Stage 1: Strategic Options 1A and 1B - the role of the Growth Network

Black Country Core Strategy Issues and Options consultation

Summary

We write to confirm BOC's representation to the Black Country Core Strategy Issues and Options consultation in respect of their operational facility at Knowles Road, Wolverhampton WV1 2ET.

BOC is a member of The Linde Group, a world leading gases and engineering company with 50,000 employees working in around 100 countries worldwide. It produces industrial gases for the healthcare, industrial, construction and hospitality industries in the form of cylinder gas, special products (refrigerants, industrial chemicals/gases, and liquid helium for medical scanners for example) and the bulk delivery of liquefied industrial gases by tanker. It also provides on-site gas generation for certain large scale facilities.

Whilst we note that the Core Strategy is at an early stage and that site specific proposals are not yet fully formulated, it is important that the plan is underpinned by a sound evidence base.

In this regard we note that the broad thrust of the questions are focussed on matters of principle, for example, whether new housing should be provided on either Green Belt land or existing employment sites.

BOC are concerned to ensure that the emerging housing strategy set out in the Black Country Core Strategy fully recognises the constraints of existing commercial and industrial business, particularly their operational facility at Knowles Road, Wolverhampton WV1 2ET in respect of potential noise impacts on incoming residents.



Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details.

With regards to the potential to locate housing on existing employment land, BOC submit that suitable sites must be carefully selected, with the evidence base justifying their selection ensuring that matters of potential noise impacts from existing commercial and industrial premises are fully taken into account.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account when considering sites to allocate for housing.


Site specific considerations/representations

Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No
Question 11a - Do you support Strategic Option 1A? Yes/No. If yes, please explain why. If no, do you support Option 1B? Yes/No. If yes, please explain why.
If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
Question 11b - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No

BOC are concerned that Strategic Option 1B - Restructure the Growth Network with more occupied employment land being redeveloped for housing in the Regeneration Corridors could result in the inappropriate allocation of employment land for residential development. BOC are concerned to ensure any decision to reallocate employment land for housing fully recognises the constraints of existing commercial and industrial business, particularly their operational facility at Knowles Road, Wolverhampton WV1 2ET in respect of the potential for unacceptable noise impacts on incoming residents.


In particular, the Economic Development Needs Assessment (EDNA) reviews a number of employment sites in the plan area, including Site Ref.186 Lower Walsall Street (MU1), which is categorised in the EDNA as a "Housing Consideration". This site (MU1) is situated immediately to the north of the BOC site and is allocated in the Bilston Corridor Area Action Plan (AAP) for "mixed uses". It is described in the AAP as an "existing employment area of poor quality, where comprehensive redevelopment for housing is not likely to be deliverable, but where a mix of compatible uses could be appropriate, if well-designed".

BOC consider that housing and other similar mixed uses may not be appropriate within at least a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET and object to any residential and mixed use allocations within this area.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account.

In conclusion, any policy allocations for such uses in close proximity to BOC's facility would need to be based on a sound evidence base including sufficient noise surveys that confirm existing noise levels are appropriate (particularly at night), and the surveys should be at a time and date agreed in advance with BOC in order to ensure that they are representative of BOC's full night time operations.

In the absence of such evidence, BOC object to any residential or mixed use allocations within a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET.


Question 49a - Policy DEL2 Managing the balance between employment land and housing

In terms of Issues and Options question 49(a), BOC are strongly supportive of the retention of Policy DEL2 Managing the Balance between Employment Land and Housing which states that before considering the release of employment land outside areas identified for housing growth, the Council will ensure:

* Satisfactory arrangements for the relocation of existing occupiers to safeguard the existing employment base
* That the development does not adversely effect the operation of existing or proposed employment uses
* That the site is no longer viable and required for employment use.

BOC strongly support the retention of Policy DEL2 as it is essential to ensuring that key existing businesses such as the BOC facility at Knowles Road, Wolverhampton WV1 2ET , which operate on a 24 hour basis, are protected in the longer term. BOC support this policy and its retention irrespective of overarching site allocations because it is able to consider more fine-grain site specific matters than a wider allocation.

