Key Issue 2 - Meeting the housing needs of a growing population

Bromsgrove District Council Response to the Black Country Core Strategy Issues and Options Report September 2017

1 Thank you for the opportunity to comment on Black Country Core Strategy Issues and Options Report, the below comments at this stage represents an officer response. Due to the timescales for consultation, there have not been any appropriate Council meetings for this response to be considered formally. This process will take place in October and should any amendments be required as a result of the formal consideration by Bromsgrove District Council we will advise you in due course.

2 At this early stage in the plan making process, the issues and option presented are viewed as a sensible approach to what is a substantial task of reviewing the existing Core Strategy. Whilst in principle partially reviewing the plan as opposed to a wholescale rewrite would appear to be a pragmatic. The introduction of substantial site allocations on land currently allocated as green belt into the process, may necessitate a more substantial review further down the line, should this be the view of BDC the Council will respond appropriately on this point in due course.

A number of more focused comments have been prepared relating to the key issues / sections of the report which are detailed below.

Key Issue 2 - Meeting the housing needs of a growing population.

3 The housing needs of the Black Country as presented under Key Issue 2 is clearly a big challenged which the plan is addressing positively. The Council accepts that a detailed piece of evidence has been presented in terms of the objectively assessed housing need, and at this stage has no reason to doubt the overall figure of 78,190. Recognition of the ongoing work being undertaken at the HMA level is welcomed, and BDC will continue to work alongside all HMA authorities in an effort to fully understand the needs of the Market area and the options for distributing growth. The 3000 houses which the Black Country Authorities have agreed to test is in principle supported. The statement at 3.19 of the report is significant and BDC agree that all the figures surrounding the housing requirement of the plan need to be tested on an ongoing basis as the plan evolves and more evidence becomes available.

Key Issue 3 - Supporting a resurgent economy

4 It is important that the Black Country continues to play its role in the economic prosperity of the region. The requirement of 800ha of employment land over the plan period would appear to maintain a flexible supply of land to cater for a wide range of needs. Acknowledging that the plan already envisages some existing employment land will be lost to housing, it is key that the best employment opportunities are safeguarded. If there are further opportunities for employment land to be released for other uses to minimise greenfield development then they must be considered favourably if appropriate.

Key Issue 6 - Reviewing the role and extent of the green belt

5 As the green belt in the Black Country has not been fully reviewed for approximately 40 years it is key that this work is now undertaken thoroughly. The Council agrees that any sites released from the green belt should be done in the context of the Core Strategy, and not left for other development plans to try and achieve. This is especially important if land outside of the Black Country area is going to be required. For any other authority to agree to take any additional development, the commitment to releasing land from the green belt in the Black Country needs to be enshrined in this plan. This commitment needs to be supported by clear policies which prioritise delivery of sites within the Black Country, before any land in neighbouring authorities is developed.

Key Issue 9 - Working effectively with Neighbours

6 The Council has successfully worked with the Black Country authorities over a large number of years. We look forward to continuing this approach both through the Strategic Housing Needs Study, and also ongoing liaison through the Duty to Cooperate, we would welcome the opportunity to discuss this response at the earliest opportunity.

Section 4. Reviewing the Strategy to Meet New Challenges and Opportunities.

7 This section of the issues and options report is seen as the most important by the Council, decisions made under this heading will have far reaching and long term effect for people, the environment, and the economy both within the Black Country and also beyond its boundaries. The 8 growth options identified on table 2 will all have differing implications and opportunities, some of which could have direct impacts on Bromsgrove District. The Council is not objecting to growth in principle, indeed it will shortly be embarking on a review of its recently adopted plan, including releasing land from the green belt. At this stage the Council is not able to form any definitive views on the options as they are presented. It would seem that all the options in one form or another could involve land being required outside of the Black Country and possibly in Bromsgrove District.

