Key Issue 9 - Working effectively with neighbours

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.

The Campaign for Better Transport is a national campaign promoting the use of sustainable transport such as walking, cycling and the use of public transport such as buses, rail and Metro. We want to see the creation of a transport system that is a real alternative to the private car.

We welcome the publication of the Issues and Options report for the proposed revised Black Country Core Strategy and would make the following comments. For ease of reference, they are tied to the questions given in the on-line questionnaire webpage http://online.dudley.gov.uk/surveys/bccssurvey2017/bccs_planning_survey_2017.htm but are in a different order.

Working with our neighbours
Are there any West Midlands wide issues that the Black Country Core Strategy needs to consider?

Whilst the Black Country authorities have worked together to produce the Core Strategy, which effectively sets the planning policy for Dudley, Sandwell, Walsall and Wolverhampton, the Black Country should not be seen in isolation from the rest of the West Midlands conurbation or from the authorities in Staffordshire neighbouring the Black Country. There are a number of challenges facing the wider region and there needs to be joint working between authorities to tackle them. The West Midlands Combined Authority has emerged since the first Black Country Core Strategy was adopted in 2011, and it is clear that despite the set up for LEP's in the West Midlands that has seen three created including one for the Black Country there needs to be a West Midlands approach to meet the needs of the economy.

By far the biggest challenge facing the West Midlands is housing. The preamble to the Core Strategy suggests 22,000 new homes are needed. The "Birmingham Plan", published by Birmingham City Council and approved by the Planning Inspectorate suggested 51,000 new homes are needed by 2031 . One question that should be considered is whether the Black Country should look at assisting Birmingham by providing some of the additional homes that are needed by the city within its area. It is also notable that housing in the Black Country is often cheaper than that within the city of Birmingham, which will contribute to demand for commuting between the two areas.

The environment is also a key challenge. The links between air quality, pollution and public health are becoming better known, with recognition people living near to motorway and trunk corridors in urban areas suffer and have a poor quality of life. Planning leading to development being more car dependent is not the way to go; developers and local councils need to ensure sustainability.
Developments should be located near frequent, high quality public transport services (not an hourly bus that finishes at 6 p.m.), have the infrastructure needed for sustainable transport (e.g. cycle lanes, well lit footpaths for pedestrians) and should be future proof. There has recently been a lot of discussion about electric cars in the future and a number of manufacturers have indicated production of petrol and diesel engine cars will cease in the 2020's, in order to address air quality concerns.

However, there is a dearth of charging points for electric vehicles. New developments should provide these as a matter of course. Adapting existing buildings (some of which were built before mains electricity was widely available) will be even more challenging.

Meeting housing needs
Should the extra new homes needed across the Black Country be built on
Green Belt land only?
Employment land (where businesses currently operate) as well as some Green Belt?

We would not support housing development solely taking place on the Green Belt. Public transport connectivity to Green Belt sides around the Black Country and in neighbouring authorities is often poor with infrequent bus services or no local rail service (Brownhills springs to mind along with Hasbury). If development is to take place in Green Belt then there needs to be improvement to the public transport offer, coupled with good facilities for walking and cycling.

Supporting our town centres
Should we focus the growth of shopping, leisure and commercial development into our main town centres?

It's now clear that we are seeing a massive change in people's retail habits and in the way they do business, which will have an impact both on town centres and traditional high streets.

More and more people are now shopping on-line, covering everything from fashion and electrical appliances to the weekly supermarket shop. Financial transactions which used to be done in banks and post offices are increasingly being done on-line, with banks thinning their network of branches. Visiting the local council office to submit a planning application or apply for a blue badge during office hours is inconvenient - doing the process via a website open 24 hours a day is preferable for many citizens.

It is noticeable that the number of empty shops and offices is increasing. Dudley town centre has lost retailers owing to Merry Hill and out of town retail parks, but the pace has increased. Walsall town centre has pockets where there are empty shops and offices - although small businesses have kept the centre thriving.

Naturally the local authorities should do what they can in order to continue to support town centres and encourage small retailers to set up in empty units - particularly in properties they own. However, it is clear that there will be a reduction in "bricks and mortar" retail and a number of properties will become redundant. Even the "out of town" retail parks and supermarkets may reduce as retailers focus more on digital channels and home delivery. This may provide opportunities for local authorities in terms of what effectively would be "brownfield" sites which can be apportioned for other uses, for example housing or new commercial development to serve different uses such as manufacturing or leisure.
Indeed, increasing the proportion of housing in town centres may well be attractive as they are also transport hubs with good bus, rail and Metro connections. They also have local facilities and services nearby for the things that cannot be done over the internet.

