Policy Area C - The Black Country Economy

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Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1140

Received: 05/09/2017

Respondent: Futures Network West Midlands

Representation Summary:

7. Employment land
FNWM fully supports the emphasis in the WMCA Super SEP to encourage manufacturing as a key component of the economic strategy. This approach is in marked contrast to the existing BCCS and a major driver behind the need for its urgent review.
One of the recent success stories in the Black Country is clearly the development of i54 and it is important to recognise that this site was identified and brought forward for development through the formal planning system commencing with a proposal in the Regional Spatial Strategy.
The success of i54 demonstrates how the availability of sites of appropriate quality and location will remain important in attracting investment. As recognised in supporting documents, the planning system will therefore have a key role to play in ensuring that an appropriate portfolio of sites is available to meet future needs but recognising that this may have implications for the provision of sites both within the Black Country and in surrounding areas. However, given the increased emphasis on manufacturing, it will also be important to protect those existing sites that are well located and appropriate for industrial activities from competing development.
As with housing, FNWM has chosen not to challenge the assessment of future employment land requirements (i.e. leading to a shortfall 'gap' of 300ha) but, on the face of it, the overall amount required seems to be very high, and appears to ignore the potential of land being recycled. The next version of the CSR will need to be rooted on a robust evidence base and must ensure that it addresses not only the quantity of land required but, most importantly, the quality.
In line with this, from a wider WMCA perspective, FNWM would advocate that consideration should be given to the re-adoption of the employment land portfolio principles set out in the former RSS (i.e. identifying sites and premises to meet all market needs including a range of major strategic sites*). If endorsed, this approach will require a wider study, contributing to the suggested WMCA SP and, if potential sites/locations are identified in or around the Black Country, this will clearly contribute to the identified shortfall 'gap'.
(* The RSS identified Regional Investment Sites, Major Investment Sites and Regional Logistics Sites although the range of sites required will need to be reviewed and updated to meet current and anticipated requirements).
Without a collective study of this nature, there is a danger of an oversupply of competing sites against the interests of the West Midlands especially when other sites, such as Peddimore, are coming on line at the same time. Such a study should include analysis of competing sites within major transport corridors beyond the West Midlands.
This particularly applies to B8 warehousing, where there is a need for a further rigorous analysis of supply and demand and how this might change over time, including the importance of access to rail freight services. In particular, it is noted that only 100ha of the Four Ashes sites are indicated in the Black Country portfolio but another 170ha could come forward at that site.

Full text:

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


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

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2774

Received: 07/09/2017

Respondent: St Modwen

Agent: Planning Prospects Ltd

Representation Summary:

Questions 50 - 54

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

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2977

Received: 07/09/2017

Respondent: Public Health Walsall MBC

Agent: Public Health Walsall MBC

Representation Summary:

Setting targets for employment land is important however, this needs to have the balance particularly in terms of where the Greenbelt is located. For example, much of the Greenbelt is located in the East of the borough and is difficult to access for people in more deprived areas in the West. This is an opportunity to link with the transport policies to look at how this can be addressed.
Building social housing, as part of housing developments, planned for the Greenbelt could also help address this.
Priority sectors require highly trained staff. Does the local population have these skills or will the new development create 'commuter workers' from other areas who invest very little to the local economy? Unemployment in Walsall is higher than the England average. Training needs to be made available for the local population if local people are going to be able to access these jobs. This needs to include a focus on those from the most deprived areas of the borough.
Design considerations to promote healthy living also need to be considered in building developments.

Full text:

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

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

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

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

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

* Impact of electric car policies (new government legislation)

* Car Share

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

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