. Peripheral development in the Green Belt raises the same issues as mentioned in Question 15c and these should be assessed when considering such development.
This option should be assessed in parallel with consideration of sustainable developments outside the Black Country Green Belt - see question 15.
Question 14 The Black Country has large areas of low density housing developed during the period 1920-1950s and includes Social Housing, ex- Council housing bought through Right-to-Buy and privately built estates. Much of the housing is sound, but will deteriorate without maintenance and investment. Many owners struggle to maintain their properties and their often large gardens.
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Ultimately this issue will need to be addressed, possibly through redevelopment; the diversity of tenures will be a challenge. Selective redevelopment would offer the opportunity to improve housing conditions, save energy and increase densities. It may also allow the development of 'aspirational' housing for higher income householders. The viability and contribution of such redevelopment should be explored before large areas of greenfield land are developed.
Questions 15 The scope for 'exporting' growth to other sustainable locations beyond the Green Belt should be explored in parallel with the Green Belt Review to ensure that the most sustainable options are identified. However, the search should extend beyond the Greater Birmingham HMA as the Black Country relates strongly to areas in Staffs, Shropshire and Worcestershire.
In relation to question 15c, many rural areas face challenges in labour supply as their population ages; new housing can help and also take up spare capacity in schools etc. This may reduce the impacts on commuting of spreading development further. However, it may be necessary to also divert some employment development also to these areas, to avoid generating additional in-commuting.
A new settlement should be considered as part of this approach. To be viable and provide a good range of facilities it should aim for an eventual size roughly the same as Codsall, Penkridge or Wombourne. A possible location would be in a triangle north of the M54 and west of the M6. This is close to the Jaguar development and could be linked to regeneration and transport improvements, with Park and Ride, along the A449 into Wolverhampton
Questions 16-20 The strategy should provide a mix of locations to meet a diverse range of needs, so the preferred option should be a mix of the options.
Question 24 At a personal level we became aware of the pressure on local school places when we investigated moving our grandson and his mother into the Black Country; no primary places were available within reasonable travelling distance. A new local school has recently been built on a sports ground; this will create traffic problems on an already congested route. It is important that the plan identifies the amount of land needed for new facilities, such as schools, and specifies requirements in terms of access and parking. It may be easier to provide facilities in association with larger new housing developments, in which case housing mix should be designed for families with children.
Question 25 In considering peripheral developments, it will be important to consider any deficiencies in social etc provision within existing adjoining areas. In this way, new development can be 'sold' to existing residents affected by new developments.
Questions 26 and 27.
New developments offer the chance for micro-generation and efficiency in energy use. Guidance should be prepared to ensure that developments are designed with energy efficiency in mind.
Question 27 Paragraph 5.12 is incorrect in implying the current transport situation is satisfactory. The motorways are struggling, and any disruption, such as the current strengthening of the M5 viaducts, creates major problems for long-distance and local travellers. Traffic on local roads has grown greatly in the 10 years since I have lived here. The peak now extends from about 3.30pm to
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nearing 7pm. Only yesterday i had to travel from Tipton to Sedgely at 1615; a 2.5 mile journey too 25 minutes! Local roads can be near to gridlock at peak times.
Industrial traffic mingles with local traffic to the detriment of both. There are clear benefits to be had by providing sites closer to main roads, so that firms to can relocate while staying within the area.
The Birmingham-Wolverhampton railway runs at capacity and offers little opportunity to increase the frequency of services, particularly serving local stations.
Walking and cycling need to be encouraged but this be requires safe and convenient routes? I can cycle to the station in 4 minutes and walk in 10, but to do so I have to crossing several roads, only one of which is safe to cross.
The metro extension to Brierley Hill will be welcome but the area needs to follow the lead set by Greater Manchester and develop a proper network: for example extending south to Stourbridge Junction.
Question 30.
A thorny question! One approach might be to use affordability contributions from Green Belt sites to fund affordable housing in the built-up area. This might prove attractive to developers, but might also exacerbate social polarisation. Evidence on wider traffic impacts of peripheral developments might be used as a leaver for contributions to improvements on key transport corridors. In reality only a restrictive policy on greenfield development will secure urban regeneration.
Question 32.
Support the idea of HIAs
Question 33
Policies to improve the environment in existing built-up areas should take account of health benefits. Policies to address lifestyle-related problems should be addressed through policies that make walking and cycling more attractive. More restrictive policies on fast-food outlets are needed, although this is a bit late given the proliferation of existing outlets.
Question 34a.
Yes. The impact of new developments on existing residents should also be considered as part of the strategic review. Often the impacts of a new development are felt away from the site - most obviously through increased traffic on already congested roads. It would be useful also to have health impact assessments for those existing areas where there are likely environmental factors, pollution, noise, air quality issues.
Question 38
If Green Belt developments cannot meet existing accessibility requirements can they be regarded as sustainable? Peripheral development will generate more car travel and longer distances. If a
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development cannot reach the standards set, would it be possible to require offset contributions to improve accessibility and public transport elsewhere (e.g. in adjoining built-up areas)?
Question 47
Yes. If it is necessary to develop Green Belt for housing then this policy should aim to recoup some of the higher development values realised for enhanced contribution to services. It important that new developments set aside sufficient land for provision of schools and the like. Greenfield sites are likely to appeal to those setting up free schools. Unfortunately this is socially divisive, but it may necessary to ensure that enough school places are provided.
Question 49
The policy on release of existing employment land should protect existing businesses and viable enterprises, but should also identify major sites that could be redeveloped for housing or other uses. It should also include criteria for assessing windfall redevelopments that cover the amenity of local residents and any existing traffic and parking problems. An adequate selection of sites suitable for relocating businesses should be identified.
Question 55
Policy should be retained/enhanced.
Question 56
It is not clear whether the list includes the Dudley Canal Portal. It should as there is a for improvements to the highway, public transport and pedestrian access to and from the site.
Consideration should be given to including the former Chance's glassworks given its key position alongside the canal, motorway and railway routes through the Black Country, and the recent formation of a Trust aiming to secure restoration.
It is important that all developments close to and adjoining the canals should enhance this important network of routes and attractions, improving access where appropriate. Opportunities to provide facilities for boat users should be encouraged as should the provision of shops, cafes and other services for boat users and those visiting the canals.
Questions 58-61 and 82
The relevance of policies for many of the district and local centres is open to question. Many smaller centres are dominated by fast-food outlets, It is also time to reassess the boundaries of some.
There may be a need to review policy criteria that apply to the new breed of medium size supermarkets (e.g. ADLI, LIDL) which are springing up in other locations (e.g. the Priory in Dudley). Not sure of the size of these in relation to thresholds for out-of-centre developments (covered by CEN6 and 7) referred to in paragraphs 6.1.11-13.
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Questions 69-73
There is a need to consider some conversion/redevelopment for housing within centres, even if this reduces retail floorspace. New housing can help to support, and lead to development, of a wider range of convenience shops - as in Birmingham centre.
Question 72
As above. Vacancy rates in all centres, large and small have remained high for many years. It is now time to accept reality. It must be remembered that in some older centres, what were once houses were turned into shops. It may be time to reverse the process.
Question 79 Need a restrictive policy on fast-food outlets in residential areas.
Question 86 Is there a policy covering the loss of public houses to other uses?
Question 88. Transport priorities will need to be reassessed in conjunction with the development of the strategic locations for housing and employment growth. As a resident, my view is that the area has major transport problems which can only be met by a much more ambitious programme for modal shift plus selective road improvements.
Connectivity to HS2 will be a major issue presenting opportunities and threats. HS1 has had mixed impacts in different parts of Kent, massively improving access for towns that are on the HS network, while adversely affecting the cost and quality of train services for many other areas.
Question 92
Support the concept of a coherent walking and cycling strategy, but reserve judgment on content of existing strategy. The canal network provides the most strategic long-distance routes, but unfortunately much of it is poor quality. Suggest you visit Sheffield/Rotherham to look at the River Don cycleway, or perhaps Leicester for cycle routes along former railways.
It is important that major new developments contain adequate facilities for cyclists and pedestrians, and where possible provide through routes that can create a longer route. Too many recent developments (e.g. Castlegate in Dudley) are bike/pedestrian unfriendly). In other cases opportunities to create new routes have been lost: e.g. the swimming pool and adjoining hew housing estates on Alexandra Road/Church Lane Tipton.

