Policy ENV7 - Renewable Energy

Comments on Behalf of Persimmon Homes West Midlands
Planning Prospects Ltd - August 2017
Chapter / Page / Question / Paragraph: General Comment
Agree / Disagree: N/A
Comments:
Persimmon Homes West Midlands ("Persimmon") have instructed Planning Prospects Ltd to prepare and submit representations to the Issues and Options Consultation for the Review of the Black Country Core Strategy (BCCS). Persimmon have land ownership and development interests across the BCCS area, and have a successful track record in bringing forward new homes in this part of the West Midlands. These representations are intended to support and promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021. Persimmon expect to make a contribution at each of these stages, and as plan preparation moves forward it is anticipated that the comments made will become more detailed, technical and specific in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review is still to be set, detailed policy wording has not been formulated, and certain key elements of the evidence base have yet to be finalised the comments made on behalf of Persimmon are necessarily more strategic and general in their nature. In the main they seek to influence the direction of travel of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is not commented on in these representations this should not be interpreted as meaning that Persimmon necessarily agree (or indeed disagree) with it. Rather, these representations should be understood as a statement of principles, which will be fleshed out where appropriate in subsequent stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual chapters or questions around specific topics. The representations should be read as a whole to obtain a sense of the trajectory Persimmon consider the Review should follow. The short questionnaire survey (ten questions) has also been completed on behalf of Persimmon, and submitted separately.
However, a note of caution should be exercised at the outset. The Issues and Options Report (for example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but it must be remembered that over the relevant periods it has failed to deliver the overall targets in terms of new homes, employment land, offices and retail (Issues and Options Report Appendix C). This is not intended as an overt criticism, particularly in light of the challenging economic circumstances within which it has operated. However, it does serve to emphasise quite strongly the importance of ensuring the strategy and policy framework arrived at through the Review is
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formulated with great care so as to maximise the opportunity and likelihood for development requirements across all sectors in the Black Country to be met.
Chapter / Page / Question / Paragraph: 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?
Agree / Disagree: Disagree
Comments:
It is considered that a "partial" review of the BCCS should be followed with a considerable degree of caution, if at all. The existing Core Strategy was focused on urban regeneration and accommodating development needs entirely within the urban area, whereas the Review will necessarily adopt a balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core Strategy was adopted in very different circumstances following the financial crisis at the end of the last decade. It catered for different needs, with no requirement to accommodate overspill growth from Birmingham, no certainty as to how employment land requirements would evolve in subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a "Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations, is considered outdated. It has proven challenging to meet development targets set by the existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and "stretched". The approach cannot be one that seeks to shoehorn the future strategy for the Black Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new strategy is required.
Chapter / Page / Question / Paragraph: 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.
Agree / Disagree: Disagree
Comments:
The evidence set out in Table 1 is likely to be sufficient to generally support the various stages of the Review, but much depends upon the content and scope of the evidence to be prepared and until certain key documents become available it is not possible to say with certainty that they will indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green Belt Review, the second stage Economic Development Needs Assessment (EDNA) are likely to be fundamental in understanding needs and opportunities, and will be central to the nature of comments to be made by Persimmon in subsequent consultations.
To ensure an effective approach the scope of the evidence base documents should be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. It is considered that the scoping of the Green Belt Review
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particularly should be informed by a consultation process, to ensure that the exercise is ultimately completed in the most effective manner.
Chapter / Page / Question / Paragraph: 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.
Agree / Disagree: Disagree
Comments:
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue fully, but a considerable degree of caution should be applied to the suggested approach which would see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the City is unprecedented, and needs to be addressed with certainty and quickly; it is essential that this housing need is met. It is not clear how the figure of 3,000 homes has been alighted on and is currently described as being "tested", but might be compared with the 3,790 homes which North Warwickshire Borough Council are already seeking to plan for as their contribution to meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full contribution in this regard. They are uniquely placed and well related to Birmingham such to make a significantly more meaningful contribution to support delivery of unmet need from Birmingham. The "testing" of some 3000 dwellings does not appear to be a fair proportion of the overall unmet need, given the scale and relationship of the Black Country to Birmingham.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt with quickly, fairly, comprehensively and transparently. The approach is an issue for now, and must be tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing some surplus employment land for housing, with a significant requirement to release Green Belt land, is supported. This represents a clear shift away from the existing BCCS approach with its almost exclusive urban focus, but one that is necessary if development needs are to be met on viable and deliverable sites.
It is essential that the Review provides for an appropriate level of housing and meets the full housing needs of the sub region. Government policy is advocating a step change in the delivery of new housing and the BCCS Review needs that step change in order to address past under delivery. The National Planning Policy Framework states in respect of housing that "The Government's key housing objective is to increase significantly the delivery of new homes. Everyone should have the opportunity to live in high quality, well designed homes, which they can afford, in a community where they want to live. This means:
* increasing the supply of housing
* delivering a wide choice of high quality homes that people want and need
* widening opportunities for home ownership; and
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* creating sustainable, inclusive and mixed communities, including through the regeneration and renewal of areas of poor housing".
It goes on to state that "to enable this, the planning system should aim to deliver a sufficient quantity, quality and range of housing".
There are significant negative impacts which would result from adopting low levels of housing growth and these must be recognised, not least the significant impact on housing affordability and increased house prices by a lack of supply.
A low level of housing growth would not meet housing needs, would not support the economic growth aspirations and could lead to unsustainable patterns of travel with people having to travel further distances between home and work.
New housing development supports and enhances new infrastructure and is a way of providing improvements to local social and community infrastructure which would otherwise be difficult to deliver through public sector means. Government policy seeks to ensure that those communities accommodating new development see directly the benefits in improved infrastructure in their communities.
In terms of the level of growth, it is important to fully consider a number of factors which influence the level of growth to be adopted and these are set out below. It is our submission that they all point to the need for some significant additional housing growth;
Population and Household Projections - A combination of natural population growth, net in migration into the HMA in line with historic trends, together with a general trend towards reduced household sizes and therefore an increase in the number of households suggests that a significant level of growth needs to be planned for. Levels of housing need to positively reflect and balance with aspirations for economic growth and grasp opportunities to meet housing needs for both open market housing and affordable housing. It is essential that the latest and most up to date projections are used to properly understand need.
Affordability - Indications of housing affordability suggest the need for higher levels of housing growth.
Economic Needs - There is a strong and essential need to support economic growth. The delivery of housing supports a vibrant economy. New housebuilding will provide for increased construction activity with both direct and indirect jobs and economic wealth creation. The availability of new quality housing supports business and wider economic activity, promoting the Black Country for inward investment. Housing and economic needs must be aligned to support job targets.
Infrastructure Requirements -The delivery of new housing will support the delivery of required infrastructure through Planning Obligations and CIL. These infrastructure projects are unlikely to be delivered through other public sector initiatives or viably provided through other land uses.
Availability of land - Whilst land is a finite resource and there will be pressure to protect Green Belt, it is essential that new development opportunities are identified that will be viable, deliverable and of suitability to the market. Whilst urban brownfield sites provide an opportunity for some growth, there needs to be some caution in over reliance upon urban regeneration if the under delivery of the past is to be avoided. Reliance is already made on SHLAA opportunities and windfall in order to reduce net need and this again needs some caution given the challenges to delivery of urban
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brownfield sites within the Black Country. The Review should more positively plan for a greater reliance upon more market focused, deliverable opportunities which identifiable and supported by evidence of delivery and viability. Land is available including sustainable Green Belt land to meet fully all needs including needs un-met needs from elsewhere in the HMA.
Chapter / Page / Question / Paragraph: 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.
Agree / Disagree: Disagree
Comments:
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the requirement is appropriate. That said, and as expressed elsewhere in these representations, for the second stage EDNA to be effective it must be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. The Stage 1 report appears to have been informed by a narrow range of consultees, and unless this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly assessed. It is essential that the Review properly grasps opportunities for economic growth and the Black Country benefits from the prosperity of such growth. The Framework requires LPA's to do all they can to support sustainable economic growth and support the needs of business.
Chapter / Page / Question / Paragraph: 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?
Agree / Disagree: Disagree
Comments:
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is characterised by an approach which protects the Green Belt and focuses development on Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the "exceptional circumstances" threshold for allowing development in the Green Belt has been met with the development needs identified through the Review. Persimmon support the conclusion that exceptional circumstances are in place now to justify review of the Green Belt. The Review of the Green Belt is in fact well overdue, having not taken place since the 1970.'s and particularly given the failings in the delivery of housing and employment growth by the regeneration focus of the strategy of the former BCCS. It is appropriate that this should take place as part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other neighbouring authorities. However in doing so, it is important that the review is comprehensive and to the fine detail required to properly consider the potential Green Belt merits of individual sites of all scales and sizes. It is essential that being undertaken as part of the Core Strategy, it doesn't merely focus on large scale releases or strategic areas, as a range of Green Belt sites will be require of all sizes if delivery is to be supported throughout the plan period and threat to deliver are avoided.
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That said, it is not possible to comment on whether the proposed approach to the Green Belt Review is appropriate or not until the methodology has been identified. As expressed elsewhere in these representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately completed in the most effective manner.
Chapter / Page / Question / Paragraph: Question 6 - Do you agree 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?