In this regard, BOC are particularly concerned that housing may not be appropriate within at least a 500 metre radius of their operational facility at Knowles Road, Wolverhampton WV1 2ET and object to any residential allocations within this area. Any housing proposals within this area would need to be based on sufficient noise surveys confirming that existing noise levels are appropriate (particularly at night) and policy DEL2 can provide that safeguard through criterion 2.

The BOC operations at Knowles Road operate on a 24 hour basis and can generate significant levels of noise during the night time period, and these operations have the potential to impact upon the amenity of incoming residents. If noise constraints are not adequately taken into account through the local plan process and inappropriately proximate residential development ultimately comes forward, this could place extra burdens and constraints on BOC's business causing it to modify its operations and impinge on its productivity and long term viability. This would be contrary to the guidance set out in the NPPF and NPPG, as follows.

NPPF para 123 (our emphasis) states that:

'Planning policies and decisions should aim to:
* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established;

The NPPG Paragraph: 006 Reference ID: 30-006-20141224 (our emphasis) states that:

'The potential effect of a new residential development being located close to an existing business that gives rise to noise should be carefully considered. This is because existing noise levels from the business even if intermittent (for example, a live music venue) may be regarded as unacceptable by the new residents and subject to enforcement action. To help avoid such instances, appropriate mitigation should be considered, including optimising the sound insulation provided by the new development's building envelope. In the case of an established business, the policy set out in the third bullet of paragraph 123 of the Framework should be followed'.

The subsequent NPPG section 'How can the adverse effects of noise be mitigated?' (our emphasis) states:

'For noise sensitive developments mitigation measures can include avoiding noisy locations; designing the development to reduce the impact of noise from the local environment; including noise barriers; and, optimising the sound insulation provided by the building envelope. Care should be taken when considering mitigation to ensure the envisaged measures do not make for an unsatisfactory development (see the guidance on design for more information).

BOC therefore request that the Emerging Core Strategy takes these considerations into full account.

Where noise surveys are to be undertaken, BOC request that they are informed in advance of the proposed survey times to ensure that the results are fully reflective of BOCs regular operations. BOC reserve the right to comment on the adequacy and reliability of such surveys once they have been submitted.

In addition the costs of relocating a BOC operational facility which has specialist purpose built equipment are such that relocation is unlikely to be possible and the policy should recognise that such facilities cannot easily relocate and will therefore need to receive adequate in situ protection.


Review of Existing Core Strategy Policies and Proposals
Policy EMP2- Strategic High Quality Employment Land and Policy EMP3 - Local Quality Employment Land (Questions 51-53)

Question 51 - Do you think that the criteria used to define Strategic High Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?
Question 52 - Do you think that the criteria used to define Local Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?
Question 53 - Do you think that Strategic High Quality Employment Areas should continue to be protected for manufacturing and logistics uses, with the other uses set out in Policy EMP3 discouraged? Yes/no; If not, what alternative approach do you recommend?

The BOC site is currently within a designated Local Quality Employment Area defined in Policy EMP3 as "characterised by a critical mass of industrial, warehousing and service activity in fit for purpose accommodation with good access to local markets and employees".

Policy EMP 3 states:

"These areas will provide for the needs of locally based investment and will be safeguarded for the following uses:
* Industry and warehousing
* Motor trade
* Haulage and transfer depot
* Trade wholesale retailing and builders merchants
* Scrap metal, timber, construction premises and yards
* Waste collection, transfer and recycling uses".


BOC is a member of The Linde Group, a world leading gases and engineering company with 50,000 employees working in around 100 countries worldwide. It produces industrial gases for the healthcare, industrial, construction and hospitality industries in the form of cylinder gas, special products (refrigerants, industrial chemicals/gases, and liquid helium for medical scanners for example) and the bulk delivery of liquefied industrial gases by tanker. It also provides on-site gas generation for certain large scale facilities.