8 The Council would welcome the opportunity to explore these options further; once more information is available as a result of the call for sites process. Understanding what land is being proposed within, and on the periphery of the Black Country is important to begin to assess if any areas being put forward will have an impact on the District, in both positive and negative terms. Options need to be considered holistically in the context of the Core Strategy and the functions and purposes of the green belt around the Black Country. They must also be considered in the context of any emerging review of the Bromsgrove plan. If land is proposed to be released in the areas of Black Country near Bromsgrove or vice versa, full consideration must be given to ascertain if there are approaches which can complement both authorities plans, and bring benefits to both areas.

Policy Area E

9 Transport infrastructure both existing and new is vital to the success of the Core Strategy, the road links between Bromsgrove and the Black Country are heavily used and in some instances congested. Recent disruption caused by work being undertaken on the M5 at Oldbury has highlighted how infrastructure issues north of the District have significant effects across Bromsgrove, this is especially relevant for transport networks and the motorways in particular.

10 The Council welcome the statement made at para 6.1.28 'following the issues and options stage further transport modelling will be undertaken to forecast the traffic impacts of the specified green belt scenarios, identify locations that may require further investigation regarding traffic impacts and identify the transport infrastructure requirements for any potential new green belt sites (including highway, public transport, walking & cycling routes).' It is our view that the location of development should, along with all the other evidence, be informed by the consideration of the results of highways modelling as described above, and modelling should not be used simply to identify the mitigation required from a pre chosen site.

11 Bromsgrove DC has been working closely with Worcestershire County Council in response to the Worcestershire Local Transport Plan 4 to begin the preparation of a transport strategy for the north Worcestershire area. As part of this strategy the links and journeys by all modes, between north Worcestershire and the Black Country, and also those that pass through north Worcestershire will need to be understood. Following on from that the implications of range of development scenarios will need to be tested to inform final choices about development locations. We would welcome the opportunity to discuss this further with the Black Country. We would like to ensure that the tools that are available to assess the transport implications of developments some of which may have wider implications that just in one local authority area are used to the fullest, to ensure sustainable development patterns.

BDC Strategic Planning
6.9.17

Thank you for consulting Lichfield District Council on the Black Country Core Strategy Review Issues and Options Consultation.

The Regulation 18 consultation document produced jointly between the four Black Country authorities sets out the scope for the Black Country Core Strategy Review (BCCSR), with the aim to identify the issues that the review will address and the broad options for how sustainable growth of the Black Country can be achieved. Given that this is an initial stage of the plan making process our comments below are fairly general.

Approach towards Core Strategy Review
Lichfield District Council note the proposed approach towards undertaking a partial review of the existing Core Strategy, seeking to carry forward and 'stretch' the existing spatial strategy and to update the spatial strategy and policies in light of new evidence and changes in national policy, rather than carry out a wholescale review.

At this stage, we have initial concerns with the proposed approach towards carrying out a partial review as opposed to a wholescale review. We consider that given the significant changes in National Policy since the adoption of the Core Strategy, namely the abolition of Regional Spatial Strategies and the introduction of the National Planning Policy Framework, there is a need to ensure that the BCCSR explores all options for growth from the outset and carry out a wholescale review as opposed to updating the existing spatial strategy as suggested.

Housing Provision
The authorities within the Greater Birmingham Housing Market Area (GBHMA) (including Lichfield, Dudley Metropolitan Borough Council, Sandwell Metropolitan Borough Council, Walsall Council and the City of Wolverhampton Council) are working together to determine how to address the shortfall within the GBHMA of 37,900 dwellings which is primarily from Birmingham City Council being unable to accommodate all of its housing requirements within its boundaries. As this work moves forward, it will be important for the Black Country authorities to consider how the emerging BCCSR may need to respond to any proposals which relate to the quantum and distribution of housing across the GBHMA.

Duty to Cooperate
The Duty to Cooperate will be of great importance as the plan evolves, particularly in relation to potential sites where cross boundary work is necessary, Cannock Chase SAC and matters relating to the green belt. Therefore, Lichfield District Council welcomes continuing positive dialogue with the Black Country authorities as the BCCSR progresses.

