Key Issue 1 - Updating the evidence base

Dear Helen

BLACK COUNTRY CORE STRATEGY ISSUES & OPTIONS CONSULTATION

Thank you for forwarding me details of the above referenced consultation. Highways England ('we') are responsible for the operation and maintenance of the Strategic Road Network (SRN) in England. The network includes all major motorways and trunk roads.

The M5 and M6 motorways which form part of the Birmingham Motorway 'Box' are sections of the SRN in the area covered by the Black Country Joint Core Strategy.

Highways England has undertaken a review of the consultation material in order to consider the potential implications arising for the SRN from the revised Core Strategy.

The consultation document asks a significant number of questions, only some of which are directly relevant to our remit.

Question 1 of the consultation considers the approach to the review of the plan. Highways England support the proposed approach to provide a partial review of the 2011 plan such that it maintains in general, the existing 'two tier' document approach to setting the spatial portrait of the area. We note however that the Core Strategy document sets out that "it may be necessary for the Core Strategy to include allocations of strategic sites". We consider that such an approach is essential for the consideration of any new strategic growth sites not already considered by the existing plan.

Such sites will often require the delivery of significant transport infrastructure, which takes time and resources as well as good co-ordination between different stakeholders to deliver. To ensure the cumulative implications of such sites are properly considered it is vital that the Core Strategy provides as much clarity as is possible on the location and scale of proposed strategic site allocations at the submission stage of the plan so that the strategic transport implications of such development can be determined and mitigation strategies agreed.

Question 5 of the consultation considers the need for a Green Belt review. Highways England supports the approach to the Black Country Green Belt review subject to the principle that existing or new policies seek to continue to maximise the reuse of brownfield land as the starting point for site allocation policy. Such a sequential approach is likely to provide the best opportunity to reduce the transport implications of development.

Evidence Base
We have considered the proposed evidence base set out in Section 3 table 1 of the consultation document and have the following observations:

We support the principle that the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study and a Black Country Green Belt Review should form the key evidence base for any new strategic land allocations considered under the Black Country Core Strategy. We note, however, that the Infrastructure and Transport evidence bases as currently outlined lack precision as to what the terms of reference of the Infrastructure Studies and Transport Impacts and Accessibility Planning Study will include.

As the Highway Authority for the SRN it is important that Highways England is consulted on the terms of reference for these studies to confirm what further involvement will be necessary so that the evidence base suitably considers the implications of development upon the SRN. In particular, we note that the Highways England Route Strategies (published in March 2017) includes the relevant evidence on the challenges affecting our network. The relevant Route Strategy reports comprise:

* London to Scotland West: (includes M5 and M6 corridors)
* Midlands to Wales and Gloucestershire: (includes M54 corridor)

Further emphasis should also be put on upcoming major regional study projects including that being developed by Midlands Connect which is considering strategic issues on the Birmingham Motorway Box.

Connectivity
A major issue concerning Highways England with regard to the Core Strategy is the connectivity of the Black Country and any future infrastructural challenges arising from the Plan. Connectivity is identified as a key issue within the Core Strategy consultation, however, at this stage new issues are not explored in detail and we note no decisions on additional transport or land use policies have been taken. Matters relating to the spatial strategy are considered and these have a strong inter-relationship to connectivity needs. Further engagement with Highways England on connectivity issues will be necessary as the plan develops.

Spatial Strategy
We have reviewed the approaches considered with regard to the setting of a new spatial strategy for the Black County and our comments on the two stage approach set out in the consultation can be found below. With regard to our responsibility for the operation of the SRN, these comments therefore relate to the transport implications of the Options.

Stage 1 (Questions 10, 11a and 11b) - It is our view that the transport implications of Option 1A of the consultation are likely to provide continuity of the existing known transport issues arising from the 2011 Core Strategy with further issues arising incrementally from issues arising from Stage 2. Option 1B would give rise to a different set of transportation implications than existing policies. This approach could have either net positive or net negative implications for overall traffic flow on the SRN depending on how the policy is implemented but not enough information is available on the approach to determine this question at this time.

Should Policy 1B be implemented it may be capable of providing beneficial transport implications by seeking to maximise opportunities to place higher density development in locations benefiting from access to high quality sustainable transport networks. It may also provide an opportunity to relocate inappropriately sited existing lower density employment development (such as B8 warehousing) out of inappropriate locations. In implementing such an approach a careful balance would need to be struck to ensure the approach does not result in an excess level of 'out commuting' from existing urban areas in the Black Country to greenfield sites on the periphery of the West Midlands conurbation.

Stage 2 - (Questions 12a-14) - In transport terms we consider that Spatial Strategy Option H2 to provide an approach to housing in the Green Belt via the provision of Sustainable Urban Extensions (SUEs) to be preferable to H1. H1 may result in an uncoordinated approach to the provision of the necessary transport infrastructure and higher levels of reliance upon travel via private cars.
Option H2 is likely to be capable of maximising access to sustainable transport via the co-location of development with rail stations or other sustainable transport infrastructure. This is likely to be the best way that the spatial strategy can maximise opportunities to reduce the traffic implications of development. Highways England therefore supports the H2 approach insofar that it is identified to be compatible with the most sustainable outcomes identified from Stage 1.
Stage 2 - (Questions 16-20) - We have considered the transport implications of Spatial options E1, E2, E3 and E4 with regard the provision of land for employment outside of the existing urban areas. Site specific consideration are likely to be highly relevant to any sites considered under such broad strategies and it is not possible for us to identify preferred options based upon the level of evidence produced to date.

On the basis of the current information available we would note the following points:

* Option E3 appears to offer the greatest opportunities to support the provision of new sustainable transport infrastructure in Green Belt locations. This potentially could be delivered in combination with allocations considered under option H2 which is likely to provide the maximum opportunity within Greenfield sites. Option E1 is also likely to provide some opportunity to maximise the use of existing infrastructure. However, it carries site specific risks that some locations may add to existing highway capacity constraints; conversely other sites might add critical mass to ensure support for investment in sustainable transport infrastructure serving new and existing development is forthcoming.

* In transport terms option E2 appears most challenging to achieve transport sustainability as free standing sites have no existing population or infrastructure to support them. Any such sites would need careful consideration of the wider transport implications and be selected carefully on their own merits.

* Option E4 proposes to consider the export employment growth to neighbouring areas. This could consider how further employment growth in Birmingham and improved transport links to the Black Country might complement that Authority's housing needs which may need to be addressed within the Black Country. For other less accessible locations, which do not benefit from strong sustainable transport links to the Black Country, we note the risk that Option E4 could give rise to a high level of out commuting traffic via single occupancy private vehicles trips. If Option E4 is adopted then it should follow similar principles to option E2 in site selection to reduce the transport implications of development.

At this stage we have considered the issues likely to arise from the Black Country Core Strategy review but it is not possible to fully determine how these issues will result in specific transport implications for our network. As spatial options are developed we would encourage further engagement with us so that that the implications of the leading options can be considered further by us prior to the next stage of the plan's development. In particular, we would anticipate that effective dialogue over development of the evidence base as it relates to transport will be forthcoming.

Please do not hesitate to contact me if you require any more information or clarification.

Yours sincerely

Patricia Dray
OD Midlands
Email: Patricia.Dray@HighwaysEngland.co.uk

Cc: Catherine Townend (Highways England)
Matthew Taylor (Highways England)
Chris Cox (Systra)

Our primary concern is ensuring that the Local Plan is informed by appropriate evidence and that where higher levels of growth are identified and policies and sites proposed, that these are informed by up to date and proportionate evidence. Table 1 on page 18 details the range of evidence base and which areas may need updating. Unfortunately, there is no reference to any historic environment evidence base within this table. What evidence base do the Council's have? Does it need updating? Are there areas missing? If sites are proposed through the Black Country Core Strategy review then we would expect a heritage impact assessment to be undertaken, or similar.

I attach a link below to some relevant advice notes to assist in the preparation of the Black Country Core Strategy Review:

Conservation Principles -

https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/

Good Practice Advice Notes -

https://historicengland.org.uk/advice/planning/planning-system/

Site Allocations Advice Note -

https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/

Page 29 looks at the issue of a Green Belt Review and we would want to ensure that the historic towns purpose of the Green Belt is fully considered.

We would support the inclusion of a specific spatial objective for the historic environment.

