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.

Poorer quality employment land which is effectively non-conforming should be included on the brownfield register such that the principle of development is approved

Otherwise it will be lost eventhough it is used by smaller organisations.

LCP believe that there is no need to retain Policy DEL2 in order to manage the release of poor quality employment land. Such land will either have been identified for alternative uses or evidence can be provided which demonstrates that it is not suitable for continued employment use.

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.

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.

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.

Changing land use from Employment to Housing needs to be managed in an orderly way to ensure that viable businesses that are required to move can be assisted to do so to a SUITABLE new site in a manner and at a time that is not detrimental to them.

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.

Policy DEL2 does need to be recast given that it is now evident that the supply of poor quality employment land that is available for housing has decreased. A revised version of Policy DEL2 is required that allows for existing active employment sites to expand whilst allowing the selective regeneration of the employment sites that are unlikely to deliver.

Policy DEL2 does need to be recast given that it is now evident that the supply of poor quality employment land that is available for housing has decreased. A revised version of Policy DEL2 is required that allows for existing active employment sites to expand whilst allowing the selective regeneration of the employment sites that are unlikely to deliver.

We write to confirm BOC's representation to the Black Country Core Strategy Issues and Options consultation in respect of their operational facility at Knowles Road, Wolverhampton WV1 2ET.

BOC is a member of The Linde Group, a world leading gases and engineering company with 50,000 employees working in around 100 countries worldwide. It produces industrial gases for the healthcare, industrial, construction and hospitality industries in the form of cylinder gas, special products (refrigerants, industrial chemicals/gases, and liquid helium for medical scanners for example) and the bulk delivery of liquefied industrial gases by tanker. It also provides on-site gas generation for certain large scale facilities.

Whilst we note that the Core Strategy is at an early stage and that site specific proposals are not yet fully formulated, it is important that the plan is underpinned by a sound evidence base.

In this regard we note that the broad thrust of the questions are focussed on matters of principle, for example, whether new housing should be provided on either Green Belt land or existing employment sites.

BOC are concerned to ensure that the emerging housing strategy set out in the Black Country Core Strategy fully recognises the constraints of existing commercial and industrial business, particularly their operational facility at Knowles Road, Wolverhampton WV1 2ET in respect of potential noise impacts on incoming residents.



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.

With regards to the potential to locate housing on existing employment land, BOC submit that suitable sites must be carefully selected, with the evidence base justifying their selection ensuring that matters of potential noise impacts from existing commercial and industrial premises are fully taken into account.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account when considering sites to allocate for housing.


Site specific considerations/representations

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
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

BOC are concerned that Strategic Option 1B - Restructure the Growth Network with more occupied employment land being redeveloped for housing in the Regeneration Corridors could result in the inappropriate allocation of employment land for residential development. BOC are concerned to ensure any decision to reallocate employment land for housing fully recognises the constraints of existing commercial and industrial business, particularly their operational facility at Knowles Road, Wolverhampton WV1 2ET in respect of the potential for unacceptable noise impacts on incoming residents.


In particular, the Economic Development Needs Assessment (EDNA) reviews a number of employment sites in the plan area, including Site Ref.186 Lower Walsall Street (MU1), which is categorised in the EDNA as a "Housing Consideration". This site (MU1) is situated immediately to the north of the BOC site and is allocated in the Bilston Corridor Area Action Plan (AAP) for "mixed uses". It is described in the AAP as an "existing employment area of poor quality, where comprehensive redevelopment for housing is not likely to be deliverable, but where a mix of compatible uses could be appropriate, if well-designed".

BOC consider that housing and other similar mixed uses may not be appropriate within at least a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET and object to any residential and mixed use allocations within this area.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account.

In conclusion, any policy allocations for such uses in close proximity to BOC's facility would need to be based on a sound evidence base including sufficient noise surveys that confirm existing noise levels are appropriate (particularly at night), and the surveys should be at a time and date agreed in advance with BOC in order to ensure that they are representative of BOC's full night time operations.

In the absence of such evidence, BOC object to any residential or mixed use allocations within a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET.


Question 49a - Policy DEL2 Managing the balance between employment land and housing

In terms of Issues and Options question 49(a), BOC are strongly supportive of the retention of Policy DEL2 Managing the Balance between Employment Land and Housing which states that before considering the release of employment land outside areas identified for housing growth, the Council will ensure:

* Satisfactory arrangements for the relocation of existing occupiers to safeguard the existing employment base
* That the development does not adversely effect the operation of existing or proposed employment uses
* That the site is no longer viable and required for employment use.

BOC strongly support the retention of Policy DEL2 as it is essential to ensuring that key existing businesses such as the BOC facility at Knowles Road, Wolverhampton WV1 2ET , which operate on a 24 hour basis, are protected in the longer term. BOC support this policy and its retention irrespective of overarching site allocations because it is able to consider more fine-grain site specific matters than a wider allocation.

In this regard, BOC are particularly concerned that housing may not be appropriate within at least a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET and object to any residential allocations within this area. Any housing proposals within this area would need to be based on sufficient noise surveys confirming that existing noise levels are appropriate (particularly at night) and policy DEL2 can provide that safeguard through criterion 2.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account.

Where noise surveys are to be undertaken, BOC request that they are informed in advance of the proposed survey times to ensure that the results are fully reflective of BOCs regular operations. BOC reserve the right to comment on the adequacy and reliability of such surveys once they have been submitted.

In addition the costs of relocating a BOC operational facility which has specialist purpose built equipment are such that relocation is unlikely to be possible and the policy should recognise that such facilities cannot easily relocate and will therefore need to receive adequate in situ protection.


Review of Existing Core Strategy Policies and Proposals
Policy EMP2- Strategic High Quality Employment Land and Policy EMP3 - Local Quality Employment Land (Questions 51-53)

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?

The BOC site is currently within a designated Local Quality Employment Area defined in Policy EMP3 as "characterised by a critical mass of industrial, warehousing and service activity in fit for purpose accommodation with good access to local markets and employees".

Policy EMP 3 states:

"These areas will provide for the needs of locally based investment and will be safeguarded for the following uses:
* Industry and warehousing
* Motor trade
* Haulage and transfer depot
* Trade wholesale retailing and builders merchants
* Scrap metal, timber, construction premises and yards
* Waste collection, transfer and recycling uses".


BOC is a member of The Linde Group, a world leading gases and engineering company with 50,000 employees working in around 100 countries worldwide. It produces industrial gases for the healthcare, industrial, construction and hospitality industries in the form of cylinder gas, special products (refrigerants, industrial chemicals/gases, and liquid helium for medical scanners for example) and the bulk delivery of liquefied industrial gases by tanker. It also provides on-site gas generation for certain large scale facilities.

BOC are fully supportive of the main thrust of policies EMP2 and EMP3 in that they seek to protect employment land. Whilst the BOC site at Knowles Road, Wolverhampton WV1 2ET has an allocation under EMP3, they contend that their operations are within a critical sector of the economy and are worthy of a higher level of protection.

In this regard they could be considered as falling within the 'high technology based sector' and therefore allocation under policy EMP2-Strategic High Quality Employment Land.

Any review of EMP2 and EMP3 should recognise the strategic nature of the BOC site and the important role it performs, and provide it with adequate protection..

RE: BLACK COUNTRY CORSE STRATEGY ISSUES AND OPTIONS QUESTIONS


Please find below the responses from William Davis Ltd:
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies?
The adopted core strategy pre-dates the 2012 National Planning Policy Framework (NPPF.) There is a need to re-assess the soundness of the existing and emerging policies against this. Moreover, the acknowledged scale of the housing requirement within the area and the associated Green Belt release forces more than a partial review. The proposals within the Issue and Options paper are fundamental changes and require a full review and re-structure of the document.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review?
The proposed documents to form the evidence base for the Core Strategy are considered sufficient; however it is essential that the Green Belt review is undertaken comprehensively. The Green Belt review should acknowledge that the release of smaller parcels of land for residential use in some areas may be more appropriate. The review should not preclude this approach by only assessing larger sites.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?
Whilst it is accepted that a Duty To Co-operate to meet Birmingham's unmet need is established within the Issues and Options document which is in-line with paragraphs 156 and 178 of the NPPF; it is considered that due to the proximity of the Black Country to Birmingham and the available infrastructure, employment, and land to accommodate growth, the proposed accommodation of 3,000 of the 38,000 shortfall is too low and should be revisited following the Green Belt review. This sentiment is echoed within the 2017 White Paper "Fixing our broken housing market" where it is discussed plans should incorporate an "honest assessment of the need for new homes." Moreover, the White Paper discusses the need for Local Authorities to "work with their neighbours so that difficult decisions are not ducked." It is considered this direction and strategy needs to be incorporated more closely with any emerging policy and associated housing target.

Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance?
The NPPF states in paragraph 22 that "policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose." This is acknowledged within the EDNA and therefore is supported. However, the long term goal of placing a residential focus on these sites is not. It is apparent from the Annual Monitoring Reports (AMRs) of Walsall and Dudley (both 2016) that this is failing and housing land should be re-allocated within the forthcoming Green Belt review. Walsall discusses "land being lost from employment to use uses is more gradual than anticipated in the BCCS targets" and within the AMR actually shows an increase from residential land to employment land of 1.47 hectares in 2015-2016. Dudley can only demonstrate 8 Hectares of land from employment to residential between 2011 and 2016 against a target of 57. It is apparent from this evidence that the current requirement is unattainable.

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

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review?
The issues set out in Part 3 require some adjustment as they appear to underestimate the difficulties of retaining the existing strategy whilst acknowledging the need for the release of Green Belt land to sustainably meet residential need.

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

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

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network?
It is considered these policies are not in accordance with the requirement to release Green Belt land to accommodate the increased housing need. Therefore, they should be altered to be harmonious with this.

Question 10 - In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy?
Whilst it is not suggested an alteration of the regeneration corridors is required in order to support the emerging growth within the Black Country, there is a clearly a need to offer a broader focus on infrastructure, employment and housing ; as the geographical extent of the current corridors does not support the sustainable release of Green Belt land.

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

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

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

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

Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA?
No. A successful Green Belt review, a Core Strategy that embraces a shift in the nature of development and Regeneration Corridor alteration will allow for the HMA to meet its own OAN.

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

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

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

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

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

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

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

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

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

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

Dear Sir / Madam

Black Country Core Strategy Review - Issues and Options Consultation Response
Introduction We are writing to provide our response to the Black Country Core Strategy Issues and Options consultation on behalf of our clients who own land to the north of Hardwick, in the District of Walsall. As well as submitting a response to the questions set out in the Issues and Options document, we have also submitted our client's land to be considered through the Call for Sites process.
This letter includes our response to the following questions:
* Question 1 * Question 2 * Question 3
* Question 5 * Question 6 * Question 7
* Question 8 * Question 9 * Question 11
* Question 12 * Question 13 * Question 14
* Question 15 * Question 21 * Question 35
* Question 36 * Question 37 * Question 38
* Question 39 * Question 40 * Question 42
* Question 43 * Question 44 * Question 45
* Question 49 * Question 95

Site Context

Our clients' land is located adjacent to Chester Road to the north of Hardwick. Their land is approximately 23.6 hectares in size and is currently used for agricultural purposes. We consider that this land could be developed for residential or retail purposes and would form a logical extension to the existing settlement with a defensible boundary. We have attached a Call for Sites form and a location plan for your reference.

Issues and Options Response

Question 1

We consider that the emerging Core Strategy should be the subject of a full review. The adopted Core Strategy predates the National Planning Policy Framework (NPPF) and the updated Core Strategy should be fully updated to take account of a change in circumstances. It covers four Local Authorities and is therefore crucial that the spatial strategy is fully reviewed so that all of the policies are relevant and up to date. Also the scale of the proposed changes to the existing strategy warrants a full and comprehensive Review. It is also essential that the Review takes account of the Birmingham Housing Market Area (HMA) shortfall.

Question 2

No - Wolverhampton City Council is the only Black Country Local Authority which has updated it's Strategic Housing Land Availability Assessment (SHLAA) in 2017. Walsall's SHLAA is from 2016 and both Dudley and Sandwell's SHLAAs cover the period of 2015/2016. We consider that all of the SHLAAs must be updated to
represent the current availability of housing land.

Question 3

The figures in the Housing Supply Background Report (July 2017) are based on the adopted Core Strategy requirement from the 2006-based household projections that were published in 2008. We consider that these figures are outdated and the figures in the Housing Supply Background Report should be based on up to date housing requirement figures as set out in the Strategic Housing Market Assessment (SHMA) 2017.

There is also an inconsistency with the housing requirement within the Issues and Options document. The Core Strategy states that the housing requirement is 78,190 dwellings. However, table 7.1 of the SHMA states that the total Black Country housing requirement totals 78,105 dwellings. This point should be rectified.

We do not agree that 3,000 dwellings is an appropriately evidenced contribution towards the 38,000 dwelling Birmingham HMA housing shortfall. Although it is positive that the Black Country Local Authorities have included a figure to contribute to towards the HMA shortfall, there is no evidence to support the 3,000
dwelling figure and we consider that the Black Country will be expected (and potentially capable) to contribute more than this once distribution figures/locations have been finalised.

Question 5

We agree. NPPF paragraph 83 states that "Green Belt boundaries should only be altered in exceptional circumstances". The proposed 21,670 (+3,000 BHMA addition) housing shortfall and limited availability of alternative sites should count as exceptional circumstances. Birmingham did not have enough brownfield
land or other suitable alternatives to meet its housing need, and therefore 6,000 dwellings have been allocated within former Green Belt land at Langley, Sutton Coldfield. The Black Country's spatial connection and proximity to Birmingham means that areas of Green Belt land within the Black Country will be amongst
the most sustainable options to locate new residential development to help meet the HMA shortfall.

Question 6

We agree.

Question 7

We object to the adopted Core Strategy Sustainability Principle 4 'Brownfield First' as it is contrary to paragraph 17 of the NPPF which states that the principles of planning should 'encourage the effective use of land by reusing land that has been previously developed (brownfield land), it does not refer to prioritising
brownfield land before Green Belt land. Sustainable Principle 4 should be amended to be in accordance with the NPPF. This principle is potentially irrelevant where there is insufficient brownfield land to meet the housing requirement and all sites identified are required to meet the housing need.

Question 8

Strategic Objectives should be reviewed to include new housing developments which is a key focus at present due to the housing shortfall within the HMA. There is a significant shortfall of housing land currently available within the Black Country and the HMA. Therefore we consider that finding land for 21,670 (+3,000
BHMA addition) dwellings should be a key spatial objective within the Core Strategy.

Question 9

We do not consider that the policies should be retained. Policy CSP1 and CSP2 are old policies which predate the NPPF. The Black Country requires a new strategy for housing growth to deal with the significant Black Country and Birmingham HMA housing shortfall and therefore the policies should be updated
accordingly.

Question 11a

We support Strategic Option 1A "continue to strengthen the Growth Network with some corridors being housing led and others employment led. Remaining housing and employment land growth to be accommodated in the green belt". We consider that there would be a significant loss of potential employment land if Option 1B is selected which is required in order to meet the Core Strategy Vision of 'Economic Prosperity'. Issues of viability are a potential major challenge for this Option which may result in some housing/employment needs not being met if sites don't come forward during the plan period. We consider that a range of sites will need to be allocated which promote a balanced housing portfolio.

Question 12a

The theoretical capacity of our client's site is approximately 495 dwellings at 35dph using 60% capacity. Suitable sites should be adjacent to existing settlements and have a defensible boundary, such as roads or railway lines. The site we have identified could be reduced to provide a smaller housing opportunity north of Hardwick.

Question 12b

We consider that land to the north of Hardwick east and west Chester Road provides a potential location for sustainable growth and the railway line acts as a defensible boundary. The scale of opportunity to meet spatial option H1 could be considered through a detailed review with the Council's policy team.

Question 13a

Yes we also support spatial option H2 because we recognise that the Council will have a range of housing sites to consider. We propose that the land north of Hardwick could also be considered for a larger SUE opportunity at circa 600+ dwellings . This opportunity could include land to the south west of our client's site.

Question 13b

This will very much depend on the assessment of existing infrastructure and will need to be reviewed on a site by site basis.

Question 13c

We consider that land north of Hardwick should be considered as a potential SUE opportunity. This may require improved highways, education and community infrastructure.

Question 13d

The core strategy could set out high level strategic infrastructure expectations and capture cross boundary requirements. However more detailed site specific requirements should be left to local policies.

Question 14

We consider that a range of small / medium scale infill and SUE opportunities together with any re-use of brownfield sites could provide a range of sites suitable for meeting the Objectively Assessed Housing Need (OAHN).

Question 15a

We support the export of housing growth across the HMA area. The HMA area represents the most sustainable approach to solving the overall housing requirements in both the Black Country HMA and other neighbouring authority areas.

Question 15b

The consideration to other areas meeting the Black Country's housing requirement should only be given where evidence shows that the land within the Black Country cannot accommodate all of this need.

Question 15c

If housing has to be exported beyond the Black Country then first consideration should be given to areas close to the Black Country boundaries or via public transport corridors that serve the Black Country.

Question 21

We do not consider that Policy DEL1 should seek to assess infrastructure on the basis of whether the site is in the existing urban area or with the Green Belt. There is no evidence that Green Belt sites have any greater ability to pay more towards infrastructure (for example roads, utilities etc) than brownfield sites. Green Belt sites often have high infrastructure start up costs which need to be properly taken into account. Therefore we consider that the policy should be updated and based on a site by site considerations.

Question 35

We do not consider that Policy HOU1 is clear enough to reach an informed conclusion. Paragraph 6.20 states that the SHLAAs are up to date for the four Authorities. We do not agree with this statement as only Wolverhampton's SHLAA is from 2017, the rest of the SHLAAs are from 2015/2016. All of the SHLAA's should be updated to show the current supply of housing land.