BLACK COUNTRY CORE STRATEGY ISSUES AND OPTIONS CONSULTATION - LAND AT
FORMER GOSCOTE HOSPITAL SITE, GOSCOTE LANE, WALSALL, WS3 1SJ
On behalf of our client, NHS Property Services Ltd (NHSPS), who are the landowner of this site (plan
below), we wish to make representations, in respect of the above site, to the Black Country Core
Strategy Issues and Options Consultation. These representations are accompanied by a Site Location
Plan contained within the Constraints and Concept Plan design document. This document sets out an
indicative capacity to support these representations.
Contains Ordnance Survey data © Crown copyright and database rights 2016. Ordnance Survey 100053719.
In addition, a Call for Sites form is submitted with these representations, in response to the Call for
Sites exercise which runs parallel to the Issues and Options Consultation.
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a. NHS Property Services Site Ownership
In April 2013, the Primary Care Trust and Strategic Health Authority estate transferred to NHSPS, Community Health Partnerships and NHS community health and hospital trusts. All organisations are looking to make more effective use of the health estate and support strategies to reconfigure healthcare services, improve the quality of care and ensure that the estate is managed sustainably and effectively.
In particular, NHSPS's Property Strategy team has been supporting Clinical Commissioning Groups and Sustainability and Transformation Plan groups to look at ways of better using the local health and public estate. This will include identifying opportunities to reconfigure the estate to better meet commissioning needs, as well as opportunities for delivering new homes (and other appropriate land uses) on surplus sites emerging from this process.
By way of background, local health commissioners are currently developing a strategy for the future delivery of health services in this area. This will involve the release of certain NHSPS landholdings which are no longer required for the delivery of health services.
The existing health and social care buildings are to remain on site, and continue to be operational. However, the site includes a number of areas with development potential. In particular, the southern and western land parcels of the subject site including Goscote House are likely to be considered surplus to the operational healthcare requirements of the NHS. Confirmation is expected within the next 12 months. These site parcels should be therefore be considered suitable for alternative uses including a range of residential accommodation, depending on the needs of the local community. In addition, NHSPS are reviewing the wider site to understand any further development opportunities. In this regard, these representations seek the release of this entire site from the Green Belt. The subject site is considered available, suitable and deliverable within the initial 5 year period.
b. Site Context
Goscote Lane is located within the small town of Bloxwich, to the north of Walsall. The site lies on the western boundary of Bloxwich.
The site is approx. 2.0 Ha with direct access off Goscote Lane, to the north of the residential area of Walsall. Formerly Goscote Hospital, the site now includes a Social Care Centre and Palliative Care Centre, as illustrated on the drawing site constraints plan. The existing health and social care buildings are to remain on site, and continue to be operational. The wider site (all within NHSPS ownership) includes a number of areas with development potential.
The site is bound by low density residential development to the north, Goscote Lane to the west, Wyrley and Essingon Canal to the east and Goscote Greenacres to the south.
The site is located 2.4km to the east of Bloxwich Train Station. The site is served by bus routes 25 and 26, which provide excellent connections to the services and facilities of Walsall, Bloxwich and Kingstanding. These bus stops are located on Goscote Lane, which borders the site.
The southern (C) and western (A and B) land parcels are likely to become surplus to the operational healthcare requirements of the NHS, and are being promoted to provide additional residential development and/or the provision of care home uses. The southern element currently comprises the locally listed Goscote House and associated car parking. The western element is currently undeveloped, and provides surplus land to the existing health and social care facilities..
As set out within these representations, it is considered that the wider site, which falls within the landholding should be released in its entirety from the Green Belt.
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c. National Policy (NPPF) - Requirements for a Local Plan
The National Planning Policy Framework (NPPF) is the preeminent national policy; in law, regard must therefore be had to it. In summary, the following paragraphs of the NPPF are of particular relevance to the Local Plan making process, and should be complied with:
a) Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. They should be consistent with the principles and policies set out in the NPPF, including the presumption in favour of sustainable development (Paragraphs 150-151).
b) Proposed housing supply must meet evidential need for housing of all types, including a 5% buffer for five year housing targets (or 20% in cases of persistent under delivery), these targets must be deliverable. The Council must identify a supply for years 6-15 which is specific and developable (Paragraph 47).