Where growth is considered and there are options for amending boundaries to regeneration corridors, creating new sustainable urban extensions, allocating development sites, we would need to ensure that appropriate assessment has been undertaken on how this growth will impact the significance of heritage assets, including their setting. Please see advice notes above and also access Historic England's website for further information.

Question 16 raises the idea of what criteria to consider when choosing sites for development - we would request that the Council's consider what the impacts are for the historic environment and consider sites where there is no negative impact or impacts can be mitigated. There are also opportunities for development to positively enhance and better reveal the significance of heritage assets and we would also request that these opportunities are considered. This point is relevant for all types of development.

We would be happy to offer advice and comment on any proposals to amend Policy ENV2 on the historic environment and we are supportive of the policy being updated in line with national policy and guidance.

Page 66 raises the issue of building density and the need to look at increased density. As a result we would be keen to ensure that the Council's have appropriate design and building heights policies to ensure that there are specific policies to deal with issues that may arise because of increased density of sites.

Where sites are identified for Gypsy, Traveller and Travelling Showpeople, alongside other forms of development, we would expect these to be fully assessed against the potential negative impacts for the historic environment.

Where transport initiatives are proposed we would recommend that these are considered against the impact to the historic environment and that relevant avoidance, mitigation and enhancement measures are included within the Core Strategy.

We are content with the proposed amendment to Policy ENV2. We would recommend that a section is included on Heritage Statements and when they are required.

Historic England is currently preparing some additional advice on preparing minerals plans and the historic environment. We would recommend that the Council's consider all appropriate evidence base to ensure that the proposals are appropriate and compliant with the National Planning Policy Framework. Historic England does also have access to a number of studies that have looked at archaeology and aggregate minerals and we would be happy to share the relevant evidence with you

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


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

Thank you for consulting the Environment Agency on the Black Country Core Strategy: Issues and Options Report.

We are the main Agency providing advice on improving resilience and adaptation to the effects of climate change, with particular regard on flood risk, water resources, water quality and aquatic biodiversity.

We strive to make a positive contribution through our Statutory Consultee role and are happy to provide comments at this stage of the plan making process. We are also happy to work with the Black County Authorities on relevant policies in the emerging Core Strategy.

We welcome the Core Strategy Review which will set out a vision and strategy for the protection and enhancement of the Black Country which will be shaped by Ecological Network Study, Strategic Mapping of the Black Country's Natural Environment and Flood Risk/ Water Infrastructure study.

Key Issue 1 - Updating the Evidence Base

The Core Strategy review will need to be based on up to date and robust evidence.

The Black Country Strategic Flood Risk Assessment (SFRA) was published in 2009. It should be updated to reflect changes which have taken place since then.

The Review should also consider alignment with the Water Framework Directive (WFD).
The WFD River Basin Management Plans (RBMP's) require that watercourses within the Core Strategy area continue to show improvements in line with specified quality standards. Where possible, all developments within the area should seek opportunities to restore and enhance waterbodies. As a minimum, developments should comply with the WFD 'no deterioration' policy.

Like other public bodies, the Black Country Authorities must "have regard to the River Basin Management Plan (RBMP) and any supplementary plans in exercising their functions" and are required to provide information and such assistance as the Environment Agency may reasonably seek in connection with its WFD functions. This means, for example, they need to reflect RBMP data in Local Plan policies, Infrastructure Delivery Plans, and in the determination of planning applications.

Further information regarding the role of Local Authorities and WFD, including examples of local planning policies relating to WFD issues can be found here: http://www.sustainabilitywestmidlands.org.uk/projects/?/Public sector - Delivering the Water Framework Directive and Environmental Infrastructure with Local Authorities/2388 ( )

Other documents the review will need to take into account includes:

* Flood & Water Management Act 2010 - new role and responsibilities for the Black Country unitary authorities as Lead Local Flood Authorities (LLFAs).
* National Flood Risk Management Strategy, 2011
* NPPF supersedes PPS25
* Black Country Local Flood Risk Management Strategy, 2016
* Updated maps for surface water
* Humber Flood Risk Management Plan, 2016 (Includes West Midlands FRMP)
* Severn Flood Risk Management Plan, 2016
* Humber River Basin Management Plan, 2016
* Severn River Basin Management Plan, 2016
* Revised Climate Change Allowances, 2016
* New flood risk permitting regime (replacing flood defence consents)
* Flooding in June 2016 - Section 19 Flood Investigation Reports being prepared by the Black Country LLFAs

A number of EA modelling studies have been completed in the area since 2009:
* Ford Brook, 2009
* River Stour at Stourbridge, 2009
* Illey Brook, 2010
* Lutley Brook, 2010
* Mousesweet Brook (Mushroom Green Dam breach modelling), 2010
* Brandhall Brook, 2011
* Darlaston Hazard Mapping, 2012
* Smestoow Brook, 2012
* Wordesley Brook, 2013
* Coalbourne Brook, 2013
* Mousesweet Brook, 2013
* Waddems & Bentley Flood Relief Culvert - ongoing, nearing completion. (currently being reviewed by Walsall MBC)

Key Issue 8: Providing Infrastructure to Support Growth

We consider that physical infrastructure could include strategic SuDS or flood mitigation as well as brownfield remediation measures which could provide multiple benefits to enable and supporting growth.

Physical Infrastructure

The increased amount of waste water and sewage effluent produced by the new developments or project growth will need to be dealt with to ensure that there is no deterioration in the quality of the water courses receiving this extra volume of treated effluent. As such there may be a requirement for the expansion and upgrading of current sewage treatment systems, if the volume of sewage requiring treatment within the Core Strategy area increases. We therefore welcome engagement with the Black Country Authorities and water providers in paragraph 5.14 to ascertain if there are any issues with supply and treatment of water that would impact the ability to deliver future housing and employment growth. It is also important that discussions are held with the Severn Trent Water to ascertain the impact upon Combined Sewer Overflows (CSOs) and other storm related discharges (pumping stations, inlet CSOs at sewage works,) within the sewer network and at the receiving sewage works to determine whether a significant increase in spills to the environment could occur. We would therefore expect a new Water Cycle Study to be undertaken as part the Core Strategy review as its progresses.

In paragraph 5.23 where it highlights viability issues in developing Green Belt sites due to 'environmental constraints such as flood risk'. We would challenge the 'need' to develop sites which are at flood risk. The aim should be to avoid development in flood risk areas in line with national planning policy.

Where sites fall within the mapped floodplain, and as such if they are to be taken forward as site allocations in future plans, they need to be sequentially tested using an up to date level 1 and 2 SFRA. This work will need to be undertaken prior to the next stage of the plan process in order to demonstrate that decisions regarding which sites to take forward comply with overarching policies on flood risk are sound.

The Sequential Test can form a standalone evidence document which supports your 'final' allocated sites, or form part of the Sustainability Appraisal, however the decision making process regarding flood risk sites should be transparent. Guidance on how to apply the sequential test in conjunction with sustainability appraisal is available at https://www.gov.uk/guidance/flood-risk-and-coastal-change#aim-of-Sequential-Test.

Should any future sites pass the Sequential Test and progress forwards towards submission stage, they will need to be supported by a Level 2 SFRA which will look in more detail at issues raised within the Level 1 SFRA, enable the application of the Exception Test, and advise on the developable land and therefore housing yield of the site.

Funding for Site Development and Infrastructure

Paragraph 5.28 focuses on working in partnerships with the public and private sector to delivery development opportunities which we welcome. The EA has a number of capital project in our 6 year investment plan. Please find below a brief update and description of Flood Risk Management Projects / Schemes (6 year investment programme) in the Black Country. We wish these to be included in the Core Strategy in light of questions 26 and 27.


Dudley

Mushroom Green Dam, Mousesweet Brook
The scheme is in construction to reduce flood risk to 42 properties. A new oversized culvert has been constructed through a 10m high embankment at Mushroom Green, Dudley to reduce the risk of sudden failure of the embankment and prevent it acting as an impounding structure. The main works of the scheme have been completed and the Mousesweet Brook diverted through the new culvert. Maintenance and reinstatement works are ongoing and are being co-ordinated with STW who are undertaking main sewer improvement works in the area.

Wordesley
A potential future property level resilience scheme has been identified in Wordesley to reduce flood risk to 10 properties from the Wordesley Brook, subject to availability of funding. This project will be led by the EA.

Halesowen
A potential future property level resilience scheme has been identified to reduce flood risk to 30 properties from the River Stour, subject to availability of funding.

