Key Issue 3 - Supporting a resurgent economy

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

I oppose Green Belt development, but our experience, and intimate knowledge, relates primarily to all that Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'. You do not ask for a detailed representation but I list some pertinent issues:
1. The Green Belt area that I/ have defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire.The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley countryside, prevents major areas of Halesowen from coalescing with Stourbridge.
2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.
3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conc lusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.
4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country
.... ..... ..... whilst valuing its local character. ' This is true of the contribution that the specific Green Belt locations listed above provide.
5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.
6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy,ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.
7. The Urban Regeneration Strategy deployed in the approved plan of 2011 , works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.
8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture . The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

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).

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).