c) Local Plans should be aspirational but realistic. Only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan (Paragraph 154).
d) Local Plans should be based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.
e) There is a cross-boundary duty to co-operate, particularly with planning issues which relate to the strategic priorities. LPA's should work collaboratively with other bodies to ensure strategic priorities across local boundaries are properly co-ordinated and clearly reflected in Local Plans (Paragraph 178-179).
f) The Inspector's primary task will be to consider the soundness of the submitted plan, this will be assessed against the following soundness criteria:
 Positively prepared - the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
The Housing White Paper (February 2017) urges local authorities to make more land available for homes in the right places by maximising the contribution from brownfield land, releasing more small and medium sized sites.
d. Overview of the Black Country Core Strategy
The Issues and Options consultation is the first stage of the review of the Black Country Core Strategy. The Core Strategy is a key part of the Local Plan for the Black Country Local Authorities which covers
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the areas of Dudley Metropolitan Borough Council (MBC), Sandwell MBC, Walsall Council and the City of Wolverhampton Council.
The existing Core Strategy was adopted in 2011, covering the period up to 2026. Upon adoption, in accordance with national planning guidance, it was agreed that the Core Strategy would be reviewed in whole or in part at least every five years.
Since adoption there has been a number of changes to national policy, furthermore a housing shortfall has been identified in Birmingham which neighbouring authorities, notably the Black Country, have a duty to consider accommodating.
The Council state that although the Core Strategy is considered generally fit for purpose, this consultation stage will identify emerging issues and set out how the sustainable growth of the Black Country can be achieved.
The documents which make up the current evidence base for this consultation exercise, and are of key relevance to these representations, are set out as follows:
 Black Country and South Staffs Strategic Market Housing Assessment - March 2017; and
 Greater Birmingham and Solihull LEP Black Country Local Authorities Strategic Housing Needs Study - August 2015
Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services, such as open space, shops, schools and healthcare, are provided.
The strategic challenges and opportunities are expressed as a set of nine key issues. Of note, and focussed within these representations are:
 Meeting the housing needs of a growing population
 Reviewing the role and extent of the green belt
Meeting the housing needs of a growing population
The Black Country and South Staffs Strategic Market Housing Assessment (SHMA) 2017 concluded that the Objectively Assessed Housing Need (OAN) for the Black Country over the period 2014-36 is 78,190 homes. It is anticipated that the housing supply, identified in the SHLAA, can deliver 48,185 of the homes needed, approximately 60%. Identified sites and "windfall" sites could deliver approximately 8,000 homes. Initially, there is a gap between need and anticipated supply of around 22,000 homes across the Black Country.
The Greater Birmingham and Solihull LEP Black Country Local Authorities Strategic Housing Needs Study identifies a shortfall across the wider Housing Market Area (HMA) of approximately 38,000 dwellings.
The Black Country have committed to test the accommodation of an extra 3,000 homes up to 2031 beyond local need, to help address the shortfall in the wider HMA. This produces a total requirement for land to accommodate 24,670 new homes.
Given the foregoing, the Council acknowledge that a large number of new homes and supporting services will need to be accommodated outside the existing urban area of the Black Country. All such land in the Black Country is currently Green Belt.
Paragraph 3.15 of the Issues and Options Consultation document identifies that there may be potential to release limited areas of surplus open space for housing in some areas. The existing Goscote House site (Parcel A and B) could deliver 49 residential units.
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In addition to this the vacant plot (Parcel C) could provide care-home uses comprising 5,600 sqm over 2 floors, and/or additional residential accommodation.
Needs of the ageing population
The SHMA provides guidance on the likely needs of different groups for housing over the new Plan period.
As set out within the Black Country Issues and Options Consultation, in addition to the SHMA, a key factor in household growth is that people are on average living longer than previous generations.
In particular, paragraph 6.30, of the Issues and Options Consultation, highlights a need for 162 new sheltered and extra care homes every year to meet the needs of older persons - 5% of the total housing need.