Appendix B of the 'Black Country Housing Trajectory' sets out that the Authorities have not met their cumulative Core Strategy Target between 2006/07 - 2015/16 - cumulative target between 2016/17 to 2025/26 is even more aspirational. The Councils need to identify more sites in order to deliver this target.

The total completions figure for Walsall within Appendix C of the 'Black Country Housing Trajectory' is inconsistent with the figure in Table 1 of the Housing Supply Background Report (HSBR) July 2017. The BCCS refers to 6,137 dwellings whilst the HSBR refers to 6,165 dwellings. This inconsistency should be rectified.

Once the SHLAA evidence for the BCCS area is consistent and up to date the position on supply of deliverable housing sites should be made available to enable an informed review of whether the OAN housing supply is appropriate for the identified OAN.

Question 36

Before a review of Policy HOU2 and Table 8 is pursued, further evidence should be provided on whether the accessibility and density standards have been successful. We consider that to apply blanket policies on density do not always lead to the most appropriate forms of development.

Question 37a and 37b

Further evidence should be provided to confirm what proportion of housing delivery across the Black Country has been on sites of 15 dwellings or more. Where for example, a significant number of schemes are being built comprising between 10-15 dwellings, then a review of the threshold may warrant being undertaken.

Question 38

Not necessarily - the density of any new development should be appropriate to the density of the existing surrounding area, not necessarily being a lower density just because its a Green Belt release or higher density because it is a brownfield site. Should be done on a site by site basis.

Question 39

Yes potentially. Where car ownership / access to public transport can be shown to be greater for different types of housing then separate accessibility standards should be applied.

Question 40

Yes as long as they are in line with up to date evidence. The most up to date evidence should be applied.

Question 42

Prior to any change being proposed to the affordable homes target, detailed evidence should be undertaken to review a range of matters including viability and past deliver across the BCCS area.

Question 43a and 43b

Where evidence demonstrates the reducing the threshold to 11 homes or more will be achievable and viable then yes. However, there is a need for an achievable up to date affordable housing viability assessment in
order to assess whether this threshold is viable.

Question 44a and 44b

As per our responses to Q's 42 and 43a, the decision as to whether the affordable housing requirement should be changed requires further detailed evidence (viability and past delivery) to demonstrate that any changes are supported with up to date evidence.

Question 45

This question makes a sweeping assumption that all Green Belt sites have a greater financial viability than brownfield sites. This may not always be the case where significant investment is required in new infrastructure and S106 obligations are overloaded without due regard to site viability. Unless viability
appraisals are undertaken as part of a comprehensive approach including a review of infrastructure requirements, the basic assumptions should be properly supported by appropriate evidence.

Question 49a and 49b

Where evidence can be provided which clearly demonstrates that employment sites are no longer required for their current use then use for residential development may be appropriate. Of all of the BCCS Authorities, Walsall has the largest areas of Green Belt land and therefore, parcels adjacent to settlements within Walsall should be seriously considered for release to meet the housing requirement within the Black Country.

Question 95a

Where appropriate sites of sufficient scale can be identified to provide opportunities that meet the Garden City / Village principles then they should be considered.

Question 95b

Whether greenfield or brownfield sites are considered, there will need to be careful consideration of site details and context, including viability. These details will determine how the Garden City or Village principles could be applied.

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?
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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

BLACK COUNTRY CORE STRATEGY ISSUES AND OPTIONS CONSULTATION

We write on behalf of our client, ALDI Stores Ltd, in response to the current Black Country Core Strategy Issues and Options consultation. Our client has a number of existing and planned stores across the Black Country area and is a major employer in the region. ALDI has a particular interest in the Black Country Core Strategy in light of ambitious future investment plans across the four local authority areas.
Representations relating to those questions considered most relevant to our client are set out below. A completed copy of the standard consultation response form is also attached.
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.
Table 1 indicates that a 'Retail Capacity Study' and 'Town Centre Uses Study' will form part of the updated evidence base supporting the Core Strategy Review. Our client strongly agrees that the Core Strategy Review must be informed by new retail evidence.
The retail policies of the current Core Strategy are based on evidence dating from 2009. Given that so much has changed in terms of retail provision since this date, the household shopping surveys on which the policies are based are of limited use. New and up to date retail evidence, based on a new household shopping survey to identify existing patterns of retail expenditure, is therefore essential.
The new Retail Capacity Study must consider both quantitative and qualitative factors regarding need. Without doing so, there is a danger that the study will fail to pick up issues relating to the geographical distribution of facilities and areas of under provision. The evidence base should also include a full health check assessment for higher order centres.
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The consultation document states that the retail evidence will inform the Draft Plan stage, which is currently due to be consulted on in September 2019. On this basis, the Preferred Spatial Options stage would be prepared without the benefit of an updated retail and town centre evidence base.
Reference to Table 1 indicates that the evidence base relating to all other major topic areas, excluding waste, is programmed to be completed at either Issues and Options or Preferred Spatial Options stage. Given that the existing retail evidence base dates back to November 2009, our client would like to see the new evidence prepared at an earlier stage to inform the Preferred Spatial Options stage.
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.
We do not wish to comment directly on whether the employment land requirement identified in the Economic Development Needs Assessment (EDNA) is appropriate. We would, however, emphasise the importance of the Core Strategy Review being sufficiently flexible when it comes to the future use of existing employment areas.
Paragraph 3.29 of the Issues and Options document does recognise that "there may be a limited number of existing employment areas which are unlikely to be 'fit for purpose' and could be considered for redevelopment to alternative uses, especially housing". In order to promote economic growth, the Core Strategy Review must not protect employment land that has no realistic prospect of coming forward for such uses. Equally, flexibility is required in relation to the reuse of existing premises/land that is no longer suitable for employment use.
Any assessment of employment land should not focus entirely on the need for, and protection of, solely B-class uses. It should also recognise the importance of other forms of economic development, including retail. The Core Strategy Review should therefore allow sufficient flexibility for the reuse of employment sites, where appropriate, for retail purposes, in order to support the sub-regional economy, through local and inward investment.
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 set out in Part 3 reflect the main strategic challenges that need to be addressed in the Core Strategy Review. Key Issue 1, updating the evidence base, will be fundamental to ensuring that the other matters identified are addressed.
Taking Key Issue 4 for example, Paragraph 3.31 notes that the primary evidence base informing the Core Strategy's retail and centres policy framework dates back to November 2009. Given the dynamic nature of retail and centres, this evidence is now significantly out of date. As set out above, it is important that this work is undertaken at an early stage to ensure that it can effectively feed into the review of the Core Strategy.
It is also noted that a number of the 'Key Issues' identified are interlinked. Referring to Key Issue 4, it is clear that policies to support strong and competitive centres will be influenced by other areas of the Core Strategy Review. This includes the commitment to delivering significant levels of housing and employment growth. The location of new housing and employment growth will directly affect the demand for retail provision over the plan period.
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Paragraph 23 of the NPPF makes it clear that planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period. In doing so, the NPPF makes it clear that needs for retail (and other main town centre uses) must be met in full. The retail need for the Black Country area must therefore be met, even if there is a requirement for new centres (potentially as part of new settlements) or provision in out of centre locations (where the necessary tests are met).
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?
Paragraph 4.7 of the Issues and Options document recognises that, following the completion of the evidence base summarised in Table 1, some of these objectives may need to be amended. The changing role of centres is provided as one such example. We would support the need for the spatial objectives to be revisited when the necessary evidence base is in place.