Introduction.

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

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

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

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

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

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

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

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

We agree that the existing two-tier forward planning approach should be retained. Most Local Plans are now currently emerging as single-tier plans, but this Core Strategy provides a strategic plan for a large part of the Metropolitan area. The individual Metropolitan Boroughs of Dudley, Sandwell, Walsall and Wolverhampton and those Districts surrounding the Black Country - such as South Staffordshire - will then develop the policies, identify the sites and implement the strategy.
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details.

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

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

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

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

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

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.

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

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

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

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

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

A few points are relevant here:-

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

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

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

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

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

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

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

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

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

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

Key issue 5 - Protecting and enhancing the environment.

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

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

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

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

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

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

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?

The key issues outlined in paragraph 3.1 are as follows:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Question 13a - Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas.
What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.

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

Question 13c - Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?

Question 13d - Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?

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

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

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

We have already mentioned above that other options rather than encroaching onto the Black Country green belt, do exist. The larger South Staffordshire villages which are served by public transport provide a logical case for growth. In the case of Codsall/Bilbrook there are 2 railways stations and the village is within cycling distance of the new i54 JLS plant and the Pendeford Business Park close by. Carefully selected green belt releases in these locations offer good potential links between homes and jobs whilst exploiting the wide range of facilities which Codsall enjoys. The Sandy Lane site, promoted by Hallam Land will be surrounded on three sides by development, once the adjacent Watery Lane site is built, and is ideally suited for development.
Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?

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

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

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

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

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

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

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

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

Question 21 - Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.

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

Questions 22-28, Social and Physical Infrastructure.

We have no further comments on these aspects.

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

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

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

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

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

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

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

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

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

Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No; Any further comments?

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

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

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

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

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

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

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?

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

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

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

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

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

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

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

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

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

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

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

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

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

The Councils should set the target for affordable homes at the level which emerges from the evidence obtained from the SHMA. With the definition of affordable homes set to change to include starter homes it is admittedly difficult to pin down exactly what counts as affordable and what doesn't. The Black Country authorities should therefore set the right policy climate to encourage more affordable homes to come through. Where so many sites ae affected by contamination and site stability issues the ability to subsidise affordable housing may be problematic. Affordable housing may therefore need to emerge through public subsidy through Registered Providers and housing trusts, rather than necessarily through cross-subsidy.
Question 44 - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments? If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Call for Sites - potential options.

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

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

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

Yours sincerely

John Acres

ACRES LAND & PLANNING LTD

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.

Response to Questions

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

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF.

The adopted BCCS was published in 2011, prior to the publication of the NPPF in March 2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change in plan making.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.

2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

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

2.5 To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3,039 dwellings against the stepped housing delivery trajectory.

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

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

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

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

2.9 If any existing employment sites are to be proposed for allocation as residential development, the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location for residential development with appropriate supporting community infrastructure, and whether neighbouring uses would conflict with the expectations of future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's housing needs and in particular there is a need for evidence to be collated to understand gaps in social infrastructure such as education provision. To provide a robust assessment of infrastructure, public consultation should be undertaken to ensure that a full picture is provided, as residents and landowners will have information of use.

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

2.12 It is also considered that the Black Country authorities include a robust landscape character assessment in the scoping of the evidence base document Strategic Mapping of the Black Country's Natural Environment.

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

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

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

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

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

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

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

2.18 As part of this the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
2.19 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.

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

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

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

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

2.23 The need to review the role and extent of the Green Belt in order to meet the housing needs of the area is strategically significant and a fundamental shift from previous policy. This of course needs to be balanced against the desire to regenerate and make best use of brownfield sites, but the scale of growth anticipated overall will require a step change in physical and social infrastructure (including highways, education and recreation provision), as recognised in paragraph 3.52 of the I&O Report.

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

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

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

2.26 Furthermore, the adopted BCCS' vision is underpinned by three 'major directions of change', none of which specifically refer to meeting the Black Country's housing needs or the infrastructure to support this. The BCCS Review vision would be more robust if it was underpinned by the nine key issues set out at Part 3 of the I&O Report and made direct reference to the supply of new homes and the infrastructure required to enable the growth required over the plan period.

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

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

2.28 Meeting the emerging housing needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust and refer to the infrastructure required to support the identified growth, if they are to be meaningful.

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

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

Q11a. Do you support Strategic Option 1A? 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?

2.30 There is a need for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both will require significant new land and infrastructure to support this level of growth, and this will require a different spatial strategy to the current one.

2.31 There is currently a deficit of 57 ha gross of employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality employment land. This does not distinguish between different types of employment, including different use classes and size or characterisation.

2.32 The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas. Whilst some of the businesses may not be 'friendly' to neighbouring uses, these types of units form the back bone of the Black Country economy and their loss would negatively impact business in the area. The loss would also remove local, sustainable job opportunities.

2.33 As set out in our response to Q2, further employment land supply evidence is required to achieve the right balance between protecting smaller urban sites which have numerous benefits in providing affordable space for start-up and smaller businesses, which represent a significant proportion of the Black Country economy, and the need to provide larger high quality sites to meet the needs of modern industries and new operators, and their need for better accessibility to markets. This will facilitate the redevelopment of some sites for housing, but the Black Country faces choices with an overall employment land deficit of 300 ha. It cannot simply turn all of its employment land over to housing.

2.34 The Councils should also be mindful of the viability of regenerating employment land for residential use, and whether the market can sustain viable development on these sites. This is demonstrated by the number of previously developed sites in the Black Country allocated for housing in previous plans which are yet to be delivered, and show no sign of doing so in the near future.

Q12a. 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.

2.35 Please refer to our response to Q13a.

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

2.36 OSH support the broad Housing Spatial Option H2 - Sustainable Urban Extensions.

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

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

2.39 Subject to meeting the requirements of the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs without breaching the principles of including land within the Green Belt, however the I&O Report acknowledges that Option H1 would not meet all of the Black Country's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Sites such as that at Racecourse Lane, will also seek to provide the infrastructure required to support the identified growth, in this case by incorporating a primary school and g irls secondary school within the masterplan for development. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met. There is advantage in having a number of SUEs located around the edge of the built up area to provide the market with choice and to ensure that houses can be delivered simultaneously in a number of different market locations.

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

2.43 Spatial Option H2 is therefore the most appropriate strategy for accommodating the
area's housing shortfall, however Spatial Option H1 can make a small contribution in the
right locations.
2.44 Any site selection criteria should reflect the NPPF, recognising that planning should
actively manage patterns of growth to make the fullest possible use of public transport,
walking and cycling, and focus significant development in locations which are or can be
made sustainable. Whilst a potential SUE may not be immediately adjacent to local
services or a rail station (which will be the case for the majority of the SUEs given their
location on the edge of the urban area), there is the potential to make it more
sustainable through new transport links (such as bus services) and on site provision.
2.45 Given the critical mass of SUEs, they have the potential to sustain significant on site
services. The Racecourse Lane Masterplan (enclosed at Appendix 3) demonstrates
8
how new educational facilities could be provided alongside a new residential community,
serving the needs of existing and future residents.