Sandwell

Thimblemill Brook Flood Alleviation Scheme
Flooding has occurred in a number of locations around Thimblemill Brook. There likely solution is to include a combination of additional channel capacity in the Thimblemill Brook to provide online storage and upgrades to existing surface water drainage and highway networks. The scheme to protect 255 properties is in the 6 year investment programme but this is subject to project appraisal and the necessary funding being available.

Brandhall Brook, Wednesbury
This is a potential capital maintenance scheme has been identified to reduce flood risk to around 15 properties from the Brandhall Brook in Wednesbury. This project is subject to availability of funding.

Collins Road, Wednesbury
This scheme to refurbish existing sheet pile defences on the River Tame to maintain the standard of protection to over 60 properties. Work is currently planned to commence in 2018/19.

Walsall

Old Ford Brook, Tower Street, Walsall
This project relates to the replacement of a culvert to safeguard properties and pedestrians in the event of a collapse. A scheme to reduce flood risk to 12 properties is in the 6 year investment programme and is planned to commence in 2020.

Wolverhampton

Waterhead Brook
This is a potential future capital maintenance scheme that's has been identified to reduce flood risk to 11 properties from Waterhead Brook, subject to availability of funding. A proposed study would highlight the best course of action to re-naturalise the currently partially blocked watercourse. Any subsequent channel modification works would enable environmental improvements within the school and open up the opportunity of others linked to Water Framework Directive objectives.

POLICY AREA F: The Black Country Environment

We welcome the emerging Black Country Environment Spatial Plan which will draw together existing evidence base and define the ecological networks within the Black Country.

We consider that Policy CSP3 - Environmental Infrastructure, could include opportunities to reinstate natural river corridors and floodplains and opening up culverts, which will complement the Garden City and WFD principles.

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

Flood risk is a key issue at the national policy level due to the number and severity of recent floods across the country. Smaller watercourses and drains are often far more susceptible than larger rivers to flash flooding as a result of localised intense rainfall. Changing climate patterns mean that storms of this nature are likely to be become increasingly common, potentially increasing the risk posed to properties near local watercourses. This was demonstrated in June 2016 when parts of the Black Country experienced flash flooding causing many properties to flood and major transport disruption.

We consider there should be a stand alone Flood Risk policy within the revised Core Strategy. The wording of the policy should be appropriate, clear and in line with the National Planning Policy Framework. The NPPF advises that Local Planning Authorities should steer all new development away from those areas at highest flood risk by applying a sequential risk-based approach to the consideration of development in flood risk areas and by taking into account the flood risk vulnerability of land uses. We are keen to provide assistance to the Black Country Authorities on drafting any future flood risk policy.

Policy ENV5 requires significant revising to reflect the replacement of PPS25 by NPPF, and will need to have regard to the Black Country Local Flood Risk Management Strategy and the West Midlands Flood Risk Management Plan (included in the Humber FRMP). The existing SFRA will need to be updated to include the latest available data on flood risk as well as other changes listed above.

All new development should minimise the risk of flooding to people, property and the environment within the site and without increasing risk elsewhere. Where possible it should also seek to reduce flood risk elsewhere.

Where it is not always possible to direct development to sites with the lowest probability of flooding, the development should seek to minimise risk to the site and make the development resistant to any residual risk and make the development flood resilient. Opportunities should also be sought to reduce the overall level of flood risk through the layout and form of development. Development should be designed to be safe throughout its lifetime, taking account of the potential impacts of climate change. Provision for emergency access and egress must also be included.

We do not support the proposed change to Policy ENV5 para 6.1.57 in relation to removing the requirement to provide SuDS in all new developments. Although the Ministerial Statement states this approach only needs to be applied to major development we feel that the policy should be more aspirational and still seek to include SuDs wherever practical, whilst recognising that in some cases it may not be appropriate. Developers should be encouraged to secure reduction of flood risk by the provision or enhancement of green infrastructure wherever possible.

We would welcome the inclusion of a requirement for long-term maintenance arrangements for all SuDS to be in place for the lifetime of development and agreed with the relevant risk management authority.

It should be a requirement for all new development (greenfield and brownfield) to reduce surface water runoff to greenfield rates, and the layout and design of a development should take account of surface water flows in extreme events in order to avoid flooding or properties both on and off site therefore we welcome the suggestion in paragraph 6.1.59 to add specific requirement for greenfield sites to maintain surface water flows at greenfield rates.

Many of the watercourses within the Black Country are culverted. Although this provides a reasonable degree of flood protection, this inhibits the potential for natural drainage and areas could be affected by flooding in extreme events or if blockages occur in these culverts. This should be taken into account when applying the sequential approach to new development as well as applying flood mitigation and resilience measures where appropriate. Where feasible, opportunities to open up culverted watercourses should be sought to reduce the associated flood risk and danger of collapse whilst taking advantage of opportunities to enhance biodiversity and green infrastructure. Existing open watercourses should not be culverted.

For any sites located near main rivers we will require a minimum of 8m development easement from the top of the bank to allow for essential maintenance access. This is required regardless of the extent and location of the floodplain and should be taken into account when considering the developable area.

An Environmental Permit from the Environment Agency will be required for any development within this 8m strip. Where the development site is situated above a culverted main river watercourse, we will require a minimum of 10m development easement from the centre line of the culvert and the area above the culvert should be regarded as a no build zone.

We consider that the revised Core Strategy should make references to the WFD and its objectives. This could be incorporated in a water quality/ water resource policy, which requires that development proposals do not lead to deterioration of WFD water body status, and which help to conserve and enhance watercourses and riverside habitats.

Policy ENV1- Nature Conservation

We are pleased to note Policy ENV1- Nature Conservation has worked effectively to protect and enhance biodiversity and geo-diversity across the Black Country.

Policy Area G - Waste

Locational Considerations for new Waste Management Facilities

With regards to policy WM4 we consider it is important that there is sufficient buffering between different land uses such as proposed residential development next and existing industrial use such as waste facilities and as such that they do not disadvantage each other with regard to amenity issues. Exposing new sensitive receptors to perceived or actual environmental and human health impacts should also be avoided. It is therefore important that policies in the Core Strategy complement each other in these respects.

Groundwater comments

The protection and enhancement of controlled waters via the planning regime and the redevelopment of contaminated land is encouraged as it provides an opportunity to remove areas of contamination that would otherwise continue to present a risk to our environment, controlled waters and human health.

The Black Country is largely made up of Carboniferous Coal Measures strata (classed as Secondary A aquifers, the former Minor ones), but also contains some more important Principal sandstone aquifers towards the eastern side. There are also numerous surface waters worthy of protection from ongoing or new pollution and/or low flow issues.

Key Issue 5 'Protecting and enhancing the environment' and Policy Area F 'Protecting the environment' does not make reference to any geology, groundwater and/or contaminated land issues.

We recommend there should be specific references to the hydrogeological environment and especially to issues such as groundwater and surface water protection (quality and quantity), contaminated land assessment (and clean-up where needed) and indeed the legislative drivers underpinning all this, such as Environmental Permitting Regulations and Water Framework Directive.

Paragraph 109 of the NPPF states that the planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil and/or water pollution. Paragraph 120 states that local policies and decisions should ensure that new development is appropriate for its location, having regard to the effects of pollution on health or the natural environment, taking account of the potential sensitivity of the area or proposed development to adverse effects from pollution.

Government policy also states that planning policies and decisions should ensure that the site is suitable for its new use taking into account of ground conditions [...] pollution arising from previous uses and any proposals for mitigation, including land remediation on impacts on the natural environment arising from that remediation and adequate site investigation information prepared by a competent person, is presented (NPPF, paragraph 121).

We recommend that you refer to our Groundwater Protection: Policy and Principles (GP3, on www.gov.uk) to get a better understanding of the issues important to us. This document sets out a framework for our regulation and management of this precious resource and describes our aims and objectives for groundwater, our technical approach to its management and protection, the tools we use to do our work and our policies and approach to the application of legislation. Also, there is of course the risk management framework for contaminated land as set out in CLR11: The Model Procedures for the Management of Land Contamination.

The Environment Agency hopes you find the above comments useful and we look forward to being consulted in the next stage of your consultation process regarding your Core Strategy.