Town centres should be developed and mixed use should be encouraged. They should not be left to wither and die. The Core Strategy must look at how town centres can be planned to ensure their continued vibrancy and look at all uses, not just retail and commercial development.

Protecting the environment
Which types of environmental areas should be provided to serve new developments?

Despite the industrial image the Black Country has been blessed with green space such as the Arboretum in Walsall and Mary Stevens Park in Dudley. This should be protected.

If there is large scale new development proposed "green space" should be provided. A park is multi use, it can provide a good route for pedestrians and cyclists (provided the paths are well lit and maintained) as well as being a facility for other uses.

Keeping the Black Country connected
What transport improvements do you think are required across the Black Country to improve our area's connections?

The geographic location of the Black Country means that it is not just a question of dealing with local flows of people and goods, two major motorways (M5 and M6) pass through as well as the West Coast Main Line - all vital parts of the strategic national transport network. The recent works on the M5 demonstrate that a lot of local journeys are being made on the motorway network, adding to the congestion and pollution that is blighting the area. It is essential for there to be modal shift of these local journeys to other modes of transport. Building new roads or widening new roads is not a sustainable option and will lead to more traffic.

Likewise the local rail network is full and operating at peak capacity. There is a need to address this quickly so there is space for modal shift and growth.

The Core Strategy references the Movement for Growth work done by the West Midlands Combined Authority. This covers a period to 2026. It is essential the Wednesbury - Brierley Hill Metro extension is operable well before 2026. The bus services between Dudley and Birmingham City Centre are hamstrung by congestion and it can take over an hour in the peaks to travel from the centre of Dudley to the centre of Birmingham. The Stourbridge - Birmingham railway line is standing room only during peak time and the car parks at local stations are often full by 08:00. There is a need to crack on with the Wednesbury - Brierley Hill Metro line and not delay matters any longer.

Looking ahead beyond 2026, the Core Strategy should be looking at what transport infrastructure will be needed to support the region. Network Rail has recently published their West Midlands Route Study , giving options for funders. However, it may be desirable to look beyond the options contained in the route study in terms of providing additional capacity.
There are aspirations in Movement for Growth for a new local passenger rail service to be introduced from Wolverhampton to Walsall, serving new stations at Darlaston and Willenhall, with Willenhall providing connectivity with planned new development there. We would suggest the opportunity be taken to extend this to Aldridge which would serve this growing town (population 27,000) as well as the villages making up Brownhills (population 12,676). This would also provide connectivity into Wolverhampton where new commercial development is planned in the city centre and at the i54 business park (which is served by a bus route from the city centre and where there are aspirations for either a Metro line or bus rapid transit route).

Whilst Midland Metro should be built between Wednesbury and Brierley Hill, there should also be provision along the Walsall - Stourbridge corridor for rail freight services to provide an alternative for trunk hauls along the M5.

The Core Strategy may wish to look at the provision in the Black Country for freight terminals and hubs. They should be connected to the strategic rail and road networks and should be on brownfield sites rather than Green Belt. Given that there is a change the rail freight market and some of the traditional flows such as coal and metals have declined one question to consider is are the current terminals (for example Wolverhampton Steel Terminal) satisfactory, or do new facilities need to be provided?

People's health and wellbeing
Do you think people's health and wellbeing should be a key issue in the Core Strategy?

Yes, people's health and wellbeing should be a key issue. Addressing the key transport issues of congestion and air pollution should, if done right and done well, improve people's health and wellbeing. The objective of the core strategy and the test of its success should be if it results in people choosing to move into and stay in the Black Country and businesses choosing to locate and invest in the area, because it is a place with an pleasant environment and excellent quality of life.

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

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

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

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

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

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

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

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

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

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

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

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

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

Social Infrastructure (Questions 22-25)

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

Physical Infrastructure (Questions 26-28)