2.46 The BCCS Review should also not make assumptions that SUEs will have major
impacts on Green Belt purposes and environmental assets (as suggested in the
'challenges' section for Spatial Option H2). Firstly, any site's performance against Green
Belt purposes is separate to any site selection process and the NPPF makes clear that
the purpose of reviewing the Green Belt is to promote sustainable patterns of
development. SUEs can have many environmental benefits, including delivering
significant public open space, providing access to the countryside, as well as
biodiversity enhancements.
Q13b. What infrastructure do you think would be needed for different sizes
of SUEs?

2.47 It is recognised (at paragraph 6.44 of the I&O Report) that increased birth rates have
significantly increased the need for new primary school places, which is now working
through to secondary schools and is placing pressure on the school estate. Therefore,
the potential for educational facilities at Racecourse Lane will contribute towards
meeting this need, serving existing residents in the area and also providing educational
facilities to support the ambitious growth across the Black Country.

2.48 However, on a general scale for the purpose of the BCCS Review, for the reasons
provided in response to Q12a and Q13a, further evidence will be necessary to inform
infrastructure requirements for each SUE, including school and healthcare provision.
The I&O Report indicates a number of infrastructure assessments are to be undertaken
before the Preferred Options version of the BCCS Review is published. Furthermore,
the Councils should be mindful of site specific evidence bases prepared by developers.

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

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

2.50 The land at Racecourse Lane, Stourbridge, represents a unique opportunity for an
educational led development alongside a new residential community and health care
facility. OSH's aspirations are to create a new development with a 2 form mixed primary
school for circa 420 pupils, and also a 3 form girl's secondary school for circa 450 pupils
to compliment the Foundation's existing boy's school and extend its education provision
to more of the local community. The masterplan includes significant high quality open
space, parkland and green infrastructure, promoting a well-balanced and sustainable
development opportunity.

2.51 We explore the infrastructure requirements of the site further in the Call for Sites form
(Appendix 2) and Racecourse Lane Masterplan (Appendix 3) enclosed with these
representations.

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

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

2.53 The site is bounded by residential development to the north, west, east and south-east. The proposed masterplan includes the relocation of the 18-hole golf course (circa 43 hectares) to the south of Racecourse Lane and the redevelopment of the existing
Stourbridge Golf Course principally for housing. As such, the new development would
be enclosed by existing built form along three boundaries and the new golf course will
act as a boundary to the south, restricting any sprawl of the built-up area. Racecourse
Lane will provide a strong defensible boundary for the Green Belt along much of its
length.

2.54 Consequently, the release of the site from the Green Belt would not result in unrestricted sprawl of the built up area further south than Stourbridge currently extends to the south and south-west.

Purpose 2 - To prevent neighbouring towns merging into one another

2.55 The relevant purpose of the Green Belt in this location is to contain the overall
conurbation to prevent it merging with Kidderminster (the nearest large town) and to a lesser degree to prevent Stourbridge merging with Hagley (a smaller settlement only partially separated from the conurbation).

2.56 The release of the Racecourse Lane site from the Green Belt would not result in Stourbridge merging with Hagley nor of the conurbation getting any closer to Kidderminster.

2.57 As set out above, the residential development would be enclosed by Racecourse Lane to the south, acting as the firm defensible boundary.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.58 Any development on land formerly in the Green Belt will to a degree extend into areas that are currently open. The land at Racecourse Lane is principally an existing golf course bounded on three sides by existing residential areas. By relocating the golf course to the south of Racecourse Lane where it can remain in the Green Belt, the residential development and the new schools can be located so as not to extend into open countryside. There is a pronounced ridge to the south of Racecourse Lane and there will be limited long distance views from the countryside into the site, other than those which would primarily be of the new golf course.

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

2.59 The site is not situated within the setting of a historic town and as such this purpose is not considered to apply in this circumstance.

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

2.60 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate a shortfall of approximately 22-25,000 new homes. It has been established even with increased densities, the Black Country has severely limited opportunities to accommodate this level of growth within the urban area and it is therefore necessary to consider Green Belt release. The ongoing recycling of derelict and other urban land will also be needed to deliver the scale of housing and employment growth needed.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?

2.61 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible to ensure the Plan is able to respond to the most up to date evidence and be in line with paragraph 173 of the NPPF.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing
infrastructure, easy access to jobs?

2.62 The NPPF is clear that local planning authorities should have fully explored all available options for delivering their housing needs within their own administrative boundaries before considering exporting growth to neighbouring authorities or the wider HMA.

Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given this exercise had not been undertaken. As such this option should only be considered as a last resort. This option would also put further pressure on infrastructure in adjoining areas, which would need to be accommodated.

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

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

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

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

Q22. 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.

2.66 Paragraph 6.44 of the I&O Report acknowledges that as a result of increased birth rates, there is a requirement for new primary school places and this is now working through to secondary schools. The existing pressure on places will only be exacerbated as the levels of growth anticipated in the Black Country's economic strategy follow through into population growth.

2.67 Paragraph 70 of the NPPF establishes that to deliver the social, recreational and cultural facilities and services the community needs, planning policies should (amongst other issues) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. Consequently, the development potential at Racecourse Lane presents a prime opportunity to meet the requirement for future education provision, in a sustainable location in close proximity to existing and proposed residential communities.

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

2.68 Please refer to our response to Q28.

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

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

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

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

2.71 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities as part of this review will be critical in establishing the existing shortfall and future requirements to support growth.

2.72 Since the BCCS was adopted, it is apparent many brownfield sites are marginally viable at best and will struggle to deliver the necessary infrastructure required (as much is acknowledged at Section 2 of the I&O Report). There will be a need for public sector intervention and funding to deliver the scale of brownfield development anticipated. Also, where markets are weaker, it should not be anticipated that greenfield development can subsidise or provide infrastructure beyond what is required to support the development itself. Whether through CIL or S106, policy must be realistic and flexible to ensure that development can come forward on the scale and at the pace required to deliver growth and meet housing need.

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

2.73 The recently published WMCA Land Delivery Action Plan identifies sources of funding and immediate priorities. Of the £200m Land Remediation Fund, £53m is already allocated to the Black Country and a further strategic package of £97m is available to be drawn down by the LEP. However, the plan states on page 44 that "to fund the current pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding is required". This, it states, will be a key requirement of the Housing Deal the WMCA is hoping to negotiate with CLG.

2.74 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed to deliver a substantial step change in brownfield delivery. As set out in our response to Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and that it is viable for new development on brownfield sites to contribute towards providing infrastructure to meet their needs. The role of greenfield locations to deliver market housing and contribute fully to meeting infrastructure costs should therefore be a key component to derisk the BCCS housing strategy.

Q32. Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? If no, please provide details

2.75 Please refer to our response to Q34b.

Q33. Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? If yes, is a new policy needed to address such issues for example?

2.76 Please refer to our response to Q34b.

Q34a. Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach?

2.77 Please refer to our response to Q34b.

Q34b. What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

2.78 We support the strategy to incorporate health and wellbeing issues in the BCCS Review. Health and wellbeing underpin sustainable planning and creating places where people want to live.

2.79 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of integrating health and wellbeing into all policies, including those of the emerging BCCS Review. In particular, the technical note encourages the creation of communities which are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social interaction and social capital.

2.80 As such, health and wellbeing should not be standalone policies in the plan, but rather should be a 'golden thread' running through the review and all policies. Any sites promoted through the Local Plan process should demonstrate their health and wellbeing benefits if they are to be proposed for allocation.

Q35. Do you support the proposed approach to housing land supply? If no, please explain why.