BOC are fully supportive of the main thrust of policies EMP2 and EMP3 in that they seek to protect employment land. Whilst the BOC site at Knowles Road, Wolverhampton WV1 2ET has an allocation under EMP3, they contend that their operations are within a critical sector of the economy and are worthy of a higher level of protection.

In this regard they could be considered as falling within the 'high technology based sector' and therefore allocation under policy EMP2-Strategic High Quality Employment Land.

Any review of EMP2 and EMP3 should recognise the strategic nature of the BOC site and the important role it performs, and provide it with adequate protection..

Dear Helen

BLACK COUNTRY CORE STRATEGY ISSUES & OPTIONS CONSULTATION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Yours sincerely

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

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

Note: questions numbers are those in the full strategy document.
Question 2 Evidence
Housing
The Housing studies do not seem to adequately examine migration flows. In considering options for addressing any shortfall in housing supply, it would be helpful to have information on flows of migrants between the study area, Birmingham and other parts of the former west Midlands region. The Black Country receives many migrants from Birmingham but exports people to other areas including Telford and Shropshire. Thus there are important links to areas outside of the HMA. The EDNA contains useful analysis of commuting flows. indicating the wider area to which the Black Country relates.
The analysis should examine the age composition of different migration flows. Previous studies indicated that people moving from the Black Country into nearby areas tended to have higher proportions of families with children and be from higher paid backgrounds. Understanding of these flows will help to plan for house types and supporting facilities and transport that will be required if more development is needed in the Green Belt and beyond.
Much of the projected housing growth stems from net international migration; this is reflected directly in the ONS projections for the Black Country and also indirectly in the projected migration flows from Birmingham. This is a topic of great uncertainty. Flows since 2014 have been higher than in the ONS projections, but post-Brexit policies may reduce flows greatly. Given the scale of growth envisaged, some assessment of the range of uncertainty is required by sound planning.
Transport
The collection of evidence on traffic impacts should not just focus on peak flows into the major centres, given the dispersed pattern of employment across the Black Country and the increase in traffic associated with the school run. Traffic congestion is apparent through many parts of the Black Country and for longer periods of the day than in the past. Delays and pollution as key junctions should be monitored.
If new peripheral housing is proposed then the impacts on the whole network should be considered, not just in the vicinity of the proposed developments, as residents in existing built-up areas already
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suffer the effects of increasing congestion. Many residents of new developments will travel back into the Black Country and Birmingham for work and other purposes. For example, do you have any data on the effects of the development on the former Baggeridge site on peak flows on the already congested routes between Gospel End, Sedgley and into the Black Country?
Health
The effects of traffic and congestion and proximity to existing polluting industries health should also be examined.
Question 3: Housing Need
At this stage I would not wish to offer an opinion on methodology in relation to Government guidance. My view is that Government's requirements for methodology are flawed; it remains to be seen if the new standard method improves the situation.
The scale of housing need is very large but it is wise to have a strategy for the projected growth as this may be required in the longer term even if the projections are too high. However, I have two reservations about planning for this level of growth under current planning rules, which are naive, deterministic and inflexible.
Firstly, my experience as a user and producer of demographic, housing and employment information has shown the severe limitations of knowledge and the difficulties of forecasting the future with any precision or certainty. As to economic forecasts, it seems that even at national level, these amount to little more than guesswork even in the short-term. Forecasts can easily be revised, and often have been, and even information about past trends is recast (e.g. after the 2011 Census) . Long-term development decisions are not that easily undone, and the real impacts can be very large and enduring. The estimation of housing 'need' and the adoption of policies to meet that need should ideally be based on weighing evidence, taking account of its quality and reliability, against real impacts on the ground, together with an understanding of risks.
Secondly, a sensible planning system would provide long-term direction with flexibility and phasing to reflect changes in demographic trends and economic conditions. However, current planning rules are deterministic and inflexible. My concern with policies to meet the large projected housing growth is whether and how the release of a vast amount of greenfield land can be controlled without jeopardising the regeneration of the core Black Country. The focus on new development can lead to a failure to consider the implications for the economic, social and environmental interests and needs of most Black Country residents. Once Green Belt land is made available, it will be developed first unless strong phasing policies can be put in place.