It is, however, noted that the first objective refers to focussed investment and development in comparison shopping and other specific town centre uses within the four Strategic Centres. No reference is made to convenience retail. There remains a need to support the provision of convenience food retailing within and adjoining Strategic Centres (and potentially outside those centres, in out of centre locations) in order to meet demand from the existing and future population.
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 both Policy CSP1 and CSP2 should be updated and amended to reflect new evidence and the required level of growth over the plan period. As it stands the figures provided in each policy are based on out of date evidence, for example, retail evidence dating to 2009.
Greater emphasis should be placed on the provision of new convenience floorspace to serve the Strategic Centres and Regeneration Corridors. An updated Policy CSP2 should also reflect the need for sufficient convenience floorspace to be provided in order to serve the new growth proposals outside of the Growth Network.
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?
On the basis of the opportunities and challenges set out in the Issues and Options document, Strategic Option 1A is, in principle, the most realistic and deliverable approach to meet the required need over the plan period.
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.
Paragraph 5.7 of the Issues and Options document notes that new housing may in some locations create a need to expand health, education and other community services. It continues by stating that as options
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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.
Whilst not strictly 'social infrastructure', it is important that the Core Strategy Review provides flexibility for the market to deliver sufficient convenience retailing, in the right locations, to support the significant planned housing growth.
Section 6 Review of Existing Core Strategy Policies and Proposals
Table 3 of the Issues and Options document provides an overview of the extent to which the Core Strategy policies may change as part of the review process. The table recognises that Policy CEN1 to CEN7 will most likely be subject to major change in most cases, with criteria and thresholds likely to be reviewed based on new and emerging evidence.
Our client supports the commitment to review the relevant retail policies, and the recognition that they will require major change. This must be based on a new retail evidence base, which is prepared at an early stage of the review process.
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.
There remains a need for a policy to provide appropriate criteria to assess the release of employment land to other uses.
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.
Policy DEL2 currently relates specifically to the balance between employment land and housing. The Core Strategy Review, and Policy DEL2 specifically, should recognise that schemes for uses other than housing could also be appropriate. This could include other employment generating activities, such as retail.
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.
We would have no in principle concern with Policy CEN1 and CEN2 being merged. Our client is more concerned with the content of the policy as a whole.
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 hierarchy of centres currently set out in the Core Strategy is appropriate in principle, e.g. the identification of strategic, town and local/district centres. The existing Core Strategy is, however, too prescriptive as to the level of development which can be brought forward in, or on the edge of, any of the
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particular centres. This policy, which only supports proposals considered proportionate in scale to the centre they are in, was based on the national policy at the time (which predated the NPPF).
The concept of trying to dictate at plan level the scale of development appropriate within individual centres in order to safeguard a given centre hierarchy, is no longer supported by national guidance. National policy now requires Local Authorities to plan positively, to support development within town centres and to promote competitive town centres, without specific reference to the potential effects of development in 'Centre A' or 'Centre B'.
Question 59
Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.
The centres included in the hierarchy should be objectively reviewed as part of the Core Strategy Review. The retail evidence base, which should underpin the relevant policies, must clearly identify a consistent set of parameters for assessing the status of individual centres. This should be applied across the four Local Authorities in an objective way.
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.
This should be revisited to take account of the updated retail evidence base.
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?
It is difficult to set out specific criteria in the Core Strategy to guide any potential new centres. The Core Strategy should, however, recognise that new strategic housing developments/urban extensions may require well located new centres to serve them.
Question 64
Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?
No, there is no need to set targets for convenience retail floorspace.
The retail evidence base assesses capacity for new retail floorspace based on population and expenditure projections. This information should be reviewed regularly in light of the particularly dynamic nature of the retail sector. Such assessment of 'need' should never be considered as targets, the likely consequence of which would be to introduce 'need' into development management decisions, contrary to national policy.
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.
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The approach taken to the application of thresholds in defined centres in the current Core Strategy is overly complicated and confusing. It is too prescriptive and is predicated on outdated national planning policy, which was concerned with directing development of particular scales to 'appropriate' centres within the defined hierarchy. This approach is no longer supported by national policy.
As currently worded, even schemes of a relatively modest scale within (and on the edge of) certain designated centres would exceed the local threshold for an impact test. Given that the Core Strategy is based on meeting the need for town centre uses in accordance with the sequential approach, issues of adverse impact should not arise. It is also important that planning policies are positive and promote competitive town centre environments.
The various thresholds set out for different types of centres should be deleted, instead relying on those set out in national guidance (applying to schemes over 2,500 sq m). It is for individual Local Authorities, when preparing their own Local Plans, to justify departures from that threshold.
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 threshold approach and reference to 200 sq m is arbitrary and unjustified. In general terms, there is no justification for adding an extra layer of protection to locations which are not identified as designated centres through the Core Strategy. The policy should reflect the NPPF and the definition of town centres set out in Annex 2.
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.
The Core Strategy currently takes the approach that out of centre development is an inherently undesirable form of development. In the context of the NPPF there is a need to take a positive approach to sustainable development in plan making and decision taking. There are now only two development management tests for retail development - the sequential assessment and impact. Subject to meeting the necessary tests, there is no reason why out of centre development should not be welcomed.
Given the significant requirement for new housing across the Black Country, there is a requirement for a less rigid approach to be taken to meeting the need for future retail provision. Whilst there is general support for a town centre first policy, it is important to ensure that at the local plan level identified needs can be accommodated and delivered within or adjoining designated centres. Currently there is a tendency for town centre boundaries to be tightly drawn and reluctance by Local Planning Authorities to extend centres to allow new retail development.
Question 82
Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.
The 200 sq m threshold is not appropriate and is far too low. The threshold is arbitrary and is not based on empirical evidence.
As it stands, the application of a 200 sq m threshold would be triggered by virtually all convenience retail schemes. We also object to the application of the threshold to what would be very modest extensions to
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existing stores, even if the extension was ultimately to provide a small increase to circulation or welfare space, rather than actually increase the retail/sales floorspace per se.
We would recommend that a strategic level document such as the Core Strategy defaults to national policy in terms of thresholds for applying the impact test. If individual Local Authorities can justify lower thresholds through a robust evidence base, the relevant local plan is the appropriate vehicle for setting such thresholds.
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.
Such a policy would be unduly prescriptive. It should be for the market to dictate, rather than planning policy, how such sites would be reused. Other policies set out at a national and local level provide the basis for the assessment of such schemes.
Question 90
Do you support the proposed changes relating to managing transport impacts of new developments? Yes/No; If no, please explain why.
Our client has concerns relating to some elements of the proposed changes to managing transport impacts. In particular, any requirements for measures such as electric vehicle charging infrastructure must be carefully worded and acknowledge potential issues of viability/practicality.
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?
The Core Strategy is a strategic level plan and should not be unduly prescriptive. It should set out broad areas, with local plans then setting out detailed policies and allocations. There needs to be a clear relationship between the two levels of policy. We would therefore recommend that the Core Strategy contains less detail than currently set out in Appendix 2.