2.81 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in our response to Q1 a full review of the Plan is necessary given there are now greater housing needs, the NPPF has been published and the WMRSS has been revoked, and the adopted BCCS has not been delivering the required level of growth. As such the approach to housing land supply should be reviewed in full also.

2.82 Given there is a shortfall of 3,039 dwellings against the targets set in the adopted BCCS, largely as a result of brownfield sites not being developed due to viability issues, the Review should include a 10% lapse rate applied to the requirement to ensure flexibility in deliverability should sites in the supply not come forward.

Q36. Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? 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?

2.83 Please refer to our response to Q42.

Q40. 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.

2.84 Please refer to our response to Q42.

Q42. Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? If no, please explain why.

2.85 The NPPG states that wherever possible, local needs assessments should be informed by the latest available information and the government's official population and household projections are generally updated every two years.

2.86 The affordable housing requirement; preferred housing mix; housing types; and density standards for the Black Country therefore need to remain fluid in order to respond to the most up to date evidence and market conditions. The BCCS Review should not comprise policies that set standards for the whole Plan Period. The standards set out in Policy HOU2 should be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date guidance.

Q47. 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.

Paragraph 6.46 of the I&O Report acknowledges that Community Infrastructure Levy contributions cannot provide sufficient sums to wholly fund new education and healthcare facilities and running costs. Therefore, the proposals presented by OSH should be assessed favourably by the Councils as it promotes a suitable opportunity to provide education provision as is required across the Black Country. This proposed education provision will be situated in a sustainable location, in close proximity to existing and potential future residents.

Question 1:
Natural England's considers the environmental policies of the existing Core Strategy relatively robust. We, therefore, agree that the partial review should retain much of what is currently in place with regard to environmental policy with improvements, where necessary, to some policies to update these in accordance with new legislation and emerging environmental evidence. Where appropriate, the appropriate environmental policies should also be further strengthened in order to ensure the successful environmental transformation of the Black Country the Plan desires.

Natural England also considers that there should be a greater reference to the importance of the natural environment and landscape-scale green infrastructure (GI) benefits throughout the Plan. The necessary 'Environmental transformation' of the sub-region is indeed one of the core directions contained within the Plan's Vision; this direction and need is only further supported with the emergence of the Black Country Garden City aspirations. The benefits of GI to an urban area are well documented and are crucial to the delivery of high quality sustainable development. It can provide multiple benefits for people and wildlife, for health and well-being, for eco-system services, for the economy. As a result, we would recommend the Plan ensures the GI needs of the sub-region are front loaded as part of development decisions and referenced in development policy, where appropriate.

Question 2:
Natural England is unsure what the 'Strategic Mapping of the Black Country's Natural Environment' is. However, this may refer to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities.

This evidence, in a large part, meets the requirements of the Plan as detailed at paragraph 3.4. Natural England welcomes the planned preparation of a Habitat Regulations Assessment Screening Report at Preferred Spatial Option stage. (para 3.8).

Question 5:

Natural England generally supports the proposed evidence based approach to the Green Belt Review. In order to meet the housing demands of an area we recognise that it is sometimes necessary to release the most appropriate green belt land in order to best accommodate the needs of both the future and existing populations. The Sub-Region , in most parts, comprises tightly constrained built form, however, there are important pockets of valuable green space / infrastructure contained within which perform a variety of important functions for people and wildlife. It is, therefore, important that we ensure future development is planned such that the populations, new and existing, are able to receive the multi-functional benefits of GI which enhance quality of life.

We note the comments of the Black Country Local Nature Partnership (LNP) in response to this question recommending the evidence review is extended across the Black Country and not just the greenbelt. We believe that Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis' will be able to support you in this endeavour. We would advise you contact the LNP for further discussion on this issue as they suggest.

Question 6:
Key Issue 1 - Recommend inclusion of Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis'
For Key Issue 5 - Recommend inclusion of Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis'
Natural England welcomes the commitment to make provision for environmental infrastructure (Paragraph 3.35) and looks forward to working with you to help ensure this aim is fully realised.

We also welcome the recognition of the need to abide by the Habitat Regulations (Paragraph 3.38) but note that nationally and locally designated sites are excluded from this section. In consideration of their importance to the Sub region we would recommend reference to their respective value.

We welcome the inclusion of the reference to the Cannock Chase SAC and SAC Partnership and the Council's commitment to the undertaking of a fresh HRA screening exercise for the purposes of informing the Plan.

Question 7:
Natural England disagrees with the principle that brownfield sites will always be prioritised for development and it is our opinion that all sites must be assessed on the same merits regardless of location. Whilst the re-use of brownfield sites is encouraged in the NPPF, Paragraph 111 states that this is only when brownfield sites do not have high environmental value. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some areas of greenbelt. (Comment replicated and aligned with LNP response).

Question 8:
Given that paragraph 1.1 of this document states that one of the three main purposes of the strategy is to direct environmental activity to the right places it is surprising that there is no spatial objective that explicitly allows for the provision of green infrastructure. Environmental Infrastructure is one of the five strategic policies subsequently set out in the document but this would be greatly strengthened if it were backed up by an explicit spatial objective such as "safeguard existing environmental assets and take opportunities to improve environmental infrastructure to support wildlife populations and provide other ecosystem services". (Comment replicated and aligned with LNP response)

Question 11a, 12a, 13a and 13b:
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.

Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development. (Comment replicated and aligned with LNP response)

Questions 16 - 20
As with the spatial options proposed for housing, we would prefer the selection of sites for employment to be undertaken through evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently fully explored in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development. (Comment replicated and aligned with LNP response)

Question 21:
The definition of infrastructure in Policy DEL 1 is broad, including public open space and sustainable drainage but the provision of environmental infrastructure is not mentioned specifically in DEL1 nor Paragraphs 5.1 to 5.6 of this report except to say that environmental impacts should be mitigated. We would like to see the provision of additional environmental and green infrastructure explicitly covered in this policy and the LNP can provide advice and support for this. It is also our opinion that this policy should be no different in greenbelt or urban areas(Comment replicated and aligned with LNP response).

Questions 32 &33:
We would support the continuation of health and well being related criterion being interwoven throughout the various policies of the Plan provided the Council can satisfy itself that this is sufficient in order to secure to positive benefits from such aspirations. We particualrly weclcome the inclusion of Theme 2 - Planning for active lifestyles although it is important to recognise that simply provision of open spaces does not always provide the health benefits we desire. The quality of the open space, the sensory experiences, perceived safety, etc are also critical to encouraging utilisation and hence attaining the community benefits. Much of this comes down to management and manitenance of sites, however, it is also important to consider locational aspects of open space / GI as some existing areas may encourage use whereas others detract.

Question 36:
We disagree with both the assumption that housing densities should be different in greenbelt and urban areas and that there should be a minimum net housing density on brownfield sites. The ecological importance of brownfield sites can equal or greater than in the greenbelt and the need for green infrastructure is often higher in urban areas. The density of a development should depend on the needs of the residents and strategic goals and should therefore be assessed on a site by site basis. (Comment replicated and aligned with LNP response)

Question 38:
Whilst we understand the need for creating space-efficient developments we would like to see each housing application assessed on its own merits to a universal standard. (Comment replicated and aligned with LNP response)

Question 47:
The definition of healthcare facilities covered by Policy HOU5 should be extended to explicitly include the provision of multifunctional greenspace to allow healthy lifestyle choices as identified in section 6.11 of this report. (Comment replicated and aligned with LNP response)

Question 49ab:
Given that the NPPF requires the planning system to contribute to and enhance the natural environment in the pursuit of sustainable development, consideration could be given to releasing land for green infrastructure and nature conservation. This is essential as current evidence indicates that our existing network of designated sites is not sufficient to protect wildlife, that areas of publicly accessible greenspace are essential for our health and wellbeing and provide other ecosystem services often lacking in very urban areas. (Comment replicated and aligned with LNP response)

Question 65, 67, 69 and 72:
Strategic centres also have a role to play in providing access to green open space and providing ecosystem services. Each development should be assessed on its merits , and whilst intensive development may be appropriate in some situations in strategic centres, the need and opportunities for multifunctional green infrastructure should be considered in all locations. This is especially relevant to health and wellbeing if strategic centres are developed such that people both live and work in these centres. (Comment replicated and aligned with LNP response)

Question 94:
We welcome updates of environmental infrastructure requirements based on up to date evidence and recommend reference to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities.
Natural England and the LNP can also provide existing data, advice and support in developing new proposals.