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

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

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

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

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

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

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

Question 13d - Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details

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

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

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

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

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

Rep made against: Policy HOU5 - Education and Health Care Facilities, Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing development

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

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

Rep made against: Policy HOU5 - Education and Health Care Facilities, Question 48 - Do you agree that the requirement in HOU5, to demonstrate there is adequate alternative provision to meet the needs of the community served by a facility which is to be lost, should be r

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

Rep made against: Policy EMP6 - Cultural Facilities and the Visitor Economy, Question 56 - Do you agree with the proposal to update Policy EMP6 in line with current priorities? Yes/No;

If no, please explain why
The Black Country is home to a number of pubs on CAMRA's national inventory heritage list which might fit in with the heritage themes of the list of attractions

Gallagher Estates
Black Country Core Strategy ssues & Options




AP PEN DIX A


H OUSI NG EVIDE NCE BASE REVIEW PAP ER
















































SEPTEMBER 2017 I HS I BIR.4327

Pegasus
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HOUSING EVI DENCE BASE REVIEW PAPER

BLACK COUNTRY CORE STRATEGY REVIEW


ISSUES AND OPTIONS CONSULTATION (SEPTEMBER 2017)














Pegasus Group
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PLANNING I I ENVIRONMENT I ECONOMICS
IC>Copyright Pegasus Planning Group Limited 2011.The contents of this document must not be copiedor reproduced in whole orin part without the written consent of Pegasus Planning Group Limited

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1. Introduction

1.1 The purpose of this report is to review the housing evidence base that supports the proposedIssues and Options within the Core Strategy. The reports considered in this paper includes :

SHMA Part 1(Section 2) SHMA Part 2 (Section 3)
Housing Background Paper (Section 4)

1.2 The conclusions of this paper, summarised in Section 5, will be fed into the representations to theIssues and Options Core Strategy Review.


2. Black Country and South Staffordshire Housing Market Area Report, March 2017 (PART 1)

Introduction

2.1 The SHMA prepared has been prepared by PBA, which is the same author of the Greater Birmingham Strategic Housing Needs Studies (SHNS). Whilst this approach is supported for consistency, the methodology used by PBA has previously been subject to come criticism.In addition, it is considered the evidence is not sufficiently transparent and, accordi ngly, it is difficult to appropriately review the assumptio ns used and results generated. Such concerns are set out within this report.

Housing Market Area

2.2 In terms of establishing the SHMA, reference is made back to the conclusion of the SHNS, which confirmed this (the Black Country and South Staffordshire) as an appropriate sub housing market area of the wider Greater Birmingham HMA. It is understood that the SHMA has been prepared covering the sub area to inform the
Issues and Options Review of the Black Country Core Strategy. Whilst this is appropriate to identify local needs, there is concern that there is not a SHMA for the HMA, as required by the NPPF and Planning Practice Guidance, over the same time period.

2.3 As there is not a wider strategic plan to apportion dwelling requirements across the HMA and nor is there a memorandum of understanding agreeing a dwelling distribution, there is concern that if smaller/ sub areas prepare their own evidence based on different timescales some unmet need may be lost. It is welcomed that the Black Country authorities have taken matters into their own hands by commissioning evidence to allow the Core Strategy to be reviewed, however, it is important that the other authorities also commit to preparing a full HMA, which includes the latest demographic data and extends to 2036 and beyond where possible.

Demographic Change

2.4 It is pleasing to note that following many years of decline, the Black Country is now growing. This is potentially due to both the policy shift in limiting development in rural areas and focusing growth on the MUA and also as a consequence of not enough homes being built in the West Midlands, due to a policy vacuum as a result of national changes and the econom ic recession, which has meant that households are out priced from more desirable areas of the West Midlands and, therefore, choosing to remain in the Black Country.

2.5 It is noted that between 2001 and 2011, there was positive natural change of circa 30,000 people for the HMA overall, although it should be noted South Staffs bucks the trends and has negative natural change.

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2.6 In terms of net migration for the same period, domestic outflows totalled 35,400 and international inflows totals 37,000, resulting in almost no net change.In addition, there was a UPC change of +30,000 people. The report justifies the use of UPC on the basis that there were discrepancies in migration.

2.7 It is understood that the Strategic Housing Needs Study for the Greater Birmingham HMA included different scenarios for the HMA as a whole, which counted and discounted UPC. The Inspector for the Birmingham Local Plan considered a scenario excluding UPC as appropriate . Clearly, this approach differs to that proposed in this SHMA and it is unclear if there are any wider implications of this.It is agreed that circumstances relating to UPC differ in each location, however, there is concern that as a full SHMA has not been undertaken the individual circumstances have not been appropriately considered.

2.8 It is identified that population growth between 2011 and 2014 was 20,400 and there was other additional growth, which was as a result of a new prison opening in South Staffs. It is suggested that, as prison population is institutional, this growth is not included in future growth projections. This approach is supported as these people will not occupy dwellings as such.

2.9 9 The report reviews the 2014 Based Projections and identifies that it includes increased levels of domestic net migration than the previous vintage (which was used in the SHNS). The projected population growth using 2014 Based data, between 2014 and 2039, is 165,300 for the sub area .

2.10 There is positive natural change for all authorities except for South Staffs. It is noted that this is due to there being an aging population in South Staffs. The rate of population growth is largely in line with past trends and the majority of growth is the elderly population.

2.11 It is noted that the 2014 Based Household Projections show household growth of 89,000 or 3,550 per annum between 20 14 and 2039 . This in our view provides the baseline projection as it is based upon short term past trends.

2.12 2 It is welcomed that two further altern.ative long term projections have been prepared: one takes account of 2014 MYE and a ten year trend period of 2004 to 2014; the second takes account of 2-15 MYE and uses a ten year trends period of 2005 to 2015. Both include UPC. There is concern, however, that in future testing of past trends a longer period of say 15 years should be used now as this takes account of a balanced period of economic prosperity and decline. Given that migration trends are quite volatile to economic changes, it is appropriate to consider the implications arising from a neutral period (i.e. where equal economic experiences are felt). It is considered that a 15 year period to 2015 accounts for 7 years pre recession and 7 years post recession.


2.13 3 The two alternative projections identify a greater dwel ling requirement circa 100 dwellings extra than the 2014 Based Household Projections per annum. It is supported that considerable weight is given to the alternative 2014 based projection as the demographic starting point, however, as advised above there is concern that this period of past trends is mainly made up of a period of negative or poor economic growth. Should over the proposed plan period economic circumstances improve and be sustained, which is possible given that the plan period extends to 2036, there is concern that the dwelling requirement may be insufficient to meet dwelling requirements.

2.14 4In terms of the household representative rates, it is unclear if any changes have been made as a result of considering the Stage 1 and 2 data sets. Further clarity is required in this regard.

2.15 Further, it would be expected that the demographic modelling methodology would include appropr iate adjustments to allow for households in a particular age category (25-34 and 35-44) that have been constrained , as a result of high house prices, to form. There does not, however, appear to be any such adjustment and accordingly these households will remain constrai ned and their needs will not be met.

2.16 6 It is unclear what level of vacancies have been applied to determine the number of dwellings appropriate for each local authority area . There are a number of different ways household can be converted to dwellings and it is,therefore, appropriate that the method is transpare ntly set out. It is advised that the percentage of vaca ncies identified by the 2011 Census should be applied for each LPA. Where the percentage is below 3%, the figure of 3% should be maintained as this has been previously recommended by the National Housing and Planning Advice Unit as an appropriate level to a llow the housing market to function effectively .

2.17 7 It is identified, however, the larger SHNS uses a 2012 based demographic starting point and therefore there is a need to address any unmet need arising between 2011 and 2014. A under supply and 'gap' of 2,689 dwellings is added to the starting point, which is proposed to be added over the plan period (i.e. before 2036). A phased approach was considered, however, this was considered a 'policy on' mater. Aithough it is suggested that weight shouid be given to frontioading the supply of sites where possible.

2.18 It is supported that the SHMA is seeking to ensure that any dwelling requirement is not lost from the overarching SHNS, however, it is suggested that this unmet need should be provided for early to allow those households form as they were projected to, alternatively such households will remain as concea led or in shared accommodation, which is determinantal to their quality of life. Further consequences are that the reduced supply to meet the increasing demand will inflate house prices and, accordingly, households may choose to move elsewhere to locations where there are available homes that are afforda ble. Clearly, out migration of people due to a shortage of homes, will not assist to grow the local economy in accordance w ith aspirations.