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.

Black Country Core strategy issues and options representations from CCDC

Please see attached the representations of Cannock Chase Council to the Black Country Core Strategy issues and options consultation.

I would be grateful if you could confirm receipt

Kind regards

Black Country Core Strategy
Issues and Options consultation July - September 2017
Response of Cannock Chase Council
Thank you for consulting Cannock Chase Council with regard to the first stage (Issues and Options) of the Black Country Core Strategy Review. Responses in relation to those questions of particular relevance to this District are set out below.
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?
This is difficult to conclude at this stage as much will depend on the emerging evidence as is acknowledged in paragraph 1.18. It is possible that some policies may be able to be 'stretched' or even stay the same, but in some cases significant changes may need to be made which could have cumulative impacts including cross-boundary implications, particularly in the light on ongoing work through the Greater Birmingham Housing Market Area (GBHMA) and the LEPS / WMCA.
It is noted that paragraph 1.27 (and 4.34) allows for sites to be put forward (via the Call for sites process) which lie within other authorities but adjoining the Black Country to enable cross boundary discussions to take place. As stated in paragraph 1.27, those sites would need to also be submitted to the relevant authority within whose boundaries the site lies (either all or in part) as these would also need to be considered thorough the Local Plan process for the authority in question. In these instances discussions would need to be had through the Duty to Co-operate in in the context of the emerging evidence base, ongoing strategic work as referenced above, and through any appropriate local plan reviews.
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? 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 impression is given on page 19 that the GBHMA study primarily relates to Green Belt but its scope is wider than that and the table should reflect the full scope of the study.
The above mentioned study includes landscape assessment which complements, but is a separate assessment to the Green Belt work. However, given the cross boundary implications, account should be taken of Landscape Character Assessment at the more localised level where such evidence exists. Cannock Chase Council has published (and updated) its Landscape Character Assessment so this will need to be given due consideration as work on the plan moves forward, as will consideration of other evidence of relevance such as that relating to the historic environment / landscape and setting. Further discussions on these matters would be welcomed as the detail of the plan starts to emerge.
Further discussion will be needed on transport to ensure that the full evidence base and most up to date situation is considered in relation to the appropriate stage of the plan.
It should also be noted that the evidence base on Cannock Chase SAC is in the process of being updated and so the Black Country authorities will need to continue to engage (as they currently are doing) in this process via the Cannock Chase SAC partnership. This is covered under key issue 5 and also in paragraph 3.61 but needs to be cross referenced to the evidence table.
Discussions are also ongoing in relation to the Cannock Extension Canal SAC and also the restoration of the line of the Lichfield and Hatherton canal and it is possible that further evidence may be required in relation to this and the advice and guidance of Natural England will be essential as the plan progresses, particularly if there are cross boundary implications from the emerging plan so dialogue under the Duty to Co-operate will need to be ongoing (again as already is the case).
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?
Paragraph 3.18 references the agreement to test the accommodation of an extra 3000 homes up to 2031 beyond local need to help address the shortfall in the wider HMA, however this will need to be considered in the light of the emerging evidence base in the GBHMA so the situation needs to be kept under review.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt review?
Yes, as this picks up the higher tier work which is ongoing at the GBHMA level, however discussions will need to be ongoing under the Duty to Co-operate in relation to more localised work to ensure alignment and consistency where there are cross boundary implications: Cannock Chase Council published its own Green Belt assessment in 2016. Comments submitted under Question 1 are reiterated here in relation to the Call for Sites process.
Green Belt options should not only be considered in terms of their suitability (or not) for development but also whether they can play a role in being utilised more effectively in terms of a Green Infrastructure network which can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) which can enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale. This should be explored further, in conjunction with partners across the HMA as work on the plan progresses.
Question 7: Do you think that the Core strategy vision and sustainability principles remain appropriate?
In principle, yes, however as set out in the response to Question 1 this will need to be kept under review in the light of the emerging evidence base. Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale.
Question 8: do you think that the Core Strategy spatial objectives remain appropriate?
In principle, yes, however as set out in the response to Question 1 this will need to be kept under review in the light of the emerging evidence base. Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale (potentially including that which may impact on the Cannock Chase SAC).
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?
In broad terms, yes although this will depend upon the detail of the emerging evidence (and see response to Question 1). Green Belt policy will need to be reconsidered however as new defensible and permanent boundaries may need to be set through this process.
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? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities eg proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
Firstly, there would need to be clear and justified evidence that the Black Country has explored every reasonable opportunity to deliver as much development as possible within its own boundaries so this will depend upon the evidence which is still underway. Secondly, any shortfall relating to the Black Country should be considered 'in the round' ie not just in terms of those areas which have a direct boundary with the Black Country but as a whole as per the evidence base which is currently being prepared across the GBHMA (which will also avoid the risk of any double counting).
Earlier questions have raised the matter of the Call for Sites potentially covering cross boundary options including sites in neighbouring districts and our response to questions 1 and 5 should therefore also be noted here.
Should export of growth be required, close working will be required to ensure sustainable development and alignment between the BCCS and neighbouring plans.
Question 19a / b - do you support Spatial Option E4? Should any factors be taken into account in an assessment of the opportunities?
Please see answer to question 15a.
Questions 26 / 27 and 28: Infrastructure
As the plan progresses, further discussions will be required on infrastructure issues depending on which sites / options are to be looked at further, as there may well be cross boundary implications which need to be addressed.
Questions 32 / 33: Health and Wellbeing
The role of sport and recreation could be strengthened (figure 10) as could the role of Green Infrastructure in providing for a range of needs.
Question 38: do you think that the current accessibility and density standards are appropriate for Green Belt release locations? If no, what standards should be applied in these locations and why?
As the adopted strategy does not allow for Green Belt release, presumably this means those standards set out in policy HOU2? Not all Green Belt sites will be the same as their context will vary on a case by case basis, and while the current policy allows for this to some extend further discussions will be needed in areas where there are cross boundary implications to ensure consistency between local plan approaches.
Question 49a: is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
Employment policy needs to be brought up to date to reflect the NPPF. Given the pressures on the need to find enough sites for housing poorer quality employment sites which are no longer fit for purpose should be considered for housing needs where appropriate and sustainable to reduce pressures elsewhere.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in policy EMP1? Do you think that distinguishing between Strategic high quality Employment Areas and Local Quality employment Areas is still appropriate?
The Core Strategy needs to reflect current national policy and guidance. As the plan (and evidence base) moves forward, delivering any net uplift (as per paragraph 6.58) will need to be explored further. As with housing, growth may well have strategic and cross boundary implications and further dialogue will be needed as the plan is developed.
Question 55: do you agree with the proposal to retain Policy EMP5?
Yes, it is important that the developers / owners of major new job-creating developments contribute to the recruitment and training of local people, which could also have cross boundary implications and benefits.
Question 56: Do you agree with the proposal to update Policy EMP6 in line with current priorities?
Yes. By promoting and enhancing the range of facilities within the Black Country it will provide visitors and residents with a range of activities which may reduce the pressures upon other, sensitive environments which are a draw for tourism, including the Cannock Chase SAC.
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 and local centres?
Yes - this approach is appropriate and consistent with the NPPF where supported by evidence and is designed to protect the vitality and viability of town centres which also has cross boundary implications.
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 - see answer to Question 74. This does not just relate to the vitality and viability of Black Country centres but also has implications beyond the Black Country.
Question 88: do you agree that the overall transport strategy supports all of the Core strategy spatial objectives? Together with questions 89 (proposed changes to the priorities for the transport network), 90 (changes relating to managing transport impacts of new developments), 91 (the efficient movement of freight), 92 (network for walking and cycling) and 93 (changes to Policy TRAN5 - travel and travel choices)
The transport implications of the plan will have far reaching consequences beyond the boundaries of the Black Country. Cannock Chase Council continues to engage proactively with a range of partnerships dealing with transport issues and will continue to do so as the detail of the plan progresses.
Re: 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.
Reference should be made to completion of the £100m, Walsall-Rugeley, Chase Line electrification/linespeed upgrade, which will lead to faster and more frequent services north of Walsall to the west Coast Main Line at Rugeley Trent Valley. The route will also provide an alternative diversionary route between Birmingham and Stafford for long distance passenger and freight services, when the Birmingham-Wolverhampton-Stafford, Stour Valley route, is closed for maintenance.
Reference should be made to the future ownership of the M6T and also the future role of the parallel A5T, which has a dual carriageway section through the Walsall MBC area at Brownhills.
Reference should be made to the Chase Line Station Alliance
* Network Rail and WMR is developing an innovative 'Stations Alliance', which, together with Abellio, the new West Midlands franchise operator, is hoped to bring about substantial improvements to West Midlands rail stations.
* The Alliance has created a WMR Stations Vision so that they are instantly recognisable in the areas which they serve and also integrate properly into the community.
* Stations should act as 'Gateways,' with quality infrastructure and more facilities such as shops.
* Network Rail are only funded to maintain stations to CP3 standards and 7-9 year franchises, do little to incentivize operators to invest in stations.
* Funded by Black Country and Stoke and Staffordshire LEPs and West Midlands Rail work is already underway to develop some indicative Master Plans for two trial routes - the Stour Valley Line from Birmingham to Wolverhampton (exclusive) and Chase Line stations north of Walsall.
* Options for funding the works will also be considered as part of a commission, which is due to be completed by Autumn 2017.
* GHD consultants have been appointed and site inspections of all stations carried out on with the consultant and local authorities, was in June.
* The study is in two stages:- Stage 1 is to confirm the projects for outline development. It is anticipated that this stage will result in a shortlist of projects for further development.
* Stage 2 will develop outline a master plan for each of the prioritised stations from Stage
WMCA Transport Delivery Committee endorsed this approach on 3 April 2017.
Re: 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.
R: Reference should be made to the proposed Mid Cannock road/rail interchange proposal by Pentalver. The facility would have the potential to be served by between 4 - 6 freight trains a day and serve the Black Country area.
Question 94: do you support the proposed changes relating to environmental infrastructure and place making?
Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale (potentially including that which may impact on the Cannock Chase SAC).
Question 96: Do you support the proposed changes relating to nature conservation?
The plan will need to ensure it takes into account any cross boundary implications as set out in the response to Question 2: the evidence base on Cannock Chase SAC is in the process of being updated and so the Black Country authorities will need to continue to engage (as they currently are doing) in this process via the Cannock Chase SAC partnership. This is covered under key issue 5 and also in paragraph 3.61 and potentially a policy may be needed to address SAC issues to align with the approach of other SAC Partnership authorities. The advice of Natural England will also be key to this issue.

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.

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.




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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








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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.













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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










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




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












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




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.










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




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 .