Question 95a:
We refer your authority to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities. We consider this can align with the emerging Black Country Garden City principles and therefore help usefully inform development decisions towards the Garden City vision. NE is working alongside the Local Enterprise Partnership and is part of the Black Country Garden City Working Group to seek to realise these aims.
We also welcome the Para 6.148 reference to potential inclusion of agreed GCPs into Policy CSP3: Environmental Infrastructure.

Natural England understands the reasons for the proposed removal of the specific criterion relating to renewable energy generation as part of CSP3. However, the importance of such facilities should not be diluted in the Plan and we would recommend other policy support where appropriate.

Question 95b:
The application of the principals will vary on a site by site basis, as the environmental and social needs will vary between developments. The location of the site on brownfield or greenfield land is likely to influence the site specific requirements, but different standards should not be applied on the basis of a greenfield/brownfield categorisation. (Comment replicated and aligned with LNP response)

Question 96:
We welcome the proposed changes that provide additional protection to irreplaceable habitats and to bring the definition of mitigation in line with NPPF to require compensation for residual negative impacts. We further recommend that the proposed additional protection for ancient woodlands is extended to include other irreplaceable features such as ancient and veteran trees. The LNP can provide advice on the most accurate data sets available to identify such features. (Comment replicated and aligned with LNP response)
Natural England also welcomes the proposed inclusion of a requirement for appropriate biodiversity features as part of new development - such as natural green space, use of native planting and nest boxes.
We welcome also the inclusion of a reference to the Black Country Geopark.
Natural England would recommend your authority liaise with the LNP who are able to provide advice towards making this Policy and its application as robust as possible.

Question 97:
We feel that there could be a greater recognition that nature and natural features are an important constituent of place making and local distinctiveness and often have a strong relationship with historic character. (Comment replicated and aligned with LNP response)

Question 100:
Natural England recognises the difficulties that have emerged as a result of the inclusion of local projects ( such as the Hatherton Branch Canal Restoration Project) and whilst generally supports the principle of such initiatives, recognises that difficulties can arisen relating to the viability of such policies on grounds of technical challenges.
Recent discussions between NE and Walsall MBC (WMBC Policy EN4 Hatherton Branch Canal) have concluded that the viability of such projects are best considered at project level. For this reason, NE would support the removal of such initiatives from Core Strategy Policy and supporting paragraphs which, without the evidence to confirm technical viability, the deliverability of which remains in question.
We would add that reference to the supported principle of such initiatives would also be supported, provided the related paragraph made it clear that Council and Policy support would only be forthcoming where the evidence for its viability and deliverability was provided.

Question 101a:
We strongly agree with the principal of prioritising natural SUDs as this provides greater opportunity for SUDs to provide multiple functions and provide biodiversity features. (Comment replicated and aligned with LNP response). Natural England's BCGC Part A GI Evidence Base can assist in this.

Question 102a:
We support this policy but suggest additional clarification and strengthening as discussed in our responses to Questions 102b and c.

Question 102b:
Would recommend specific reference to Natural England's BCGC Part A GI Evidence Base in accompanying paragraphs

Question 102c:
We suggest further clarification on what constitutes open space as the policy does not specify publically accessible open space. We would welcome a definition that extends all sites that have developed nature conservation interest, are used informally for recreation or provide other ecosystem services. Reference again to Natural England's BCGC Part A GI Evidence Base

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.

Apologies for not using the online process but I wanted to include a "covering letter" of sorts explaining my organisation and context of my comments. I would appreciate confirmation of receipt of the form.

My comments are on behalf of Wolverhampton branch of the Campaign for Real Ale (CAMRA - 1230 members approx. across the Wolverhampton area) so concern how public houses may be affected by the Black Country Core Strategy and whether they can be explicitly defined as built social infrastructure or a community facility. I've tried to associate my comments to specific questions in the consultation (in particular changes to policy HOU5 would seem the most likely avenue to achieve this) but would appreciate it if the status of pubs could also be considered more generally in case I have not put my comments in the best places.

I appreciate a large thrust of the consultation is around the status of Green Belt and options regarding using that for development. I was informed that 2 of the pubs in Tettenhall, Wolverhampton are situated in the green belt but would suspect that across the whole of the Black Country there would be many more that are affected by areas covered by the strategy (including strategic centres and regeneration corridors) or any future changes to the identified areas. The consultation also asks about identifying areas outside the four councils (e.g. land in South Staffs) for housing and employment which might also affect pubs there.

Our hope would be that pubs could be recognized as an important community facility within the strategy or associated policies so that any proposed development for the land they sit on is weighed up against the impact of losing an important community facility (e.g. so that a "need for housing" identified in the strategy doesn't automatically trump the need for a community to retain its pub).

Whilst I am commenting on behalf of Wolverhampton CAMRA, CAMRA has branches in Walsall and Dudley that would hold similar views on the importance of pubs to their local communities and we would be most happy to be contacted for further discussion on this subject if desired.

Rep made against: Key Issue One, para 3.4, p 17

3.4 mentions "heritage assets" some pubs could be interpreted as being heritage assets - particular those of note as being a landmark building or serving a community for a very long time
(Wolverhampton has a number of 18th century pubs).
Rep made against: Question 13b - What infrastructure do you think would be needed for different sizes of SUEs? If a SUE is large enough and far enough away from existing facilities (reasonable walking distance) then a pub would be an important social infrastructure facility that should be considered. A good
local pub would be the heart of its community and promote social inclusion and well-being. The lack of such a facility would contribute the SUE being a mere dormitory.

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

Answer = Yes. I fear without specific guidance in the strategy a developer would seek the profitability of squeezing as many houses as possible into an area with little regard to creating a community people would want to live in.

Rep made against: 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.

If anyone has identified a pub or pubs in this section (pub plots can be very appealing to housing developers) please consult with the local community or interested bodies such as CAMRA before accepting it as a fact.

Rep made against: 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.

Answer = yes. Similar to my response to 13d. For a large housing development a pub would be an important social infrastructure facility that should be considered. A good local pub would be the heart of its community and promote social inclusion and wellbeing. The lack of such a facility nearby (reasonable walking distance) would contribute the development being a mere dormitory.

Rep made against: 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 development

Answer = yes. Pubs should be considered built social infrastructure and would certainly count as "community meeting places." Community pubs promote social inclusion, help combat social isolation (the Local Government Association has cited loneliness as a major public health issue) and research from Oxford University, "Friends on Tap," has shown that people with a "local" pub are happier, are
more satisfied with their life and have a wider network of friends. In short, a housing development without social infrastructure like pubs is a dormitory, not a community.

Link to cited report: http://www.camra.org.uk/documents/10180/36197/Friends+on+Tap/2c68585be47d-42ca-bda6-5d6b3e4c0110

Rep made against: Policy HOU5 - Education and Health Care Facilities, 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 r

Answer = yes. If social infrastructure, including pubs, is included there should be a requirement that adequate alternative provision is demonstrated. The Black Country being predominately urban doesn't mean a community or locality is not affected in the same way as the loss of the "last pub in the village" - there is reference elsewhere to facilities of being within "easy walking distance"
particularly for less mobile community members - if the last pub in a locality went it could contribute to social isolation of those not able to travel wider. Loss of pubs could be counter to social inclusion and sustainable communities.