Agree / Disagree: Disagree
Comments:
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into account through the Review, subject to the comments made elsewhere in these representations about dealing fairly, comprehensively and transparently with accommodating the overspill need for homes from Birmingham, and ensuring the Green Belt Review is completed in a comprehensive and most effective manner.
However, as expressed elsewhere in these representations, a further key issue is the need to recognise the shortcomings of the existing BCCS, the extent to which over the relevant periods it has failed to deliver the overall targets in terms of new homes, employment land, offices and retail, and through the Review to ensure the policy framework becomes one which will ensure the development needs of the Black County are met and opportunities for growth are deliverable and viable and of sufficient interest to the market.
Chapter / Page / Question / Paragraph: Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
Agree / Disagree: Disagree
Comments:
The sustainability principles should be extended to include amongst their number the specific recognition that the Black Country authorities must assist as fully as possible with meeting the overspill development requirements of their neighbours (principally Birmingham).
Reference is made to a brownfield first approach and this needs to be taken with some caution and is not consistent with the requirement of national policy. The Framework advises on an approach which "encourages" the effective use of land by reusing land that has been previously developed, but does not set out a sequential approach. Such priority for brownfield sites has played a significant part in the failing in delivery of the previous BCCS. There needs to be some care in merely carrying forward the previous vision and principles of redevelopment as set out in the previous Plan.
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Chapter / Page / Question / Paragraph: 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?
Agree / Disagree: Disagree
Comments:
It is clear that the legacy spatial objectives do not remain relevant and need to be thoroughly re-thought in order to present objectives which are relevant to the challenges today in the context especially of significant needs for housing and the failings or the previous regeneration approach. The spatial objectives are ineffectively framed around a strategy focused almost entirely on directing development towards the Regeneration Corridors. It is very clear that the BCCS Review will need to take a material change in direction and allow for the prospect of significant growth in the Green Belt in a range of locations and of different scales, as part of a balanced approach to accommodating growth. This must be recognised through the spatial objectives. It must acknowledge the requirement to accommodate development in the most sustainable manner and in the most appropriate locations including within the Green Belt.
Chapter / Page / Question / Paragraph: 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?
Agree / Disagree: Disagree
Comments:
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic Centres are appropriate. However, greater emphasis must be placed on the recognition that this forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere in these representations it is considered that the Regeneration Corridor approach is no longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should deal generally with accommodating growth in an even handed and balanced manner outside the Strategic Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned growth required in the Green Belt.
Chapter / Page / Question / Paragraph: Questions 10, 11a, 11b - 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?
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.
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If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
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.
Agree / Disagree: Disagree
Comments:
The Regeneration Corridors are a dated and artificial construct, and this approach should be discontinued. They are insensitive to market and occupier needs. The approach should be simplified by removing the corridors and accommodating development through carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping existing employment land where appropriate, and expanding into the Green Belt. This should be coupled with a straightforward criteria based approach to the development of land that is not allocated. This would be an approach focused very much on the provision of land for development, rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban capacity, broadly defined, whilst also recognising that some development needs can only be met in the Green Belt.
There is no need for a sequential approach to first prioritise the role of the Growth Network and Regeneration Corridors which has failed to deliver in the past.
Green Belt sites will be best provided for on a wide range of smaller sites and some care needs to be taken upon reliance upon large scale urban extensions given the lead in time and challenges to their delivery. In order to address past failings in delivery and boost supply particularly in the short term, a wide range of small to medium size sites need to be identified in the Green Belt as a priority.
Separate submissions are being made on behalf of Persimmon to the "call for sites".
Chapter / Page / Question / Paragraph: Questions 12a, 12b, 13a - 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.
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).
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.
Agree / Disagree: Disagree
Comments:
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Promoting delivery and market certainty is more likely under Spatial Options H1 and this should be a strong influence in choosing this approach. Persimmon support the view expressed that there is considerable potential for "rounding off" and relatively modest incursions into the Green Belt for small to medium sized housing sites, and the "opportunities" identified in this regard in the table under paragraph 4.29 of the Issues and Options Report should all be recognised. Whilst there is some concern that such small sites may not contribute to infrastructure in significant ways, this is a matter which can be carefully planned for by the LPA's and cumulative contributions can be combined to support infrastructure provision without compromising CIL regulations.
Whilst there may be some opportunity for a very limited number of Sustainable Urban Extensions it must be a strong influence that the contribution such sites make to housing supply is only likely to be realised in the longer term. They are equally not always certain to make larger infrastructure contributions as they too invariable face viability challenges.
Separate submissions are being made on behalf of Persimmon to the "call for sites".
Chapter / Page / Question / Paragraph: 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?