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
The adopted Core Strategy predates the National Planning Policy Framework (NPPF). The Core Strategy should be fully updated to take account of all relevant changes in Government policies and guidance, including the implementation of provisions being brought in through the Housing and Planning Act (2016), such as Starter Homes and the Brownfield Land Register. The Black Country covers four Local Authorities and it is therefore crucial that the spatial strategy is fully reviewed so that all the policies are relevant and up-to-date. Furthermore, the scale of the proposed changes to the existing strategy warrants a full and comprehensive Core Strategy Review. It is also essential that the Review takes account of the Birmingham Housing Market Area (HMA) shortfall.
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details.
The existing evidence base is, in part, dated and needs to be brought fully up-to-date in order to provide a sound and robust basis for the emerging Core Strategy.
Our client continues to promote the acceptability of the redevelopment of the previous developed land (including Factory complex AP (UK)) at Heathfield Lane West, Darlaston (Walsall Borough) for housing development (please refer to the Call for Sites submission).
Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
We recognise that there will be a need to release greenfield (including Green Belt) land for development to plug the shortfall between the existing supply identified through the Black Country Core Strategy constituent Authorities' SHLAAs and the final objectively assessed housing need figure for the Black Country. In reviewing the existing supply data we consider that it is important to continue to encourage housing development on previously developed sites, to assist with the delivery of regeneration across the Black Country and to contribute to achieving sustainable development. There should be an appropriate balance between previously developed and greenfield land supply.
The completions and SHLAA housing supply figure of 48,185 homes includes the previously developed land (including factory complex AP (UK)) at Heathfield Lane West, Darlaston (please refer to the Call for Sites Submission). We support the retention of this site, as a suitable site for significant housing delivery, in the housing land supply.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
We agree with the essence of the key issues summarised in the first two bullet points. The Black Country Authorities should still retain their focus on supporting the redevelopment of brownfield land for housing, where appropriate, alongside the need to look beyond the existing Growth Network for additional land supply. However we consider that a full review of the Core Strategy should be undertaken, supported by a robust and up-to-date evidence base, to ensure the Core Strategy is sound.
Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
The NPPF (paragraph 17) states that the principles of planning should encourage the effective use of land by reusing land that has been previously developed. The NPPF does not provide a specific hierarchy for the development of land and therefore we recognise that having a sustainability principle that seeks to put brownfield land first could be difficult to justify and enforce. Accordingly we consider that the fourth sustainability principle should more closely reflect the wording of the NPPF. However it is important that the Black Country Authorities still positively encourage the redevelopment of suitable brownfield sites because these are still an important element of having a balanced housing land supply.
Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
We consider that Core Strategy policies CSP1 and CSP2 should be updated to reflect growth proposals beyond the Growth Network.
Question 10 - In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
We consider that the boundary of Regeneration Corridor RC5 should be expanded to include the former AP (UK) and Moxley Tip sites because these are both significant regeneration sites and both included within the emerging Walsall Site Allocations Document.
Question 11b - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.
We continue to support the redevelopment of the former AP (UK) site to housing. This site has extant planning permission (ref. 08/0394/FUL) for redevelopment to housing and is the subject of a draft allocation (HO303) within Policy HC1 of the ongoing Walsall Site Allocations Document. Proposals for the redevelopment of this site for housing are being actively pursued. We therefore strongly promote the inclusion of this site as a housing site within the Core Strategy (please refer to the Call for Sites submission).
Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.
The shortfall in housing land supply means that the percentage of housing development on previously developed land is going to decrease from the 95% target included in current Core Strategy Policy HOU1 due to the need to release greenfield land to meet the Emerging needs. The Black Country Authorities should however continue to positively encourage and support development on previously developed sites, through viability negotiations and through the use of grant funding where necessary. This will enable suitable previously developed sites to come forward for housing development at the earliest opportunity as part of a balanced housing land supply.
Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
NPPF paragraph 58 states that policies should aim to ensure that developments should respond to local character and history and reflect the identity of local surroundings. NPPF paragraph 59 identifies that design policies should avoid unnecessary prescription or detail and infers that the approach to density should be taken in relation to the neighbouring buildings and the local area more generally. The NPPF does not therefore currently set minimum density standards.
Any proposed changes to accessibility and density standards need to be justified with appropriate evidence. Before a review of Policy HOU2 and Table 8 is pursued, further evidence should be provided on whether the accessibility and density standards have been successful. We consider that applying blanket policies on density does not always lead to the most appropriate forms of development that are deliverable, viable, and compatible with the location and meet market requirements. The wording of Policy HOU2 should be sufficiently flexible to accommodate approaches to density to be considered on a site-by-site basis.
We therefore disagree with setting a minimum net density of 35dph and with a possible increase on this figure. Furthermore any proposed changes to the current accessibility standards should only be undertaken using the criteria set out in the Planning Practice Guidance.
Question 37a - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
Question 37b - If no, should it be reduced to 11 homes or more? Yes/No; If no what other threshold should be used and why?
Further evidence should be presented on what proportion of housing delivery across the Black Country has been on sites of 15 dwellings or more. The Black Country faces significant challenges over the viability of sites within its housing land supply under the current market conditions. The Core Strategy should be supported by up-to-date viability evidence. Any proposed changes to site size thresholds needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 173 & 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
Question 39 - Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
The proposal for any additional accessibility standards for particular types of housing should be justified by sufficient appropriate evidence that meets the requirements of the Planning Practice Guidance. The NPPF (paragraphs 173 and 174) sets out the need for policies to be supported by evidence, the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and the need to avoid placing the implementation of the plan at serious risk. More evidence is therefore required. We reserve the right to comment further as and when new evidence becomes available.
Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
The NPPF (paragraph 50) requires Local Planning Authorities to take Strategic Housing Market Assessments (SHMAs) into account as part of the evidence base for developing Local Plans. The NPPF also states that local planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community, as well as identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand.
Therefore it is appropriate for the 2017 Black Country and South Staffordshire SHMA should form part of the consideration in appraising the mix of homes to be delivered on individual sites. However the Core Strategy policies should avoid setting prescriptive house type targets for the Plan period to provide the flexibility for a wide range of factors to be taken into account in delivering different types of housing on sites in the Black Country over the course of the Plan period.
Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
Question 41b - A target for each authority? Yes/No; Any further comments
Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
Question 41d - Another approach altogether? Yes/No; If yes, please specify. Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.
It is considered that there is currently insufficient evidence to support a requirement for the Core Strategy strategic policies to introduce either a specific policy approach towards self and custom build housing, or a target for each authority, or a requirement for large housing sites to provide serviced plots. Whilst the Core
Strategy could encourage the development of self and custom build housing, it should not introduce specific delivery requirements and targets without robust evidence.
Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
Detailed evidence is required to determine, amongst other matters, viability and past delivery across the BCCS area, before any changes can be proposed.
Question 43a - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
Question 43b - If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?
Further evidence is required. The Black Country faces significant challenges over the viability of sites within its housing land supply under the current market conditions. The Core Strategy should be supported by up-to-date viability evidence. Any proposed change to site size thresholds needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 174 and 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the Plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
Question 44b If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
Further detailed evidence is required to support any proposed changes. The Core Strategy should be supported by up-to-date viability evidence, including with respect to whether a 25% requirement remains viable.
Any proposed changes to affordable housing requirements needs to be supported by robust evidence on viability and deliverability. The NPPF (paragraphs 173 and 174) sets out the need for policies to avoid placing such burdens on sites that their ability to be developed viably is threatened and to avoid placing the implementation of the plan at serious risk. We reserve the right to comment further as and when new evidence becomes available.
Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
Question 49b - If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.
Where there is clear evidence that the existing employment use is not required, then such previously developed sites should be released to meet the housing requirement within the Black Country. The NPPF (paragraph 17) encourages the effective use of land by reusing previously developed (brownfield) land. The NPPF (paragraph 22) also states that planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why?
Our client considers that the approach to water efficiency should reflect the outcome of the Housing Standards Review (2015) and therefore seeking a water efficiency target of 125 litres per person per day being the minimum national standard, implemented through building regulations.
The DCLG Written Ministerial Statement (WMS) issued on 25 March 2015 stated that "From the date that the Deregulation Bill 2015 is given Royal Assent, local planning authorities and qualifying bodies preparing neighbourhood plans should not set in their emerging Local Plans, neighbourhood plans, or supplementary planning documents, any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings". The Deregulation Bill was given Royal Assent on 26 March 2015.
Any variation to the national minimum standard would therefore require additional evidence. As acknowledged in paragraph 6.1.52 of the Black Country Core Strategy Issues and Options Report, the Black Country does not currently lie in an area of serious water stress and therefore it does not appear likely that a variation to the national minimum standard could be demonstrated. However we reserve the right to comment further if new evidence becomes available.
The WMS also states that the optional new national technical standards with respect to water should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered in accordance with the NPPF and Planning Practice Guidance. The Planning Practice Guidance identifies that in order for Local Planning Authorities to introduce a new requirement they need to identify a 'clear need' based on: existing sources of evidence; consultations with the local water and sewerage companies, the Environment Agency and catchment partnerships; and consideration of the impact on viability and housing supply of such a requirement.
Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
In accordance with the requirements of the NPPF (paragraph 174), in setting any local standards through Local Plan documents, "local planning authorities should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle. Evidence supporting the assessment should be proportionate, using only appropriate available evidence".
The national accessibility standards are not a requirement. The NPPF (paragraph 158) makes it clear that each local planning authority should ensure that their Local Plan is based on adequate, up-to-date, and relevant evidence. The new Core Strategy should therefore only require developers to meet the national accessibility standards if this can be justified by appropriate evidence in accordance with the criteria set out in the Planning Practice Guidance, with reference to Requirement M4(2) and/or M4(3) of the optional requirements in the Building Regulations. We reserve the right to comment further if and when new evidence becomes available.
Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
In accordance with the requirements of the NPPF (paragraph 174), in setting any local standards through Local Plan documents, "local planning authorities should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle. Evidence supporting the assessment should be proportionate, using only appropriate available evidence".
We consider that space standards should be left to developers to determine in line with market requirements.
Whilst the Housing Standards Review introduces a new national space standard, this has not been incorporated into the Building Standards and is not a requirement. Housebuilders have a vested interest in building products that meet market needs, which will sell and which are viable to build. The policies in the new Core Strategy should be sufficiently flexible to allow this to happen without adding a prescriptive policy burden. If the market demands space standards in line with the optional national standards, then it is more likely that developers will deliver these. These considerations all form part of the need to take account of 'market signals', as required by the NPPF.
The NPPF makes it clear that each local planning authority should ensure that their Local Plan is based on adequate, up-to-date and relevant evidence. The new Core Strategy should therefore only require developers to meet the National Space Standards if this can be justified by taking account of need (evidence provided on the size and type of dwelling currently being built in the area), viability (consideration of the impact of adopting the space standards as part of the Plan's viability assessment) and timing (potential need to factor in a reasonable transition period following adoption of a new policy on space standards to allow developers to factor this into future land acquisitions), in accordance with the requirements of the Planning Practice Guidance. We reserve the right to comment further if and when new evidence becomes available.
Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why
There is currently no evidence presented with the Issues and Options consultation document to use to make an informed decision on whether the standards should be different for brownfield and greenfield sites.