Utilisation of this site for the provision of care home uses, would contribute towards this need. Furthermore, a large percentage of the Black Country's ageing population rely on living within easy walking distance of healthcare. It is therefore important to locate new homes in areas with good access to existing healthcare and community services or where new, sustainable facilities can be created to serve new development.
Policy Area A, of the Issues and Options Consultation, focuses on Health and Wellbeing. Paragraph 6.10 stipulates that accessibility to health care and community facilities must be addressed in terms of location and physical access.
Accordingly, it is considered that redevelopment of this site, the provision of residential units, and or the provision of care home uses, would seek to achieve the objectives of Policy Area A. Furthermore, such redevelopment would meet the needs of the Black Country's ageing population, maintaining accessibility to existing health care.
Reviewing the role and extent of the Green Belt
As set out above, evidence has identified that a significant amount of Green Belt will be required to help meet the housing need within the Black Country and the wider HMA. Given this, is has been decided that a formal review of the Black Country green belt should be carried out through the Core Strategy review.
In this instance, two studies have been commissioned. The evidence base for Key Issue 6 will comprise:
 Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study; and
 Black Country Green Belt Review.
We expect that the two studies together will provide a robust and thorough examination of the green belt to assess and identify the potential to release sites from the green belt, alongside growth within the urban area, to meet the projected needs identified for housing and employment growth up to 2036.
This site is located within the Green Belt. Given the existing built form, the land at Goscote Hospital which falls within the red line boundary, constitutes previously developed land within the Green Belt.
It is evident, as set out below, that the site in its entirety, encompassing the existing health and social care facilities, does not serve the five purposes of the Green Belt. Accordingly, these representations seek the release of the entire site from the Green Belt.
Given the Evidence Base for the Black Country Issues and Options document, it is apparent that extra homes required across the Black Country will need to be built on Green Belt land.
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Paragraph 1.19, of the Issues and Options Consultation document, seeks to ensure that that any release of green belt sites for development does not take place at the expense of urban regeneration. Given the characteristics of this site, this is not a concern which should be associated with future development in this location, as small scale redevelopment would ensure that the characteristics of this area are retained.
The NPPF identifies that Green Belt serves five purposes:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Green Belt is central to the Black Country Core Strategy. It is considered, that when assessing the function this site performs within the Green Belt, it is very low.
The sites natural boundaries, prevent future development from unrestricted sprawl and the countryside from encroachment. Given the sites location, redevelopment would not result in neighbouring towns merging together. Furthermore, redevelopment of this site, given its existing built form would encourage the recycling of derelict land, which should take preference over untouched green belt land.
Accordingly, when reviewing release of land from the Green Belt, given the foregoing, it is sites such as this which should be considered first.
e. Reviewing the Spatial Strategy
Strategic Option 2A seeks to accommodate housing growth outside the urban area. Within this option, two broad Housing Spatial Options have been identified.
Spatial Option H1
Spatial Option H1 is based on 'round off' the Green Belt edge. It is considered that this could be done by way of a large number of small to medium size sites.
We consider that this is a suitable option for future growth of the Black Country, specifically Walsall. It is anticipated by the Council that sites could range in size from a few homes to hundreds of homes, where this would provide a defensible new green belt boundary and sufficient services exist. Furthermore, identifying large and medium sites would not require significant infrastructure, and would be deliverable in a lesser time period.
The site at Goscote Lane should be identified as one of such sites, given that it adjoins the existing built up area and contributing to the housing need of Walsall and the Black Country. This site is available, achievable and deliverable.
Spatial Option H1 would provide for development to take place within the urban area closer to where need arises.
Spatial Option H2
Spatial Option H2 seeks to identify a limited number of large scale Sustainable Urban Extensions (SUEs). It is considered by the Council, that such an option would significantly boost the supply of housing and maximise provision of affordable housing.
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Given that no SUEs are currently being promoted in the Black Country it is considered that a significant level of work would be required in order to identify suitable locations. Consequently, such sites would require a range of infrastructure and services.
It is considered that Spatial Option H2 would concentrate delivery later in the plan period, and place a heavy reliance on a limited number of large sites.