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2.19 In terms of bringing land forward for development as part of the Black Country Core Strategy Review, it is appropriate to ensure that as many sites as possible are encouraged to come forward for development immediately, where there are no barriers to implementation.Indeed, for any strategic sites, given the lead in times required to prepare and determine planning applications, these must be planned early to ensure that they are entirely built out in the plan period and fully contribute to the dwelling requirements.

Market Signals

2.20 With regard to considering if further adjustments are to be made to the demograph ic requirements,the report considers market signals. It outlines that:

in terms of completions there is a similar profile to national following economic cycle;
for house prices house price change was close to national trend until 2007, but in the recession it fell faster than the national figure, and in the recovery it has not caught up with the national trend, however, they out performed comparators. House prices in South Staffordshire were highest in HMA;
in respect of affordability, the Black Country is far more affordable than England, however, South Staffs is different but an improvement in affordability between 2012 and 20 13;
for rents, the national average was higher than the study area and there has been marginal increases locally except in South Staffs which has increased at twice the rate;
in terms of overcrowding, this is relative to the national average;
for concea led households, similar number of concealed than the regional average.
2.21 The report concludes, there is no evidence that housing has been undersupplied or that planning has been particularly restrictive to justify an uplift in demogra phic projections in the Black Country, however, an uplift is suggested for South Staffs (LPA breakdowns and summaries are provided).
2.22 The conclusion states that there is no evidence housing has been undersupplied. This statement is factually untrue, particularly in light of the 'gap' identified above, as we are experienci ng a housing crisis as set out in the NPPF. Simply because the Black Country's indicators are in line with the regional and national level of overall under provision, does not mean that there is not an excessive need.It is wrong to state that there is no evidence of housing undersupply and, accordingly, the application of an uplift for the Black Country should be reconsidered.
Jobs and Houses
2.23 With regard to consideri ng jobs and houses, three economic projections have been tested. It is concluded that there are no suggestions from any of the data that the area needs a larger labour force to meet the economic requirements. The Oxford Economics model does support, however, market signal adjustment for South Staffordshire on the basis that it indicates that more residents would prefer to live

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(but not work) there . It is concluded that a 25% uplilt should be applied to the demographic starting point and added under supply for South Staffs.
2.24 As highlighted in response to previous PBA Reports, which examine the relationship between jobs and homes, there are concerns that the model used does not strictly follow the advice set out by the Planning Advice Service, which was ironically prepared by PBA. Firstly, in respect of the Experian model, the population is set to the SNPP and, consequently, it is understood that commuting levels and working ages flex where necessary to ensure the economic needs are met. Very limited information is provided for all of the variables and it is difficult to understand the changes taking place. There is concern that as the model cannot be transparent ly scrutinised it cannot be objective.
2.25 In terms of the Oxford Economics projections, generated from the West Midlands Combined Authority model, it is outlined that the trend based projections generate a higher dwelling requirement than that arrived at from the job growth forecasts . This is largely because the jobs growth forecasts are very low. The report does not state w hat date the Oxford Econometrics forecasts were taken from and it could be that there is more recent information. As suggested in theIssues and Options Report, the economy has faired better than anticipated and hence less employment sites than expected came forward for development.It is unclear whether this has been picked up in the forecasts. There is concern that the data is potentially a number of years old and may be out of date. Clarification of the vintage of the data would be helpful.
2.26 Clearly, these scenarios are based on a 'policy off' position and accordingly do not reflect improved economic ambitions for the future.In light of this, it is appropriate that further testing takes place to consider the dwelling requirement of a more aspirationa l economy. It is acknowledged that Appendix B Includes an analysis based on the outputs of the Strategic Economic Plan, whilst this is useful there are a number of assumptions used due to the inability of the model to provide detailed age/ sex break downs and accordingly generate the number of dwellings required to meet the needs of that population. There is concern that this assessment based on quite broad assumptions is insufficiently accurate that further modelling should be used to appropriately identify 'policy on' implications.
Conclusion
2.27 To conclude, the demographic starting point is 80,055 dwellings between 20 14 and 2036. An adjustment of an additional 2,689 dwellings is suggested over the plan period to account for the previous shortfall. n addition, to account for market signals it is suggested that an additiona l 25% uplilt is applied.
2.28 The recommendations suggest that 84,123 homes are provided for between 2014 and 2036, which is 3,824 dwellings per annum . As highlighted above, based on the scenarios tested, this is considered to be a reasonable starting point, however, there are concerns in relation to the methodology and a further alternative scenario should also be tested to identify implications of a longer term trend that incorporates experience from both periods of economic prosperity and decline.If such recommendations are applied it could well result in an increased dwelling requirement .

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2.29 It is suggested that the LPAs may consider front loading the housing requirement to address the undersupply more rapidly. This suggestion is very much supported and it is advised that the Black Country Core Strategy Review does all it can to urge the early delivery of housing, particularly as this will plug any gaps arising whilst larger sites are coming forward.
2.30 It is suggested that by providing a 25% increase to the OAN for South Staffordshire in response to providing sufficient labour to meet economic needs the OAN for the Black Country may need to be reduced so not to be counted tw ice. Ta king the economic argument out of the equation, an uplift was applied to South Staffs in response to market signa ls on the basis that it is becoming less affordable. Based on this scenario, there is no double counting as the additional uplift is to take the pressure off existing housing market (i.e. providing more supply to meet the high demand). By simply providing for future needs on a one home for one household basis, this will not dilute the pent up demand nor impact on house prices. Given this scenario, it is suggested that a reduction of the Black Country OAN, in place of the uplift in South Staffordshire, wi ll simply result in unmet need in the Black Country, which could be transferred to South Staffordshire but provide no slack. t is therefore suggested that the South Staff uplift is maintained and there is no reduction to Black Country OAN.

2.31 It is disappointing that the SHMA does not consider the affordable housing and whether any uplifts to OAN are required. Whi lst this is a 'policy on' adjustment it is appropriate to know as part of the SHMA what the implications are.It is advised that the SHMA is updated to incorporate this.

2.32 With rega rd to unmet cross boundary need, it is suggested that in setting housing targets, there is scope for South Staffs to offset some of its unmet need against their recommended market signals adjustment. It is further suggested that migration flows from other areas outside the HMA may be stronge r than assumed in the base projections, however, all migration should be picked up in the projections and, as highlighted above, this additional allowance is to provide slack in the housing market that will allow existing concealed/ shared households to form and potentially prevent house prices from increasing at the faster rate identified.
It should, therefore, not form part of any unmet need from outside the HMA.

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3. Strategic Housing Market Assessment, June 2017 (PART 2)

Introduction

3.1 It is welcomed that the Black Country authorities have undertaken this second stage of work looking at the needs for all types of housing, including affordable housing and the needs of different groups in the communities.

Socio Economic Context

3.2 The statistics identified in this section is factua l and, therefore, no comments are offered in respect of this section.

The Cost and Affordability of Housing


3.3 The costs and affordability of homes is noted and there are no comments offered in respect of this section.

Type and Tenure of Future Housing Need


3.4 It is unclear if the data relied upon to determine the future requirements for homes is that, which has been generated by the preferred scenario identified in the SHMA Part 1. t is advised that, where possible, such data is used to identify the size of future households likely to arise over the plan period as opposed to potentially using other sources. It is, therefore, more likely that needs will be met.

3.5 Further, in paragraph 4.6 there are references to adjustments made to counter the existence of overcrowding. Such changes were not documented within the SHMA Part 1.

3.6 In terms of suggested household size requirements, it is interesting to note that for the 'owner occupied' category the need is mostly for larger three and four bedroom properties. There is concern that given the density and other proposed policies to improve the efficiency of land will restrict the delivery of larger homes and as a result needs wi ll not be met.

3.7 Finally, whilst it is useful to know the likely size and tenure dwelling requi rements of arising households, the Black Country authorities should not include any prescriptive policies requiring a particular split as the circumstances for each site vary and it is therefore appropriate to consider dwelling size and type on a site by site basis.

3.8 It is important that the level of affordab le housing identified as necessary is tested against the dwelling requirement to determine if the delivery of these affordable homes is viable. It is important that the policy initiative to deliver affordable housing does not compromise the delivery of housing overall, otherwise it would be contradictory to the policy provisions of the NPPF.