Rep made against: 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
The Black Country is home to a number of pubs on CAMRA's national inventory heritage list which might fit in with the heritage themes of the list of attractions

We are instructed by Bloor Homes to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportunity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation website. We trust you take our comments into consideration and look forward to being notified of future stages of consultation on the Core Strategy.


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?

No, we consider that the review needs to go further than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphas is on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a var iety of reasons relating to ownership, viability, market perceptions, site suitability etc.

The approach of the BCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework. Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different econom ic climate to the adopted document. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.







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To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors. It is, however, advised in the "delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of concentration in the growth corridors is "less than participated". One of the reasons for this is that more windfall sites will come forward than expected outside of the Growth Network. These windfall sites have assisted in housing delivery. Appendix C - Black Country Monitoring Summary, of the emerging plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developme nts have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constra ints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employment land. As a consequence, the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attract ive to the market.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the MS.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience diff iculties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementation rate needs to be identified in respect of the windfall element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgement with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discuss ions with the adjoining Authorities to the Black Country, including South Staffordshire , Wyre Forest and Bromsgrove

To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographical linkages.

We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites can be made available to meet the needs of the market. This will also help with early delivery and will help Local Authorities to maintain a five year housing land supply and also to boost significantly the supply of housing in accordance with the requirements of paragraph 47 of the Framework .

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "be significantly " for supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework . To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission.

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Authorities. The housing market areas should not be confined to the administrative boundaries of the Black Country Authorities. ( HL to review)

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 partic.ular issues that should be taken into account in considering development on any particular sites or any particular areas, please provide details.

We consider that a more in depth analysis needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.




To: Black Country Core Strategy - Dudley MBC Date: 81h Septembe r 2017




As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Autho rity boundaries.

We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Author ities. This strengthens our view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Author ities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward. Our experience to date has been that the programmes have been time consuming, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

As a starting point, we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to visit the HMA but build upon the work undertaken in establishing the Greater Birmingham HMA part of the preparation of the Birmingham Development Plan. HMAs overlap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whet her the HMA boundary remains valid for the purposes of its assessment. This approach is, however, entirely missing.

It should also be noted that the SHMA does not fully address affordable housing requirements . It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordable housing need is not a direct component of the demographic part of the objectively assessed








To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017



needs assessment. As such, an updated calculation of this nature is not included in the SHMA. It is for the client Authorities to consider whether more new homes over and above the objectively assessed housing needs figure identified in the SHMA should be provided in the plan area to address more affordable housing need through policy adjustments .

The Framework advises that paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things, "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore, provide a complete picture of housing need within the subject Authority areas.

The SHMA is not, therefore, in accordance with national guidance in this regard. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore , there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing Core Strategy where there has been significant under delivery in the Growth Network. As referred to in our response to Question 1, there is clear uncertainty regarding for delivery of a significant number of the housing sites identified on the existing employment land by the current development plan documents. It is necessary for the emerging Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure take account of non-delivery of proposed housing allocations. At the present time the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). It is, therefore, our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 11.6% of flexibility to supply and to take account of the delivery in delivering the urban regeneration sites.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78,190 units over the plan period, this produces an annual requirement of 3,554 units per annum which is also far in excess of what has ever been achieved annually in the SCCS. We consider that this is a challenging figure in terms of the current supply , over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25,000 units identified.

We note that the overall supply from the urban area depends upon some 42 ,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5, the latter identifying the problems in releasing employment sites), we consider that the local plan strategy wh ich relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.













To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017



The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.

It is apparent , therefore, that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefo re, the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfield/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locat ions which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness, viability , delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to the Black Country up to 2036 in the EDNA is appropr iate and in line with national guidance? Yes/No . If not, please explain why they are not appropriate and in line with national guidance.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerg ing plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.

In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network.

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

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We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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

We agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release 1n adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vital role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework. That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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 believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly, reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified.

We believe that elements of the evidence base require furthe r exam ination including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.

There appears to be some confusion in the plan as to the extent of the gap identif ied. The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery, this is not taken into account affordable housing needs. Furthermore, the emerg ing plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly











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above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore , less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified. This suggests that the contribution from greenfield/Green Belt sites from within the SCCS area and from Authorities adjoining it will need to be increased significantly.

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25 ,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfall from the early part of the current local plan period.

For these reasons, Greenfield I Green Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to 'comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive ' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.

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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employment and with in the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investme nt may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the M5, should be identified.











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We also have concerns that the regeneration corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:

'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period. '

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 agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the BCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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 comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No.

We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overre liance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore, that overall the Greenfield requirement should provide some 40 ,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No.

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfield
I windfall sites and that there is no real certainty that further employment land can be released








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over the plan period to provide housing opportunities. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context , we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.

Paragraph 47 of the Framework requires housing opportunities to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunities, will not provide any certainty to the development industry regarding the provision of housing throug h the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Ability to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximately 150 - 750 units.

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

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a 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 settlement/services, proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.

We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.

















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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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire , Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following criteria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area.

Question 158 - Do you think that there are any potential locations that should be
considered? Yes/No

We believe that Hagley will provide an appropriate location for sites to be released which meet the needs of the Black Country . Hagley is very well related to the Black Country, lying just to the south of the edge of Stourbr idge. It is a sustainable settlement, being the second most sustainable settlement in Bromsgrove District with both primary and secondary schools, a railway station, local facilities and can access the Black Country through the primary road network.

We have ident ified two opportunities for sites to be released at Hagley through the "Call for Sites" process on behalf of Hagley Hall Estate.

The site addresses are as follows:

1. Western Road I Stourbridge Road
2. Stoney Lane I Stakenbridge Lane I Kidderminster Road

The Call for Sites response provides more information regarding the suitability of these two sites for development.

We can confirm that, subject to the release of the sites from the Green Belt through the Bromsgrove District Plan, both sites can be made available in the early part of the plan period and will provide high quality, sustainable developments which will fulf il the housing requirements of residents of the Black Country.




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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.

Yes, we believe that the best way to ensure that housing provided outside of the Black Country will meet the needs of people, who would otherwise live in the Black Country is to ensure that the location of new development has good functional and geographic links with the Black Country. As noted in our response to Question 15b, sites can be released which immediately adjoin the Black Country and administrative area or are in settlements with strong functional and physical/geographic links with the Black Country. Clearly, there is nothing to stop people migrating from the Black Country into the surrounding Shire Authorities, regardless of housing provision, and, therefore, the provision of additional housing outside of the BCCS, but which will meet the needs of people living in the Black Country, will ensure that the needs of Black Country residents can be met either within the Black Country itself or in settlements which are suitable to serve it.

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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise, it will be important for the SCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the SCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged.

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.

We suspect that, generally speaking, there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Author ities to work with landowners and developers in this regard together with the relevant strategy consultees.

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CI L contributions.

We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.




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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.

At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Authorities should adopt realistic expectations as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorit ies do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards. Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forwa rd. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions, including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No. If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding. It is for this reason that we endorse a higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).


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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 .

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes . The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significant ly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the SCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employment sites.

In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajecto ry for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability , ground conditions, failure to release employment sites, we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the SCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.














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Question 36 - If you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed, what standards should be applied instead, for example, should the minimum net density of 35 dph be increased to maximise brownfield housing delivery? Yes/No.