In our view, exploring both options H1 and H2 would seek to ensure housing is delivered across the Black Country in the short and long term. Both options would promote wider choice and opportunity within the housing market and allow diversification of the housing stock.
In utilising both spatial options, housing units could be delivered in the short term, building upon existing infrastructure. Whilst locations could be identified for SUE's and understand the need, timing and cost of the range of infrastructure and services required.
f. Walsall's Role within the Black Country Core Strategy
Two of the key objectives for the Walsall Site Allocations Document which the Black Country Core Strategy seeks to support are:
 To deliver sustainable communities through the development of new housing on vacant, derelict, and under-used land...to provide a range of homes that meet the needs of all members of the community.
 To provide a regeneration strategy for Walsall that promotes sustainable growth within the existing urban areas whilst protecting the Green Belt from inappropriate development.
Furthermore, re-using previously developed land and providing smaller housing sites means that there is unlikely to be a need for significant new infrastructure to serve the redevelopment of this site.
In addition to the aforementioned, Walsall have set a target of providing 95% of new dwellings on previously developed land. All of these principles are supported within the Black Country Core Strategy, and therefore support the release of this site from the Green Belt, and more specifically the redevelopment of parcels A, B and C for residential development and/or the provision of care home uses.
g. Development Potential
Given the foregoing, it is considered that this site would be suitable for small scale residential redevelopment and/or the provision of care home uses.
In the first instance, it is imperative to note, this site is being promoted at this stage, and within the Call for Sites, as it is achievable, capable of being delivered within the early years of the plan period (0-5 years) and viable. In addition, the site responds positively to a number of the Core Strategy objectives.
A conceptual masterplan is included within these representations at Appendix 1. This indicative masterplan demonstrates that the site can accommodate 49 residential units and the provision of care home uses (approximately 5,600 sqm). It is anticipated, at this stage, that redevelopment would comprise the existing Goscote House (A), existing car parking (B) and vacant land (C).
It is anticipated, at this stage, that this would provide 21 flats and 28 houses comprising the following housing mix:
 9 x 1 bed flats;
 12 x 2 bed flats;
 7 x 2 bed houses; and
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 21 x 3 bed houses.
Policy HOU2: Housing Density, Type and Accessibility sets a framework for determining the most appropriate house type mix at a local level. The Policy also sets a net density range of between 35 dwellings per hectare and 60 dwellings per hectare for the majority of sites.
Paragraph 6.29 of the Issues and Options Consultation document notes the importance that Green Belt release locations should be chosen on the basis of good walking, or public transport, access to residential services, however achieving high levels of access may be more difficult on the urban fringe.
This mix is indicative only at this stage to demonstrate the potential capacity of the site. The landowners welcome the opportunity to engage with the planning authority in terms of the detailed design of the proposals and the nature of the residential mix.
h. Summary and Conclusions
The issues and options document sets out that a large number of new homes and supporting services will need to be accommodated outside the existing urban area of the Black Country, all of which is currently in the green belt.
These representations set out and confirm the justification for the release of this site from the Green Belt. It is evident, that the wider site does not perform against the purposes of the Green Belt set out in the NPPF.
Accordingly, redevelopment of parcels A, B and C would provide a contribution to the Black Country housing need, which is currently identified as 21,670 new homes, and/or the provision of care home uses. The Constraints and Concept Plan design document includes an indicative capacity to support the main representations at this early stage. These representations therefore promote and identify the land at Former Goscote Hospital as a suitable site to contribute towards these requirements.
As detailed above, it is considered that the redevelopment of the land at Former Goscote Hospital, would contribute to the Council's Housing Need. This site presents an excellent opportunity for a modest, residential redevelopment and/or the provision of care home uses on previously developed Green Belt land. Small scale redevelopment would ensure that the characteristics of this area are retained, without the need for significant infrastructure.
Given the foregoing, it is evident that the land parcels at the Former Goscote Hospital site are achievable, capable of being delivered and viable.
We would request to be kept informed of future stages of the Local Plan preparation.

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).