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Requirements of Specific Groups of the Population

3.9 As highlighted above in respect of the size and tenure of homes, whilst it is useful to be aware of the requirements of specific groups of the population, it is important that this information is not used to determine overly prescriptive policies. As highlighted above, the circumstances of each site vary and it is important that there is flexibility to meet market requirements based on needs in that particular location in order to deliver mixed sustainab le commun ities.

Conclusion

3.10 0 Within the conclusions for each of the Black Country authorities it is explained that vacancy rates are applied to the number of households required in order to generate the number of dwellings. Firstly, it is unclear what the source is for identifying vacancy levels. In the case of South Staffordshire, for example, it is suggested that a rate of 2.6% is applied, however, it is widely recognised that a 3% vacancy rate is considered to be the ideal level of vacant homes to allow for transactions, for homes to be renovated. It is therefore advised that a minimum of 3% or higher should be used, when applying a vacancy rates.

3.11 It is helpful that the SHMA has identified the relevant affordab le housing requirement for each of the individual authorities. It is, therefore, considered that this District level data should be used in preparing an affordable housing requirement reflective of the different level of need. This will ensure that more affordable homes are provided in the locations where they are needed. Further, such affordable housing levels should be tested to ensure such a level is viable and deliverable and that the overall delivery of homes will not be compromised as a consequence of the planning obligation.

3. 12 As highlighted previously, it is important that the proposed policies are not too prescriptive in relation to housing type, tenure and size in order to allow the characteristics of each location to be taken into account.

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4. Housing Supply Background Report, July 2017


4.1 It is noted that the work is preliminary and that a more detailed consideration of sites will take place in 2017/ 2018 to further identify the housing land supply available to contribute to meeting the housing requirements of the Core Strategy Review. Initial comments in response to the evidence presented is, however, provided below.

Evidence, Assumptions and Allowances

4.2 The methodology of the SHLAAs are currently predicated upon the strategy of the existing Core Strategy. Given that the strategy is likely to change as a result of the requirement for more land to meet the increased dwelling requirement, the methodologies should also be more flexible to maximise opportunities, but also remain realistic in respect of the delivery of the development opportunities identified. Detailed comments are provided below .

Discount Rates

4 .3 A 10% discount rate was applied to sites which were commitment in 2009 and a rate 15% was applied to unidentified sites that were expected to come forward within the regeneration corridors or freestanding employment sites.It is unclear as to whether these remain appropriate. As set out in the Core Strategy Review, a number of sites, particularly employment sites, have not come forward as anticipated and, therefore, discounting rates may need to be revised to be more realistic - especially for sites that are occupied.

4.4 It is suggested that the Councils undertake further work examining past trends of non implementation of different categories of sites to determi ne the correct level appropriate to the area and circumstances . This evidence based approach is considered to be the most robust and sound way to identify discount rates.

4.5 Further, as recommended by the Local Plans Expert Group, an additiona l land supply buffer of 20% is suggested to be provided as a contingency mechanism for scenarios where there is a deficiency in delivery. Should this approach be adopted as advised, there may not be a need for discounting as set out above. t is proposed, however, that given the delivery difficulties experienced previously in the Black Country an increased buffer of 25% should be applied in place of the 20%.

Demolitions

4.6 It is identified that assumptions relating to demol itions over estimated the reduction in housing stock as a result of urban renewal. It is unclear whether there are any further urban renewal schemes which are to take place over the new plan period.If so, where possible, demolitions arising from these should be identified on a site by site basis, rather than applying assumptions, to ensure lost dwellings are accurately identified.

Density

4.7 As set out the adopted Core Strategy identifies that sites of 15 homes or more to achieve a density of 35 dwellings per hectare (DPH), net of open space and major roads. The policy also requires developments of 60 dph or more to be located in the strategic or town centres, and for other high density developments (45-60 dph) to have good access to residential services by foot or public transport. It is understood that this policy approach is applied to sites in the HSLA to calculate the number of dwellings that can be accommodated on each site.

4.8 Whilst the principle of this is sound, there is a need to ensure that the assumptions do not over estimate the yield of sites, particularly in locations of the Black Country where there is an opportunity to diversify the existing housing mix through the provision of lower density family homes. It is appreciated that there is a need to deliver an efficient use of land, however, there is an over provision of particular types of homes in certain locations, which has led to wider social issues.

4.9 Further, on a separate matter, since the recession the apartment market has suffered, particularly given the amount of upfront investment required to deliver such schemes.In light of this, sites that were originally identified for higher density homes may not come forward as originally envisaged . t is important, therefore, that such schemes are reassessed and a more reasonable and deliverable level of homes is identified and counted within the SHLAA and Housing Trajectory.

Windfall Allowances


4.10 A windfall allowance is generally accepted in respect of small sites as it is impossible to identify many of these as some will arise through the general churn of land. A figure of 6% of the total housing supply from the Core Strategy or 418 homes as a windfall allowance for small sites of less than 15 homes was considered to be acceptable by theInspector.

4.11 It is welcomed that small sites have been defined as sites of 9 homes or less in accordance with the Housing White Paper. This clarification has reduced the threshold for windfall sites, which was previously less than 15 homes. This change will help to identify more sites within the SHLAA and provide more certainty to the housing land supply and is supported.

4.12 As a consequence of the change in threshold, an allowance based on a proportion of the overall dwelling requirement should be amended as, according ly, less homes will come forward. It is suggested that historic trend information is obtained for sites of 9 or less in order to identify the average number of homes that have come forward and a proportional split can be determined thereafter .

4.13 It is recognised that larger windfall sites do also arise, however, these are less able to predict and we would express caution over using past trends to identify future supply from this source.

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Surplus Employment Land


4.14 The existing strategy relies on a large proportion of land for housing to be provided through the redevelopment of employment land, however, it has been identified that there is a need to increase the employment land over the period to 2036. t further states that it could require the retention of more of the existing employment land that may have been expected previously to be released for housing.

4.15 Whilst it is acknowledged that a review of the quality of employment sites has been undertaken. It is known from developers active in the Black Country that there are a number of sites that are currently vacant with employment land designations. These sites have been advertised, however, there has been no interest. n light of this, it is recommended that the Black Country authorities reconsider land allocations for sites that are not fit for purpose in their current use. According ly, it may be the case that employment development would be better located on new sites.

Current Identified Housing Supply 2006-26

4.16 It is reassuring that the Black Country has planned for the dwelling requirements well in providing a total housing supply some 7% in excess of the dwelling requirements . As set out above and in the accompanying representations the Local Plans Expert Group's recommendation, which is to have a 20% buffer of land supply over and above the dwelling requirement identified, should be adopted . Given the challenging market conditions in some areas of the Black Country, it is considered that such an approach would be beneficial to provide a contingency for when particular sites are stalled due to unforeseen circumstances .Indeed, the buffer could be increased to 25% to adopt a cautious, yet reasonable, approach.

4.17 In terms of the five year land supply calculations, it i suggested that there is a five year land supply based on both the adopted Core Strategy dwelling requirement and the emerging SHMA 2017 annualised requirement. There is no information/ method as to how this has been calculated and what level of buffer has been applied if any. This needs to be taken into consideration when determining the five yea r land supply positon and transparently set out.

Potential Changes to Housing Supply 2016-36

4.18 It terms of the suggested housing capacity from Wa lsall Town Centre, as highlighted above in relation to densities, there is concern that it is more challenging to bring forward apartment development and accordingly the authorities should be cautious when identifying number of homes that can be delivered.

4.19 With regard to reducing discount rates, it is welcomed that research is ongoing to determine whether the rates remain appropr iate. It is considered that the rates should not be reduced unless there is evidence to support it. It is recognised that the implementation of the Core Strategy was impacted by the recession, however, the housing market in some areas of the Black Country remains challenging and it is appropriate to retain contingencies to account for this.



Potential toI ncrease Densities

4.20 As highlighted above, there are concerns with regard to increasing densities. It is welcomed that work has been carried out to review the historic and current density rates. Looking at the results, although the same period is small, it appears that higher densities were achieved in earlier years, however, more recently, densities are lower. Indeed, the research based on current commitments also reflect the current trends for more lower density development. This data reflects concerns identified above relating to the apartment market and difficulties associated with bringing these sites forward.