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield. It will be necessary to have regard to site constraints, parking requirements , offset distances, green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is importa nt not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the dens ity will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfield sites, particularly if these are expected to accommodate significant areas of green infrastructure .

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances. High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should 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.

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

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.

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their










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assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach . This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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.

We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No .

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders . It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

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 site? Yes/No.

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No.

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as educat ion, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore , that a flat rate of 25% across the BCCS area should be adopted.

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

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investm ent market












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ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No.

We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No.

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements. The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.










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Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No.

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently, the amount of land which will need to be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No.

The introduction of National Space standa rd does have implications for viability since it introduces a significant additional cost to new house building without any necessary uplift in values. It can, therefore, have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country. Yes/No .

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No.

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of National Space standards.

Question 101A - Do you support the proposed changes relating to flood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A f lexible approach will be required from the Local Authorities when assessing individual schemes. In particular, a j oined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

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 .

We consider that the benefits of higher energy efficiency, as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money investing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes .

We are instructed by Barberry Developments Ltd. to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportun ity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation webs ite. We trust you take our comments into considerat ion and look forward to being notified of future stages of consultation on the Core Strategy.

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?

No, we consider that the review needs to go furthe r than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphasis on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a variety of reasons relating to ownership, viability , market perceptions, site suitability etc.

The approach of the SCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework. Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different economic climate to the adopted docume nt. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors . It is, however, advised in the "delivery" section of the emerging Core Strategy (paragraphs 2. 5 to 2.11) that the level of concentration in the growth corridors is "less than participated". One of the reasons for this is that more windfall sites will come forward than
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Appendix C - Black Country Monitoring Summary, of the emerging plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developments have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated ". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4 , new evidence identifies a significant requirement for additional employment land. As a consequence , the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attractive to the market.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the M5.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience difficulties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementatio n rate needs to be identified in respect of the windfall element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgement with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discussions with the adjoining Authorit ies to the Black Country, including South Staffordshire, Wyre Forest and Bromsgrove whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographica l linkages.

We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites can be made available to meet the needs of the market. This will also help with early delivery and will help Local Authorities to maintain a five year housing land













supply and also to boost significant ly the supply of housing in accordance with the requirements of paragraph 47 of the Framework.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "be significantly " for supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2. 10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly , business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available , it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable , sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission.

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Author ities. The housing market areas should not be confined to the administrative boundaries of the Black Country Author ities. ( HL to review)

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 any particular areas, please provide details.

We consider that a more in depth analys is needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.

As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Authority boundaries.

We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Authorities. This strengthens our












view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Author ities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward. Our experience to date has been that the programmes have been time consuming, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

As a starting point, we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to visit the HMA but build upon the work undertaken in establishing the Greater Birmingham HMA part of the preparation of the Birmingham Development Plan. HMAs over lap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whether the HMA boundary remains valid for the purposes of its assessment. This approach is, however, entirely missing.

It should also be noted that the SHMA does not fully address affordable housing requirements. It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordab le housing need is not a direct component of the demographic part of the objectively assessed needs assessment. As such, an updated calculation of this nature is not included in the SHMA. It is for the client Authorities to consider whether more new homes over and above the objective ly assessed housing needs figure identified in the SHMA should be provided in the plan area to address more affordable housing need through policy adjustments.














The Framework advises that paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things , "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore , provide a complete picture of housing need within the subject Authority areas.

The SHMA is not, therefore, in accordance with national guidance in this regard. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore, there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing Core Strategy where there has been significant under delivery in the Growth Netwo rk. As referred to in our response to Question 1, there is clear uncertainty regarding for delivery of a significant number of the housing sites identified on the existing employment land by the current development plan documents. It is necessary for the emerging Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure take account of non-delivery of proposed housing allocations. At the present time the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). It is, therefore , our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 11.6% of flexibility to supply and to take account of the delivery in delivering the urban regeneration sites.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78,190 units over the plan period, this produces an annual requirement of 3,554 units per annum which is also far in excess of what has ever been achieved annually in the BCCS. We consider that this is a challenging figure in terms of the current supply, over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25,000 units identified.

We note that the overall supply from the urban area depends upon some 42,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5 , the latter identifying the problems in releasing employment sites), we consider that the local plan strategy which relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.

The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.












It is apparent, therefore, that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefore, the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfie ld/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locations which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness , viability, delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to 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.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerging plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate
expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.

In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network.

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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














We agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release in adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vita l role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework. That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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 believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly , reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified.

We believe that elements of the evidence base require further examinat ion including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.

There appears to be some confusion in the plan as to the extent of the gap identified . The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery , this is not taken into account affordable housing needs. Furthermore, the emerging plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore, less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified .











This suggests that the contribution from greenfield/Green Belt sites from within the BCCS area and from Authorities adjoining it will need to be increased significantly.

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfall from the early part of the current local plan period.

For these reasons, Greenfield I Green Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to ' comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.

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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employme nt and within the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investment may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the MS, should be identified.

We also have concerns that the regeneration corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:





'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period.'

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 agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the SCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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 comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No.

We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overreliance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore , that overall the Greenfield requirement should provide some 40,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No .

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfield I windfall sites and that there is no real certainty that further employment land can be released over the plan period to provide housing opportunit ies. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context, we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.





Paragraph 47 of the Framework requires housing opportunit ies to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunities, will not provide any certainty to the development industry regarding the provision of housing through the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Ability to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximately 150 - 750 units.

Question 128 - Do you think there are any potential locations that should be considered? Yes/No.

Yes, we specifically consider that land at Kingswinford bordered by the 84178, the A449 Kidderminster Road and the A4 101 should be released for development. The site extends to 26 hectares and could provide a mix of market and affordable housing and supporting open space and landscaping. Further details have been submitted through the "Call for Sites".

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

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a minimum/maximum size, mix of uses, mix of housing types, accessibi lity 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 settlement/services , proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.

We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.















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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire, Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following criteria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area.

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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise , it will be important for the BCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the BCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged .

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.

We suspect that, generally speaking, there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Authorities to work with landowners and developers in this regard together with the relevant strategy consultees .

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CIL contributions .










We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.

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 .

At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Authorities should adopt realistic expectations as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorities do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards . Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forward. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions , including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No. If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding . It is for this reason that we endorse a











higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).

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.

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significantly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the BCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Gree n Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employment sites.

In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajectory for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability, ground conditions, failure to release employment sites, we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the BCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.




Question 36 - If you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed, what standards should be applied instead, for example, should the minimum net density of 35 dph be increased to maximise brownfield housing delivery? Yes/No.

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield. It will be necessary to have regard to site constraints, parking requirements, offset distances, green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is important not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the density will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfield sites , particularly if these are expected to accommodate significant areas of green infrastructure .

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances . High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking , relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developab le should 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 .

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

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.



No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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 .

We believe it would be prudent to keep the affordable homes target as origina lly set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No .

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

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 site? Yes/No .

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No.

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore , greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.

Question 47 - Do you think that Policy HOUS should be expanded to cover other types of built social infrastructure and set out standards of built social infrastructure to serve major housing developments? Yes/No.

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector




since the surgeries generate a rental income so that there is a development/ investment market ready to provide the product. It does not need to be funded from contributions from residentia l development.

Education provision will need to be carefully researched so that a capacity in schools is ident ified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No .

We believe that the policy does need to be refined in order to ensure that land which is not necessa ry to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprentices hip programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards . We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No.

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements. The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.













Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No.

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently, the amount of land which will need to be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No .

The introduction of National Space standard does have implications for viability since it introduces a signif icant additional cost to new house building without any necessary uplift in values. It can, therefore , have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country . Yes/No.