Question 4. Employment Land Requirements
It is very important to allow scope for major employment developments. The i54 site is a good example of the benefits of long-term planning. That said, the amount of land proposed seems large in relation to what is likely to be achieved. My concern is that much land originally identified for industry or offices in the past has gone for some form of retail or more recently distribution: valuable land close to Motorway junctions has gone for retail or logistics. These uses are important but generate lots of traffic on strategic routes and provide jobs that are either low-paid or don't
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contribute much to the local economy. This may simply happen again if too much land is identified for industrial or office use.
I am also concerned about the seeming reluctance to tackle the undesirable legacy of the Black Country's long mining and industrial past (paragraph 3.9). This area's long and complex industrial history has left a juxtaposition of dirty, low value uses close to housing. Unless this is addressed, the area will not attract higher income residents, whose spending is vital to improving the local economy and its shopping and cultural facilities. Queen Victoria is supposed to have drawn the curtains as her train travelled between Brum and Wolverhampton; the view today is not so bad but the image that is presented to the millions who traverse the motorway, rail and canal routes through our area is far from appealing.
Other businesses thrive but are now badly located, making them less efficient and often generating traffic and environmental problems for local residents. I live near an oil-mixing plant that brings in tankers from across Europe. Unfortunately it is close to housing, quite noisy at night and a source of traffic congestion as the access is poor. It is also in a key canal-side location which could be an environmental and economic asset, being close to the major museums of the Black Country.
Given the amount of land that is being set aside for employment, it is important that a proportion is set aside for businesses that should relocate. This will include areas for 'dirty' uses.
Key Issue 5: Green Belt Review
If the required amount of development cannot be accommodated within the existing built up area, then some Green Belt Land will be needed. However, such a review should be undertaken as part of a wider investigation of options as peripheral development may not be the most desirable in terms of environment, sustainability and the well-being of the population.
The investigation should be wider in terms of
 geography - involving councils in Shropshire, Staffordshire and Worcestershire, as well as those in the Grater Birmingham HMA
 history - being informed by lessons from the past about new and expanded towns and peripheral developments on the edge of the conurbation.
 full impacts - not only on the immediate localities but also on the wider conurbation, for example through increased traffic flows back into employment and shopping areas.
 the proper role and value of the Green Belt - We live in the heart of the Black Country, but Green Belt allows us access to open countryside within about two miles of our house. It provides a breathing space, somewhere to walk and a visual relief from the congested and busy metropolitan area. Green Belt development would not affect my immediate living environment but it would make living where I am less desirable.
Question 6 Key Issues
No
Transport (or keeping the Black Country Connected).
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This fails to properly acknowledge the widespread problems of existing traffic congestion within the Black Country and on the national motorway routes. HS2 offer opportunities but also threats to the Black Country's rail connectivity. Congestion, coupled with the still poor environment in many areas is a barrier to building a more prosperous and liveable Black Country.
The plan needs to be informed by the Transport Strategy, but the large amounts of development will require the Transport Strategy to change. The scale of development envisaged will have major impacts on traffic flows across the whole area. It should not be assumed that the proposals in the Transport Strategy are all that will be required. The horse pulls the cart but the driver should be in charge of both.
Economy. The same point as for transport. The relationship with the economic strategy should be two-way. Planning is about balancing competing priorities. The economy, and aspirational economic strategies, can change rapidly - will the Midlands Engine still be working in 5 years time? The impacts of development and changes in the environment are more enduring.
Question7: Vision and principles
Agree that these values remain appropriate.
Question8: Spatial Objectives
1. Major centres. Trends in retailing and services have changed rapidly with the increased use of internet and direct delivery of goods and the decline in local banking and other public and commercial premise-based services. These add to the long-term challenges that have afflicted centres over previous decades. It is necessary to reappraise their role perhaps looking to increasing residential and leisure uses.