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

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

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

These representations are made on behalf of clients who own land adjacent to the built up area of Aldridge at Barr Common Road as edged red on the attached drawing 4833.99: location plan. The land at Barr Common Road, Aldridge as edged red on drawing 4833.99 is being promoted for release from the Green Belt to accommodate new housing development.
Q1: Meeting Housing Needs
It is agreed that some or all of the extra new homes needed across the Black Country should be built on Green Belt. This does not necessitate the abandonment of the policy of promoting the development of Brownfield land, but the Black Country Core Strategy should recognise the need, in order to maintain a balanced portfolio of housing sites, to release land from the Green Belt.
In the adopted Black Country Joint Core Strategy, Policy HOU2 relates to housing density, type and accessibility. In the supporting text to Joint Core Strategy Policy HOU2 (paragraph 3.12) it states that the Black Country "suffers from a lack of housing choice, which limits its ability to attract more households and Social Groups A and B." The Joint Core Strategy recognises that one quarter of new market housing built in the Black Country is occupied by A and B households who are new to the area or who would otherwise have left. In this context, the Joint Core Strategy states "if the equivalent of national level A and B households in 2033 were to be achieved in the Black Country this would require all new market housing built over the Plan period to be occupied by A and B households". The Joint Core Strategy recognises that factors most likely to attract A and B households are "proximity to professional and managerial jobs" and "the appearance of the surrounding area and schools."
The Joint Core Strategy clearly recognises that throughout the Black Country there is a lack of aspirational housing. This was recognised by an Inspector who dealt with an appeal at Chester Road, Aldridge (APP/V4630/V/08/1202859). The Inspector identified the lack of aspirational houses within Walsall as being of very special circumstance to justify new dwellings in the Green Belt. The Inspector stated (paragraph 78):
"....there is little if any aspirational housing in Walsall and that the type of dwellings proposed would assist with the retention of entrepreneurs within the Borough."
In order to meet the housing requirement of the Black Country in the Plan period and also to address the evidential lack of aspirational houses, it is important to identify housing land to be taken from the Green Belt. This will improve housing choice, including the provision of aspirational housing and it will also ensure prompt delivery of housing.
Such an appropriate site to be released for housing will be land adjacent to 1 Barr Common Road, Aldridge as identified in red on the attached drawing 4833.99. Development of the site will provide for a range of housing in terms of its size, type, design and tenure. The site is not subject to any ecological or heritage constraints. There are no known technical constraints that would preclude the site being brought forward for development. The site is suitable, available and achievable for housing and is deliverable in the Plan period. Consideration should therefore be given to identifying the land at Barr Common Road within a general area to be released from the Green Belt to accommodate new housing.
The land at Barr Common Road is well related in terms of its scale and location to the existing pattern of development including the residential development north of Bosty Lane. The site is located such that it is within easy walking distance of all services and facilities within Aldridge. Barr Common Road in the vicinity of the site is a public transport route. Everyday activities can be undertaken on the site, where there is the need to travel, there is the opportunity to do so by sustainable means.
Q2: Supporting the Economy
As with the provision of housing, it is important that the Joint Core Strategy provides for a choice of employment sites in terms of their size, quality and location. In this context consideration should be given to the allocation of some employment land in the Green Belt to meet a self-evident shortage of premium industrial sites.
Q4: Protecting the Environment
Notwithstanding the fact that developers provide for commuted sums when delivering new parks, sports pitches etc. as part of development, this inevitably places a burden on Local Authorities in terms of the continuous maintenance of such facilities. As part of new development, consideration should also be given to maximising the use of existing parks, sports pitches, nature areas and walking and cycling routes. New development can facilitate the enhancement of existing facilities through financial contributions and improvement of facilities. Consequently the enhanced use of existing facilities should also be a priority.
Q7: Providing Community Facilities to Support Growth
Please see response in relation to Q4: Protecting the Environment.
Q9: Working with Our Neighbours
The situation in terms of housing provision for Birmingham and the shortfall of provision that was identified by Birmingham's Local Plan Inspector, means that it is inevitable that all adjoining Authorities, including the Black Country Authorities, will need to accommodate growth from Birmingham to meet its housing needs. The situation in Birmingham provides a clear indication that the pressure for housing in the Black Country is upwards. It therefore follows that there is a need to ensure that there is an adequate supply of housing land in the Black Country in terms of its style, location and quality to meet the housing requirements of Birmingham. This further reinforces the need for land to be released from the Green Belt in the Black Country to meet the development requirements of not only its area but that of Birmingham as well.
Q10: Regeneration Across the Black Country
The delivery of new homes and jobs in the Black Country could be expedited by an immediate recognition of the fact that there are insufficient sites available for housing of sufficient quality to provide for aspirational housing. Consideration should be given to the immediate release of land from the Green Belt to meet the requirement for aspirational housing (see Q1 above). The delivery of the aspirational housing on Green Belt land will deliver employment not only through the construction process but by ensuring that entrepreneurs and the captains of industry are retained within the Black Country thus maintaining existing employment and attracting new investment. Such a site for aspirational housing could include land adjacent to 1 Barr Common Road, Aldridge as edged red on drawing 4833.99.

See the attached Issues and Options Report Consultation - Land at Tipton Road and Setton Drive, Woodsetton/Sedgley.