Question 1: Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
2.3 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.4 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.5 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.6 In terms of the Plan period proposed in paragraph 1.17, whilst a 15 year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.7 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained in the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications on the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* The OAN identified by the SHMA for the Black Country and South Staffordshire is generally supported, however, there are concerns with regard to the methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid 2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
Question 2: Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
Question 3: Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
Question 4: Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
Question 6: Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, all except for the principle to 'put brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. The is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is, therefore, suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
Question 8: Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPF's main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
Question 9: Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.6 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.
Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
Question 11a: Do you support Strategic Option 1A? Yes/No; If yes, please explain why. If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.
5.7 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.8 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
Question 12a: Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
Question 12b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
Question 13a: Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
5.9 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.10 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.11 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.12 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.13 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.14 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.15 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
Question 13c: Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?
5.16 Land at Home Farm, Sandhills is a location on the edge of Brownhills in Walsall Borough that could accommodate in excess of 1,200 homes, complete with open space, al local centre and potentially a primary school if required. A Call for Sites form is included at Appendix B, which demonstrates the sites suitability, achievability and deliverability. In addition, a Technical Compendium is included at Appendix C, which includes evidence in relation to landscape and visual matters, cultural heritage and archaeology, transportation, agricultural circumstances, ecology, flood risk and drainage and ground conditions. All of which serves to demonstrate there are no constraints to the delivery of the site and that residential development of circa 1,200 homes can be successfully achieved.
Question 13d: Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?
5.17 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.18 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
Question 15a: If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
5.19 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in both the Black Country and South Staffordshire) across authorities and, therefore, once all options within the HMA have been explored, these could help deliver growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15c: Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.
5.21 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.22 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.23 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.24 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
Question 21: Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 We are in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals proposed at Home Farm, Sandhills.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
Question 29: Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with the Core Strategy. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions in the Black Country Core Strategy Review are needed.
Question 30: Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of green field and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing green field and Green Belt sites should come forward for development as soon as practically possible. In light of the lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the plan period and the needs are met.
Question 31: Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?
6.11 When delivering green field/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous community.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing
Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
Question 36: Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
Question 37a: Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete re-assessment on accessibility and density standards as part of the emerging Local Plan Review.
Question 38: Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
Question 39: Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
Question 40: Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
Question 42: Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter
Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
Question 45: Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment
Question 49a: Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan Period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment
Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation
Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

REPRESENTATIONS
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? 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 site or in any particular areas, please provide details.
2.2 Whilst it is noted that a Black Country Economic Development Needs Assessment (EDNA) (May 2017) forms part of the Evidence Base, the assumptions on future requirement appeared to be based on growth figures for the West Midlands Combined Authority (WMCA), rather than refined to cover just the Black Country. We are concerned that using WMCA data is likely to distort growth assumptions and fail to provide an accurate economic forecast for the joint planning area, particularly as population growth and GVA peer head figures will vary across the West Midlands region. Consequently, we firmly believe further work is required to assess employment needs of the joint authority area.
2.3 Assessments on future employment needs should be based on scenarios that involve assumptions on population growth, household projections as well as subregional forecasts on GVA per head that relate to the plan area. At the very least the EDNA should have regard to the findings of the Black Country & South Staffs Strategic Housing Market Assessment (March 2017) (SHMA) which has concluded that the Objectively Assessed Housing Need (OAN) for the Black Country over the period 2014-36 is 78,190 homes. The EDNA should translate what the implications of this OAN will be on the economy, and therefore we strongly believe further work on the EDNA is required.
2.4 We support the undertaking of a Green Belt Review, as inevitably land will will be needed to meet employment and housing needs. But to support this exercise, we would suggest that further work is undertaken to assess urban capacity, particularly older employment sites, to demonstrate that options within the urban area have been fully examined.
Question 11a - Do you support Strategic Option 1A? Yes/No. If no, do you support Option 1B Yes/No. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
2.6 Point 3.16 of the Issues & Options Document acknowledges that "a key source of housing supply under the existing spatial strategy is the release of surplus employment land for housing". Given the housing need requirement for the Black Country it is considered unlikely that this approach could be wholly discarded therefore some employment land will need to be considered for release for residential development and therefore we cannot support Strategic Option 1A as it makes no recognition that some employment land will need to be released. On this basis, we consider Strategic Option B is the more appropriate to take forward; but we would suggest that other options should be explored which recognise that higher levels of employment and Green Belt land will potentially need to be brought forward to meet future needs
Question 11b - Are there any current employment areas that might be suitable for redevelopment to housing?
2.7 Low-quality employment which contributes least to the realisation of the economic development aspirations of the area should be considered first for release for housing, and should not be afforded rigid policy protection. Only the 'Best' or 'Good' quality employment land warrant protection, as these locations are the most likely to generate and support high levels of jobs. This would mean that in the Black Country only land identified as 'Strategic High Quality Employment Land' should be the only land that receives policy protection from alternative uses.
2.8 It is recognised that some areas currently defined as 'Local Quality Employment Land' play a role in the overall supply of employment land in the Black Country, but there is absolutely no justification for safeguarding these sites long term. Policy for these locations need to be flexible and responsive to changing circumstances, including the need to deliver housing.
2.9 These Representations are accompanied by a completed 'Call for Sites' form for a site known as Brownhills Business Park on Lindon Road. In the Walsall Employment Land Review (Updated April 2017) the site was allocated the reference number IN5.3. It is considered that this site is suitable for redevelopment to housing. The site is not fulfilling any meaningful economic benefits, with tenants on short-term rolling contracts with no permanence to the employment and job provision on this site. None of the uses employ significant numbers of people, and it is evident that the site is in need of investment and could be put into more productive use. The cost of redeveloping the site for commercial use is prohibitive and would make any commercial development unviable. Redevelopment of the site is needed to remediate the land, address crime issues on site and remove a site that has become an eyesore, blighting neighbouring sites. The only way to achieve this is to release the site to housing development. It is also noted that the site is located within a partial residential area and therefore redevelopment of the site for housing would not introduce incompatible uses to the area.
2.10 It is noted that the general strategy for growth in the Black Country is to focus growth around the opening of HS2 and the extension of the Midland Metro. The proposed site is not located in close proximity to either of these and would not be suitable for businesses attracted by either project. It is therefore suggested that there should be an overall review of existing employment land to evaluate consistency with this aspiration.
2.11 It is also noted that the EDNA found that over half (53%) of the Black Country's total employment land is located in Walsall. This is clearly a significant imbalance and suggests the need to review employment land allocations in Walsall. It is also noted that there are areas within Walsall, including the site, which are not located in close proximity to HS2 or the expanded Midlands Metro. It is suggested that any review should include an assessment of any employment lands proximity to these projects and potential contribution to economic growth associated with the realisation of these projects.
2.12 As previously discussed, the NPPF is clear that planning policies should not protect employment land where there is no reasonable prospect of it being used for that purpose. This site has been allocated as a Local Quality Employment Area since the adoption of the Black Country Core Strategy and has not fulfilled this allocation in the intervening years. It is considered that this demonstrates that there is no reasonable prospect of the site being used for purposes compliant with the Local Quality designation and therefore the site should not continue to be protected for employment use and should be considered for redevelopment to housing.
2.13 Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
2.14 It is recognised that there may be a role for a policy managing the release of poorer quality employment land for housing. However, the wording of such a policy needs to comply with the requirement of the NPPF which states that planning policies should avoid the long-term protection of allocated employment sites where there is no reasonably prospect of the site coming forward for that purpose.
2.15 It is noted that point 2.5 of the Issues & Options Paper acknowledges that "there is not as much surplus employment land suitable for housing as anticipated." This suggests the need to re-evaluate the policy regarding the release of poorer quality employment land for housing to ensure that poor-quality employment land is not being blocked from release unnecessarily.
2.16 It is suggested any policy concerned with managing the release of employment land for housing should include provision to review the quality of the employment use of the site, through compliance with the uses listed as appropriate for its designation, and other indications of quality, including permanence of the employment use.
Question 50 - Do you think that the Core Strategy should continue to set a target for total employment land stock in Policy EMP1? Do you think that distinguishing between Strategic High Quality High Quality Employment Areas and Local Quality Employment Areas is still appropriate?
2.17 This Representation does not seek to offer a view on whether or not the Core Strategy should continue to set a target for total employment land stock, albeit we strongly question the levels currently identified for the reasons set out previously. We do however wish to express a particular view on the distinction between Strategic High Quality Employment Areas and Local Quality Employment Areas.
2.18 The EDNA itself noted that this distinction "does not represent a common practice of designation based on the review of approaches followed by other planning authorities. Furthermore, the range used does not reflect the same scale of 'measurement'" it goes on to recommend that "this is something that may need to be considered in the future" (point 7.14). It is considered that the review of the BCCS provides the ideal opportunity to review this distinction.
2.19 The EDNA clarifies that the most common delineation used elsewhere is to rate sites on a scale of best, good and other with specific/distinct references made to key strategic sites or enterprise zones (point 7.15). Sites are allocated to a classification by way of the quartiles within which their score falls and are ordered from the highest score (100) to the lowest (0) based on the scoring of a list of assessment criteria (point 7.15). It is considered that this offers greater flexibility than the binary approach of designating sites as either Strategic High Quality or Local Quality Employment Areas.
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 should the terminology be amended?
2.20 As discussed above, this Representation questions whether distinguishing between Strategic High Quality and Local Quality Employment Land is still appropriate. The EDNA suggests that a different classification system of Premium, Very Good and Good should be used. We strongly agree with this. Any future assessment of the joint planning areas employment land supply should use these categories, so that only the best quality employment land is protected. 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?
2.21 The National Planning Policy Framework (NPPF) is clear at paragraph 22 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 and that land allocations should be regularly reviewed. Paragraph 21 of the NPPF also makes clear that policies should be flexible to accommodate needs not anticipated in the plan and allow rapid response to economic change. It is therefore the case that a thorough review of existing employment land should be carried out to evaluate the merits of existing employment areas as site such as Brownwhills Business Park are clearly no longer worthy of policy protection.
2.22 We agree that sites assessed as being "Best Urban and "Good Urban" warrant protection, so long as there is sufficient flexibility to allow alternative use in the event that circumstances change (e.g. lengthy periods of vacancy). However, there is absolutely no justification for safeguarding or restricting the use of low quality employment sites, and an alternative approach must be taken that allows flexibility.