4.21 In paragraph 4.19 it is suggested that if density policies could be changed to raise the minimum density requirement to 40 dph instead of 35dph. This, however, is clearly a matter for further consideration as part of theIssues and Options Core Strategy Review. There is concern that applying a blanket density requirement will, on a number of sites, lead to new developments that are potentially out of character with the local environment and result in the delivery with more smaller dwellings in an attempt to get more homes on the land. It is suggested that the Black Country authorities remain consistent with national density requirements and that higher densities should be encouraged in more accessible locations, however, there should be flexibility for each site to be considered on its own merits.

Small Site Windfall Allowance (<10 homes)

4.22 As highlighted above, it is understood that the small site threshold has changed from 15 dwellings to 9 dwellings, however, the allowance has not changed to reflect this lower threshold. It is advised that the allowance is amended to be reflective of evidence of windfalls under 10 dwelling . The additional 4,990 homes over 10 years is, therefore, likely to be less.

Large Windfall Sites (10+ homes/ not currently employment land)


4.23 Again, as identified above, given that all sites that are likely to come forward for development should be identified within the SHLAA, it is considered that large windfall sites should be minimal. n addition, the authorities updated the SHLAA on an annual basis and therefore new sites should be captured.In addition, there is a finite supply of such land and accordingly it cannot be relied upon heavily as there is concern the sites coming forward will reduce.

4. 24It is welcomed that the allowance for large sites is half of current rates, however, there remains concern that the delivery of this land is not certain. It is advised that the Councils do not rely on this source as a component of supply and that it is a bonus to the supply should opportunities come forward .

Occupied Employment Land

4.25 As highlighted above, to implement the findings from the qualitative assessment of employment land to ensure that it is fit for purpose and when it does not meet

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future employment needs it should be transferred to a more compatible use. It may be the case that new land outside the urban area may be appropriate for employment land. The qualitative assessment will assist to define an appropriate employment land strategy.

4.26 Conversely, some sites that have been identified for housing remain in employment use and are actively occupied. It may be the case that some existing sites assigned for housing remain as employment land. Aga in, the qualitative assessment w ill assist in identifying this.

Other Sources

4.27 In terms of releasing open space for housing, evidence would need to demonstrate that change the use is acceptable in planning terms.

Summary

4.28 It is concluded that through changes to the methodology, additional supply can be found, however, there are a number of concerns relating to these changes as identified above. Whi lst more homes would be delivered ,there are potentially other detrimental and undesirable consequences that could occur. It is important, therefore, that the Black Country authorities consider the wider implications of the changes proposed.

Conclusions

4. 29 There is clearly a significant challenge in finding sufficient sites to meet the arising need for homes identified by the 2017 SHMA. Whilst it is commendable that the Black Country authorities are attempting to maximise the housing land supply from existing sources in the urban area, there is concern that there are wider policy implications for increasing densities, relying on large windfalls and sites in other uses. It is suggested that the Counci ls need to review the suggested changes in the Housing Supply Background Report in the context of the responses to the
Issues and Options Core Strategy Review and other policy matters, as well as undertake more work on certain policy aspects as suggested to ensure the strategy is deliverab le and ultimately a successful plan for growth.

Pegasus


5. Overall Conclusion

5.1. In summary, the evidence has identified that there is a challenging dwelling requirement in the sub HMA, that the is a need for affordable homes that is likely to be met through the dwelling requirement and that there are limited urban sites to accommodate additional homes. This evidence clearly identifies the need for a Green Belt Review,to find out if land outside the urban area and inside the Green Belt could come forward to assist in meeting the dwelling requirements. If there are insufficient sites within and outside the urban area, it is possible that some of the unmet needs are exported outside of the Black Country but within the sub HMA and other potential locations considered thereafter.

5.2. Finally, a number of queries/ suggestions have been made in respect of how the evidence has been prepared/ or is to be taken forward.It is recommended that this advice is taken on board in order to ensure the Core Strategy Review is sound in accordance with the NPPF requirements.

These representations are made to the Black Country Issues and Options report by Peveril Securities. Peveril is a commercial and residential developer based in the Midlands with a long track record of delivering employment and housing sites. Amongst Peveril's current projects are a large site where planning permission has recently been received (formerly Green Belt) for housing and commercial uses adjacent to the proposed HS2 station at Toton, Nottingham. The company also has a joint venture with another developer which is seeking to bring forward the Royal Ordnance Factory site at Featherstone to the north of the M54. The company also brought forward the Wolverhampton Business Park on the eastern edge of Wolverhampton.
1.2 The company controls land located to the south of the M54 between junctions 1 and 2, and owns land broadly speaking between the outskirts of Wolverhampton and Cannock Road further to the east and the M54 to the north. The area of land controlled is shown on Land Inclusion plan.
1.3 Peveril welcomes the opportunity to participate in the Core Strategy process in the Black Country including South Staffordshire. The company has made representations to South Staffordshire's emerging Sites Allocations Document in the context of the current Core Strategy. These seek to bring forward an extension to the Royal Ordnance Factory site (as SSBC propose) and also to request South Staffordshire Council safeguard land for the further expansion of Hilton Cross as a strategic employment site within South Staffordshire.
1.4 The representations made by Peveril seek to cover the following areas and issues raised within the Black Country Issues and Options report:
1. The overall scale of housing being proposed.
2. The overall scale of employment land being proposed.
3. The strategy for the release of strategic sites (including Green belt) for both housing and employment.
4. The use of regeneration corridors to promote growth.
5. Other factors and timing.
1.5 Peveril welcome the progress that is now being made within the Black Country authorities with a view to proposing a strategy for defining of the appropriate scale of housing and employment land regarded as appropriate (mainly as an overspill for Birmingham) up to 2036. The strategy of accepting at the outset that in order to meet such needs there will be a
requirement for significant release of Green Belt is supported. In addition Peveril supports the inclusion of South Staffordshire as a location to meet housing needs given it is a sub market of the HMA. Peveril welcomes the need to comprehensively review the Green Belt as part of the growth strategy and agrees that the authorities should take a realistic view of the scale of land likely to be required to meet future needs.
Comments on Overall Housing Land Requirement (Key Issues 1 and 2)
1.6 Peveril notes that the conclusions of the Issues and Options report about the likely levels of housing need required are strongly related to the results of the Examination into Birmingham's housing requirements as part of its Development Plan and the 'overspill' that is needed to be provided for outside the City in the Black Country. The overall figure arrived at for the housing requirements to be provided in the Core Strategy Plan period is based on the 2016/17 SHMA and then the completion figures and SHLAA assumptions. This results in a residential requirement of 21,670 dwellings with a further 3,000 dwellings added to meet the wider HMA shortfall hence an overall requirement of some 24,670 dwellings up to 2036.
1.7 Peveril agrees with the Black Country authorities that the requirement to meet needs emanating from Birmingham has been established and needs to be met. Failure to do so would be a failure under the duty to co-operate in terms of the soundness tests for Local Plans in the NPPF. The quantity of the unmet need from Birmingham is in itself an up to date objectively assessed need (OAN). We understand there is a methodology paper being prepared that sets out how future housing needs may be met in the Black Country, notwithstanding the fact that much work has already been done in terms of the quantification of unmet need from Birmingham, the 2016/17 SHMA etc. What needs to be certain is that the overall quantification of housing needed in the Black Country does not miss out any important considerations that might be specific to the Black Country rather than taken as read as Birmingham's unmet needs. Thus it is important that any OAN figure for the Black Country takes into account key issues such as housing market signals and economic considerations in the Black Country as well as taking as a given those calculations that affected the housing needs in Birmingham.
1.8 Peveril would therefore wish to see as part of the process the calculations that may follow from the methodology so that the Black Country authorities can be satisfied that all relevant considerations affecting housing land provision (and related employment land provision) in the Black Country have been taken account of in addition to the unmet need from Birmingham. It is also important to test the deliverability of the SHLAA sites which are claimed to deliver over 48,000 homes in the Plan period as well as windfall sites.