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No .

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of Nationa l Space standards.

Question 101A - Do you support the proposed changes relating to f lood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A flexible approach will be required from the Local Authorities when assessing individual schemes. In particular, a joined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

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.

We consider that the benefits of higher energy efficiency, as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money investing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes.

We are instructed by Clowes Developments to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportunity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation website. We trust you take our comments into consideration and look forward to being notified of future stages of consultat ion on the Core Strategy.


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?

No, we consider that the review needs to go further than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphasis on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a variety of reasons relating to ownership, viability , market perceptions, site suitability etc.

The approach of the BCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework . Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different economic climate to the adopted document. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors. It is, however, advised in the "delivery" section of the emerg ing Core Strategy (paragraphs 2.5 to 2.11) that the level of concentration in the growth corridors is "less than LONosifrticipated' ToKf?dmmffiT the I\ SQXtl R this is that more windfall sites will come forward than
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To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




expected outside of the Growth Network . These windfall sites have assisted in housing delivery. Append ix C - Black Country Monitoring Summary, of the emerg ing plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developments have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy , seeking to focus new residential development on poor quality employment land, will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employme nt land. As a consequence, the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attractive to the market. These would include sites capable of providing high quality housing, attractive to existing residents ion the Black Country who are seeking to move within the area, as well as an occupier seeking accommodation and which are moving to the Black Country for economic reasons i.e. the move is associated with inward investment.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the M5.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience difficulties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementation rate needs to be identified in respect of the windfa ll element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgeme nt with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discussions with the adjoining Authorities to the Black Country, including South Staffordshire, Wyre Forest and Bromsgrove whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographical linkages.





We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites, including high quality , can be made available to meet the needs of the market. The exercise should take a long-term view of development needs, providing a boundary which can endure beyond the plan period. This will also help with early delivery and will help Local Authorities to maintain a five year housing land supply and also to boost significantly the supply of housing in accordance with the requirements of paragraph 47 of the Framework.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework , housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission .

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Authorities. The housing market areas should not be confined to the administrative boundaries of the Black Country Authorities. ( HL to review)

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 any particular areas, please provide details.

We consider that a more in depth analysis needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.

As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Authority boundaries.












We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Authorities . This strengthens our view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure . In so doing, the objective should be to ensure that the needs of all are met, including those currently residing in the Black Country and who are seeking higher quality housing and those who are moving into the Black Country for economic reasons. The provision of such housing can also achieve a 'churn' in the current stock .

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Authorities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward . Our experience to date has been that the programmes have been time consum ing, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78, 190 units over the plan period, this produces an annual requirement of 3, 554 units per annum which is also far in excess of what has ever been achieved annually in the BCCS. We consider that this is a challenging figure in terms of the current supply, over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25 ,000 units identified.












We note that the overall supply from the urban area depends upon some 42 ,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5, the latter identifying the problems in releasing employment sites), we consider that the local plan strategy which relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.

The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.

It is apparent , therefore , that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefore , the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfield/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locations which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness , viability, delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to 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.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerging plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.












In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network .

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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

We agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release in adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vital role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework . That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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 believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly , reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified .

We believe that elements of the evidence base require further examination including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.












There appears to be some confusion in the plan as to the extent of the gap identified. The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery, this is not taken into account affordable housing needs. Furthermore, the emerging plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore, less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified . This suggests that the contribution from greenfield/Green Belt sites from within the BCCS area and from Authorities adjoining it will need to be increased significantly .

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first ' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40 ,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfa ll from the early part of the current local plan period.

For these reasons, Greenfield I Gren Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to 'comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.













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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employment and within the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investment may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the M5, should be identified.

We also have concerns that the regeneratio n corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:

'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period. '

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 agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the BCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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 comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No .












We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overreliance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore , that overall the Greenfield requirement should provide some 40,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No.

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfie ld I windfall sites and that there is no real certainty that further employment land can be released over the plan period to provide housing opportunities. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context, we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.

Paragraph 47 of the Framework requires housing opportunities to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunit ies, will not provide any certainty to the development industry regarding the provision of housing through the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Abil ity to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximate ly 150 - 750 units.

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

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a 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 settlement/services, proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.



We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.

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 opportun ities 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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire, Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following crite ria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area. These sites should contribute to a portfolio of high quality sites.

Question 15B - Do you think that there are any potential locations that should be considered? Yes/No.

We consider that land immediately adjoining the administrative boundary of Dudley in the Kingswinford area should be released from the Green Belt to provide an urban extension. This would provide housing which would use facilities in the Kingswinford area. We have identified land on the attached plan at Lawnswood. The site would be able to provide high quality housing, as part of the overall provision of housing needs for the Black Country, in a location in which we would be able to take advantage of nearby education, sport and High Street facilities. Being situated close to the A449 also means that occupants would be able to reach other parts of the Black Country for employment and leisure purposes.

We have completed a "Call for Sites" form which explains the development potential of this area in more detail.

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.












Yes, we believe that the best way to ensure that housing provided outside of the Black Country will meet the needs of people, who would otherwise live in the Black Country is to ensure that the location of new development has good functional and geographic links with the Black Country. As noted in our response to Question 15b, sites can be released which immediately adjoin the Black Country and administrative area or are in settlements with strong functional and physical/geographic links with the Black Country. Clearly, there is nothing to stop people migrating from the Black Country into the surrounding Shire Aut horities, regardless of housing provision, and, therefore , the provision of additional housing outside of the BCCS, but which will meet the needs of people living in the Black Country, will ensure that the needs of Black Country residents can be met either within the Black Country itself or in settlements which are suitable to serve it.

We consider that the provision of high quality sites is an important part of the approach, since there will encourage existing residents to stay in or close by in the Black County . Furthermore, such sites will help to support the economic objectives of the BCCS by providing housing for inward investment related house moves.
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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise , it will be important for the BCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the BCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged.

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.

We suspect that , generally speaking , there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Authorities to work with landowners and developers in this regard together with the relevant strategy consultees.

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CIL contributions.

We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.

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 .













At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Author ities should adopt realistic expectat ions as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfie ld sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorities do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards. Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forward. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. Furthermore, some of these sites will not be in locations which are attractive to those seeking new housing. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions, including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No . If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding. It is for this reason that we endorse a higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).

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.





Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locationa l criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living,which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significant ly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the BCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employme nt sites.


In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajectory for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability, ground conditions, failure to release employment sites , we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the BCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.

Question 36 - If you think that the current access ibility and density standards set out in Policy HOU2 and Table 8 should be changed, what standards should be applied instead, for example, should the minimum net density of 35 dph be increased to max imise brownfield housing delivery? Yes/No.




The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield . It will be necessary to have regard to site constraints, parking requirements, offset distances , green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is important not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the density will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfie ld sites, particularly if these are expected to accommodate significant areas of green infrastructure.

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances. High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should 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 .

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordab le housing.

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.

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger fam ilies.












Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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.

We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No.

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

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 site? Yes/No.

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No .

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites . We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.

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

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a developme nt/investmen t market ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the













Education Funding Agency also need to be taken into account when assessing education requirements .

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No .

We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Author ities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No .

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements . The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.

Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No .

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently , the amount of land which will need to




be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No.

The introduction of National Space standard does have implications for viability since it introduces a significant additional cost to new house building without any necessary uplift in values. It can, therefore, have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country. Yes/No.

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No .

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of National Space standards .

Question 101A - Do you support the proposed changes relating to flood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A flexible approac h will be required from the Local Authorities when assessing individual schemes. In particular, a joined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

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.

We consider that the benefits of higher energy efficiency , as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money invest ing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes .

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.