Question 1: Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
Question 2: Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
Question 3: Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
Question 4: Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
Question 6: Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
Question 8: Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
Question 9: Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
5.6 No comment.
Question 11a: Do you support Strategic Option 1A? Yes/No; If yes, please explain why. If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
5.7 Option 1A is considered to be appropriate for accommodating the growth needs of the Black Country over the Plan period to 2036. This option would significantly boost the supply of housing land and help to meet the significant current and future identified need.
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
Question 12a: Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
5.10 No comment.
Question 12b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
5.11 No comment.
Question 13a: Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
5.12 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.13 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.14 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.15 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.16 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.17 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development. With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
Question 13c: Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?
5.18 No comment.
Question 13d: Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.20 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
Question 15a: If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
5.21 Even if all realistically deliverable options have been considered within the Black Country, there will remain an unmet need for housing. Therefore, it is necessary for the Black Country authorities to consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.22 No comment.
Question 15c: Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.
5.23 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.24 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.25 No comment.
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.26 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.27 No comment.
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.28 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.29 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.30 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
Question 21: Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 No comment.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. Committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
Question 29: Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
Question 30: Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
Question 31: Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS Housing
Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
Question 36: Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
Question 37a: Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
Question 38: Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
Question 39: Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
Question 40: Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
Question 42: Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
Question 45: Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment.
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

Question 1: Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
Question 2: Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
Question 3: Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
Question 4: Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
Question 6: Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
Question 8: Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
Question 9: Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.6 As touched upon above and throughout these Representations, it is clear that given the significant amounts of housing that will need to be delivered across the Black Country, there will be a need for a switch from a sole focus on brownfield regeneration to a need for a dual approach that focuses on both brownfield and strategic greenfield/green belt release. The focus on Regeneration Corridors and Strategic Centres was very much a product of the times and housing needs of when the Core Strategy was first adopted in 2011. In light of the emerging, higher housing requirements, it is clear that there is a need for a fresh approach to the spatial distribution of growth across the Black Country. Whilst reference to strategic centres and regeneration corridors could remain, this remit needs to be expanded to reflect the evident need for urban extensions outside of the existing growth networks. Indeed, Sustainable Urban Extensions both within the Black Country administrative boundaries and within the adjacent South Staffordshire District will be required to meet emerging housing requirements. These policies should therefore be expanded to include references to urban extensions in the form of green field land outside of the defined urban area, to ensure that sufficient certainty is built into the plan that the housing needs of the area will be met. Amending these policies to make it clear that both brown field and green field land is required will ensure that a fresh approach to spatial distribution across the Black Country Area would be secured and delivered.
5.7 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.

Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
Question 11a: Do you support Strategic Option 1A? Yes/No; If yes, please explain why. If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No;
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
Question 12a: Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
Question 12b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
Question 13a: Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
5.10 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.11 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.12 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.13 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.14 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.15 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.16 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
Question 13d: Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.18 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
Question 15a: If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
5.19 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15c: Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.
5.20 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.21 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.22 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. Indeed, there is likely to be a significant growth in the need for logistics floorspace to accommodate rapid increases in the dot.com purchasing of goods and demand for next day delivery. Efficient access to motorway junctions and the strategic road network and the availability of large sites will therefore take priority, as well as other considerations such as the ability to operate 24 hours. Placing such sites directly next to the existing urban area may therefore be impractical. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.23 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
Question 21: Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.2 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.3 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.4 No comment.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.5 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.6 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.7 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
Question 29: Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.
6.8 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
Question 30: Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.
6.9 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
Question 31: Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?
6.10 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
Question 36: Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
Question 37a: Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
Question 38: Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
Question 39: Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
Question 40: Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
Question 42: Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
Question 45: Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 Figure 11 and Table 6 of the Issues and Options Paper make no reference to Hardwick. We have replicated Figure 11 on the following page [SEE ATTACHED DOCUMENT FOR IMAGE], and labelled Hardwick which we consider should be identified as a Local Centre within the retail hierarchy. There are a number of local facilities in Hardwick, including a cluster of shops, public houses and restaurants centred around the Chester Road/Hardwick Road junction. There are 9 facilities located at this junction, which comprise of 2 no. restaurants, 1 no. public house, 5 no retail units and 1 no. A5 unit. Hardwick is therefore well served by a number of local facilities, and should therefore be a designated centre within the Core Strategy Review. This is particularly the case given that Hardwick is well-suited to accommodate future housing growth as explained in other sections of these Representations, therefore Hardwick should be designated as a centre to reflect future growth in the area.
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 As discussed above, it is suggested that through the Local Plan Review, there will be a need to designate new centres (such as Hardwick) as a result of additional housing growth. Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

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

Question 1: Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
2.4 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.5 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.6 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.7 In terms of the Plan period proposed in paragraph 1.17, whilst a 15-year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.8 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer a wide range of existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained within the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications for the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 In respect of the Strategic Market Assessment for the Black Country and South Staffordshire Richborough Estates would wish to raise the following key comments:
* In determining the OAN, there are concerns with regard to the SHMA methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In respect of the Housing Background Report, Richborough Estates would wish to make the following key comments:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid-2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
Question 2: Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
Question 3: Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
Question 4: Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher-level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
Question 6: Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
Question 8: Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
Question 9: Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
5.6 No comment

Question 11a: Do you support Strategic Option 1A? Yes/No; If yes, please explain why. If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
5.7 No comment.
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No;
5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
Question 12a: Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
Question 12b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
5.11 Richborough Estates considers that land at Pedmore Lane, Stourbridge should be considered. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability. This site would represent sustainable options for meeting housing needs arising from within the Black Country.
Question 13a: Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
5.12 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.13 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.14 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.15 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.16 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.17 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
Question 13c: Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?
5.18 No comment.
Question 13d: Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?
5.19 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.20 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
Question 15a: If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
5.21 Even if all realistically deliverable options have been considered within the Black Country, there will remain an unmet need for housing. Therefore, it is necessary for the Black Country authorities to consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in South Staffordshire) across authorities and could help deliver the necessary growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
5.22 Richborough Estates considers there are a number of locations within South Staffordshire that provide geographically strong links with the Black Country and would represent sustainable housing sites. This includes land at Sneyd Lane, Essington and land at High Hill, Essington. A call for sites submission has been undertaken in respect of these sites to demonstrate availability, suitability and deliverability. These sites would represent sustainable options for meeting housing needs arising from within the Black Country.
Question 15c: Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.
5.23 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.24 No comment.
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.25 No comment
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access). If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
5.26 No comment.
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
5.27 No comment
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
5.28 No comment.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.29 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.30 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. Indeed, there is likely to be a significant growth in the need for logistics floorspace to accommodate rapid increases in the dot.com purchasing of goods and demand for next day delivery. Efficient access to motorway junctions and the strategic road network and the availability of large sites will therefore take priority, as well as other considerations such as the ability to operate 24 hours. Placing such sites directly next to the existing urban area may therefore be impractical. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.31 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
Question 21: Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 Richborough Estates is in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 24: Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No; If yes, please provide details.
6.4 No comment.
Question 25: Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastructure required.
6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. Richborough Estates is committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.
Question 26: Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.6 No comment.
Question 27: Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
6.7 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
Question 29: Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.
Question 30: Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.
Question 31: Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?
6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
Question 36: Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
Question 37a: Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete reassessment on accessibility and density standards as part of the emerging Local Plan Review.
Question 38: Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
Question 39: Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
Question 40: Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
Question 42: Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
Question 45: Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment Question 49a: Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail Question 59: Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres
7.27 No comment
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

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

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