Agree / Disagree: Disagree
Comments:
The only circumstances in which any housing growth should be exported elsewhere in the HMA is if there is compelling evidence it cannot be accommodated within the Black Country, and there is a robust and certain framework in place to ensure that the homes will be required. An ongoing and open ended general process of discussion around this issue is unacceptable, as would be any policy in the BCCS Review which relegated it as a problem for another day. It is a problem for now. The export of housing from Birmingham is unprecedented in its scale, and the issue cannot simply continue to be passed down the line. At some point agreement needs to be reached in terms of how need across the HMA is going to be met, and the BCCS Review provides an ideal platform in this regard.
Persimmon do not support any contention at this stage that there is any sound reason why all housing need cannot be accommodated within the Black Country and there is no justification for exporting need to adjoining neighbouring Authorities.
Chapter / Page / Question / Paragraph: Questions 16 - 20
Agree / Disagree: Agree / Disagree
Comments:
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development on, the Green Belt. Large, regular, and unconstrained sites with immediate access to the Strategic Road Network are required to contribute towards meeting the need for employment land, particularly in relation to logistics led requirements. There remains a role for the recycling of
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brownfield sites to contribute towards meeting employment land needs, but this will not meet the requirements of the highly location sensitive large space occupiers that the Black Country should be seeking to attract.
It might be that sites within Sustainable Urban Extensions (Spatial Option E3) can also make some contribution in this regard, but this cannot be relied upon, particularly in the short term, and it is unlikely that SUEs will provide an effective mechanism to accommodate large scale requirements. Exporting growth to neighbouring areas (Spatial Option E4) should only be entertained as a last resort and if there is compelling evidence it cannot be accommodated within the Black Country.
This again speaks to the point made elsewhere in these representations that for the second stage EDNA to be effective it must be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. The Stage 1 report appears to have been informed by a narrow range of consultees, and unless this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly assessed.
Chapter / Page / Question / Paragraph: Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.
Agree / Disagree: Disagree
Comments:
The general approach to review HOU1 is of course appropriate, but comments have already been set out above in respect of concerns about adopting a brownfield first approach. Any housing trajectory needs to reflect and support early delivery with a significant shift away from and reduction in the amount of housing to be built on brownfield sites. Any level of need identified, must be met with realistic assumptions about supply. Undue reliance upon windfall merely circumvents the proper planning of an area and reduces certainty. Discounts should be applied for non delivery of commitments and allocations. Some over provision in supply is essential and can ensure a choice and range of sites and greater market interest. Allowances for large scale demolitions as in the past should be removed. Assumptions which increase the expected density of development should also be avoided. There is no meaningful market interest or appetite for increasing the density of housing in the Black Country and delivery would be better supported by reflecting market needs which are focused on sensible and modest density ranges often associated with suburban family housing.
Chapter / Page / Question / Paragraph: Questions 36, 38 and 40 - 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?
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?
Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period?
Agree / Disagree: Agree / Disagree
Comments:
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The type of approach set out in Policy HOU2 and Table 8 is appropriate in general terms, although greater clarity should be provided to confirm that the standards are general ones, that their practical application is highly location specific, and will be considered on a site by site basis to reflect local circumstances. There should be no requirement to increase the density standards, and again it should be clarified that these (and indeed the accessibility standards) should be regarded as indicative only.
For Green Belt releases, site specific standards should be avoided and density should reflect local circumstances. There should be no separate standards for particular housing types; this would add an unnecessary level of complexity and risk hindering the delivery of such units where they might have been provided as part of schemes otherwise broadly acceptable for their provision.
The SHMA should be used as a general guide to the types of houses to be delivered, but must be applied generally, rather than rigidly, or again this will hinder delivery.
Chapter / Page / Question / Paragraph: Questions 44a and 45 - 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?
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.
Agree / Disagree: Agree / Disagree
Comments:
The affordable housing requirement is appropriate, but on the clear understanding that the provisions of Policy HOU3 in terms of viability testing remain in place. There should be no increased requirement for Green Belt release sites. It is simplistic to assume these sites will have greater financial viability in circumstances where they are likely to have additional costs associated with utilities and infrastructure provision. A target of 25% subject to viability is appropriate.
Chapter / Page / Question / Paragraph: Questions 95a and 95b - 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.
Agree / Disagree: Disagree
Comments:
Given the particular challenges faced by the Black Country authorities in terms of development viability and attracting investment it is difficult to understand why "Garden City principles" should be pursued. It is of course important to ensure that the best practicable standards of design and environmental infrastructure are achieved, but this can be done within a conventional framework of fairly standard criteria based development management policies, rather than applying an additional, unnecessary and distracting "Garden City" approach.
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Chapter / Page / Question / Paragraph: Questions 103a and 103b - 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
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.
Agree / Disagree: Agree/Disagree
Comments:
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement for renewables applied and viewed more flexibly. This approach should be applied to housing as well as non domestic buildings