1.9 Notwithstanding those concerns, it is clear that overall requirement of 24,670 houses in the period to 2036 represents a significant amount of new land to be found. An up to date calculation of OAN in accordance with the emerging Government methodology (and current in relation to the methodology accepted by LPAC) would be advisable. This may result in additional dwellings to 24,670 overspill figure being generated.
1.10 Peveril would therefore reserve its position in terms of whether the 24,670 dwelling requirement figure to 2036 represents an appropriate OAN until the results of an up to date methodology being applied to the relevant statistics affecting the Black Country and Birmingham overspill has been undertaken and checks made of deliverability assumptions on SHLAA and windfall sites.
Employment Needs (Key Issue 3)
1.11 The Issues and Options report makes a conclusion that some 300 hectares of new employment land is required up to the period 2036. It is very important in Peveril's view that both the quantity of employment land and the quality of land available is comprehensively dealt with in the Issues and Options report and emerging Core Strategy. It is essential that high quality sites are identified and the most use is made of the Black Country's assets - mainly good quality highway links in order for employment land to be delivered rather than simply identified. The calculations that have been made to arrive at the 300 hectare figure - while accepted to be not as precise as required for housing - in Peveril's view understate the true need for good quality employment land.
1.12 Peveril is concerned that having identified a qualitative need over the Plan period of 800 hectares of land for employment (via the EDMA report), this figure is then reduced by 394 hectares of land which is either "currently available or is likely to come forward within the Black Country, including opportunities to intensity existing employment areas". The assumptions about the ability of the 394 hectares to deliver quality land - rather than be poor quality sites which will not be delivered - do not appear robust.
1.13 In this regard (paragraph 3.27 of the Issues and Options report), Peveril strongly supports the idea of building upon successful and high quality locations for new investment such as the M54 corridor.
1.14 In this regard, Peveril's view is that the existing regeneration corridors as set out in current Local Plan (see Figure 8 of the Issues and Options report) needs reviewing and widening with the potential to allocate good quality employment land within enlarged regeneration corridors (see below). The 300 hectare figure also seems somewhat low given the potential for large

employment sites to be allocated within quality locations and/or regeneration corridors. Strategic sites such as ROF Featherstone and Hilton Cross in the M54 corridor in the Wolverhampton/South Staffs area are in themselves quite large sites. The 300 hectare requirement would soon be taken up by four or five large sites if suitably high quality locations were found for employment leaving little residue left for smaller scale allocations. In Peveril's view, therefore, the Core Strategy should seek to identify key strategic employment locations first without necessarily seeking to restrict overall development for employment purposes to 300 hectares. This is in addition to reviewing the 300 hectare figure.
Strategy for Allocation of Land for Housing (Strategic Option 1A)
1.15 Peveril supports the conclusions made in the Issues and Options report in respect of the need to release Green Belt land to meet the housing requirement because there is insufficient brownfield land available. Peveril supports the acknowledgement within the Issues and Options report that South Staffordshire would have a key role in enabling the Black Country authorities to meet the emerging development requirements.
1.16 In this regard South Staffordshire is in the latter stages of its Part 2 Local Plan process. Peveril is participating in this process and it is understood the Examination into the Part 2 Plan will take place in November 2017. South Staffordshire wishes to conclude its Local Plan process and then for the new development requirements identified through the Black Country Core Strategy to 2036 to immediately be taken into account in a review of its policies. Whilst this is not ideal - and Peveril has suggested the potential to identify safeguarded areas of land to be removed from the Green Belt pending the adoption of the Black Country Core Strategy - it is probably in practical terms the best way forward. The alternative would be to suspend the current Local Plan which would not be in the interests of providing certainty (albeit for a short period) in South Staffordshire about future development requirements.
1.17 As far as Issue 1 in the Core Strategy is concerned - whether the provision for housing should be carried out on the basis of looking at sustainable open extensions rather than piecemeal releases - Peveril would strongly contend that priority should be given to identifying sustainable urban extensions. The land which Peveril controls to the north of Wolverhampton and to the south of the M54 (see representations below) would allow a sustainable mixed development to be planned in a more comprehensive way and for new facilities to be brought forward as part of a sustainable urban extension. The alternative for providing numerous piecemeal extensions would be a less comprehensive strategy to facilities - education; local centres; open space and transportation. With impact of development more widely dispersed

rather than concentrating in a specific allocation where it may be more possible to achieve acceptable mitigation.
1.18 Peveril would agree with the Council that it is difficult to define the scale of what represents a sustainable urban extension. In terms of transport and to achieve a new station (for example), the potential extension of up to 10,000 dwellings would not be unreasonable; however, there can be sustainable urban extensions that would take place with many fewer dwellings than that. From experience elsewhere, an extension of 1,000 dwellings of more could be regarded as sustainable as that level of development can provide a reasonable local centre; school and strategic open space.
1.19 It is also possible in a sustainable urban extension to provide employment facilities. In the case of Peveril's proposals, those employment facilities could be both local but also related to existing strategic employment sites. The presence of Hilton Cross - and potential extension to it - along with the Royal Ordnance Factory would make the area to the east of Wolverhampton a good location for a housing based urban extension because existing and proposed strategic employment sites already exist in that area. The employment land shortfall identified of 300 hectares should firsts and foremost be considered in the context of the ability to extend the existing strategic employment sites which were identified because of their good proximity to strategic transport networks.
Regeneration Corridors (Key Issue 3 and Question 10)
1.20 Peveril will support the concept of regeneration corridors set out in Figure 8 of the Issues and Options report, i.e. current Local Plan allocations. A review should be carried out of those corridors to see whether they can be extended or added to in a way that first and foremost allows high quality employment land to come forward. Peveril would also suggest either the extension of the existing Stafford Road regeneration corridor to the north of Wolverhampton for the creation of a new regeneration corridor along the M54. This would take within the corridor the existing strategic sites at Hilton Cross and the ROF and I54 as well as giving the ability for such sites to come forward with new housing - as Peveril suggests (see below). The regeneration corridors can be used as a basis for extension of existing good quality employment land and potential allocation of land as a sustainable urban extension.
A Potential Urban Extension to the East of Wolverhampton (Spatial Option H2)
1.21 Peveril's land control extends over an area of land of some 84.74 hectares lying in between the M54 to the north (including Hilton Cross); Cannock Road to the east; Underhill Lane/Bushbury Lane to the south and the northern outskirts of Wolverhampton to the west.

It is understood Wolverhampton City Council owns land (currently abandoned playing fields) in the south-western part of the site. There is woodland and Northcote Country Park at the centre of the site as well as heritage assets. The area can be put forward as a sustainable urban extension because of its location and because it is well-defined by roads that could be used as the outer edge of a new Green Belt boundary as well as being in close proximity to existing largescale employment proposals - at Hilton Cross; the Royal Ordnance Factory and I54.
1.22 It is not the purpose of these representations to carry out a full assessment of the landscape impact; transport or other site specific considerations. However, an initial masterplan has been prepared to identify the potential capacity of the site when taking a reasonable view of the existing on-site constraints. This masterplan is attached. It shows that the site under the control of Peveril (including the Wolverhampton City Council land) can accommodate some 38 hectares of land for housing together with a local centre; primary school; access routes and the protection of existing woodland, the country park and listed buildings. Access arrangements can be provided for in the context of a new road running east-west through the northern part of the site. This road is different to the route option 9 which the County Council is currently considering as a means of providing appropriate access for the Royal Ordnance Factory site to the north of the M54. Whatever route option is taken to serve the Royal Ordnance Factory this will not prejudice the release of the sustainable urban extension proposed by Peveril.
1.23 In addition to the housing areas, there is benefit in extending the Hilton Cross employment site sitting in the north-eastern corner of the area Peveril controls. This could be extended by a further 7 hectares. This area could be part of the sustainable urban extension to provide jobs for new residents alongside those being created at the Royal Ordnance Factory. In these terms the site could:
1. Provide up to 1,350 dwellings in a sustainable location.
2. Be well related to existing and proposed strategic employment sites.
3. Provide local facilities to support the scale of development proposed.
4. Establish new but long term Green Belt boundaries.
5. Be deliverable due to Peveril's land control.
1.24 It is considered that the potential to release this land and provide well-established Green Belt boundaries in accordance with the advice in paragraph 85 of the NPPF provides a realistic and

deliverable means of allowing the expansion of Wolverhampton - the site crosses the border between Wolverhampton City and South Staffordshire - in a way that allows the benefits of a mixed sustainable extension to the urban area to come forward. Peveril would be willing to discuss these matters further but in terms of how the policies are evolving for the Black Country Core Strategy suggests this site be identified as a sustainable urban extension. Peveril considers that the Core Strategy should identify key sites that would comprise sustainable urban extensions in a specific policy rather than necessarily make general statements about overall strategy to accommodate the 24,670 dwellings (if that is the figure eventually regarded as the OAN for the area).

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

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

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

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

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

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

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

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

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