Re: Black Country Core Strategy Review

Thank you for your consultation on the above document.

The Canal & River Trust (the Trust) is the guardian of 2,000 miles of historic waterways across England and Wales. We are among the largest charities in the UK. Our vision is that "living waterways transform places and enrich lives".
Following consideration of the document we have the following comments to make:
The waterways can be used as tools in place making and place shaping, and contribute to the creation of sustainable communities. We seek for any development to relate appropriately to the waterway, minimise the ecological impacts and optimise the benefits such a location can generate for all parts of the community.
The waterways span several local authority boundaries and it is therefore important to ensure that there is a clear and consistent approach to development. There is a recognised need to strengthen existing planning policy at all the different spatial levels in order to provide robust planning policy frameworks that supports canals, rivers and docks as a cross-cutting policy theme; acknowledging the value of canals, rivers and docks/wharves, in terms of
* being a form of strategic and local infrastructure performing multiple functions (including sustainable transport, open space and green infrastructure, land drainage and water supply as well as flood alleviation), which is likely to be affected by all scales and types of development;
* their roles in improving the physical environment, opportunities for people and the wider economy;

* their contribution to supporting climate change, carbon reduction and environmental sustainability;
* * the public benefits that can be and are being generated by our canals, rivers and docks/wharves;
* * support future development, regeneration and improvement of canals, rivers and docks/wharves;
* * protect the heritage, environmental and recreational value of canals, rivers and docks and to safeguard them against inappropriate development;
* * support their ability to deliver economic, social and environmental benefits to local communities and the nation, (currently valued at in excess of £500 million per annum);
* * secure the long-term sustainability of inland waterway network, their corridors and adjoining communities; and
* * their contribution to promoting Health and Wellbeing
The Core Strategy is therefore a key document in setting the overarching planning and regeneration policies across the area and ensuring a co-ordinated approach to the waterways across the Black Country.
The Trust therefore welcome continued support and recognition for the waterways but consider opportunities exist to strengthen Policies and further highlight the importance of the canal network to the Black Country

INDIVIDUAL QUESTIONS for EACH REP

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

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

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

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

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

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

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

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

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

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

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

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

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

Social Infrastructure (Questions 22-25)

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

Physical Infrastructure (Questions 26-28)

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

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

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