2. Employment is key but the emphasis on logistics may need to be reviewed and increased attention paid to innovative manufacturing. HGV drivers report and call at West Midlands' depots but they may live far away; manufacturing can provide well-paid jobs for local people.
8. Should include educational facilities at all levels. Sustain role of the universities and allow for expansion of schools to meet the growing child population ( a 26,000 increase 2014-2039 according to ONS).
9 and 10. Significant stocks of re-usable minerals and construction material will continue to become available through redevelopment of older sites. The recovery of this and conversion into new products or energy should take place within the Black Country, subject to environmental and health standards.
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Question 11
Neither, but 1B preferable. The strategies should commit to exploring sustainable options beyond the Green Belt as part of a major strategic review across a broader geography.
Release of existing employment sites: improve local amenity for nearby residents; do they suffer poor location and access in relation to nature and amount of vehicle movements; vacant for a long period; appearance.
Question 12A.
Some 'rounding off' may be acceptable but not supported as a major contributor to needs. This is a soft option, which is easiest to deliver for authorities and builders, but very unsatisfactory. Developers will build these sites first, unless strict phasing is imposed, and this will undermine regeneration and the more sustainable options.
Internal wedges can be very valuable in providing access to open space for a large number of residents. If land is released in this way, developments must be required to provide a substantial amount of accessible open space and footpaths to maintain and improve local amenity.
The cumulative wider impact on services and traffic locally and across a wider area would be large but would be difficult to relate to any specific development. This would create problems in securing developer contributions.
In reviewing the peripheral boundaries it is vital to consider the visual impact on the perception of sprawl and separation between settlements. The mere physical distance between built-up areas is not the sole criterion for assessing boundaries. In some cases it may be possible to allow expansion if new development is shielded by woodland etc. In other cases a proposed development might leave a physical gap, but through placement (e.g. on a ridge) may erode the perception of separation.
Question 13a
If Green Belt land is needed then this option could satisfy that need in part. Strategic infrastructure (transport) should be specified as should the employment content. Ideally should make provision for affordable housing, most realistically through shared ownership. Peripheral development in the Green Belt raises the same issues as mentioned in Question 15c and these should be assessed when considering such development.
This option should be assessed in parallel with consideration of sustainable developments outside the Black Country Green Belt - see question 15.
Question 14 The Black Country has large areas of low density housing developed during the period 1920-1950s and includes Social Housing, ex- Council housing bought through Right-to-Buy and privately built estates. Much of the housing is sound, but will deteriorate without maintenance and investment. Many owners struggle to maintain their properties and their often large gardens.
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Ultimately this issue will need to be addressed, possibly through redevelopment; the diversity of tenures will be a challenge. Selective redevelopment would offer the opportunity to improve housing conditions, save energy and increase densities. It may also allow the development of 'aspirational' housing for higher income householders. The viability and contribution of such redevelopment should be explored before large areas of greenfield land are developed.
Questions 15 The scope for 'exporting' growth to other sustainable locations beyond the Green Belt should be explored in parallel with the Green Belt Review to ensure that the most sustainable options are identified. However, the search should extend beyond the Greater Birmingham HMA as the Black Country relates strongly to areas in Staffs, Shropshire and Worcestershire.
In relation to question 15c, many rural areas face challenges in labour supply as their population ages; new housing can help and also take up spare capacity in schools etc. This may reduce the impacts on commuting of spreading development further. However, it may be necessary to also divert some employment development also to these areas, to avoid generating additional in-commuting.
A new settlement should be considered as part of this approach. To be viable and provide a good range of facilities it should aim for an eventual size roughly the same as Codsall, Penkridge or Wombourne. A possible location would be in a triangle north of the M54 and west of the M6. This is close to the Jaguar development and could be linked to regeneration and transport improvements, with Park and Ride, along the A449 into Wolverhampton
Questions 16-20 The strategy should provide a mix of locations to meet a diverse range of needs, so the preferred option should be a mix of the options.
Question 24 At a personal level we became aware of the pressure on local school places when we investigated moving our grandson and his mother into the Black Country; no primary places were available within reasonable travelling distance. A new local school has recently been built on a sports ground; this will create traffic problems on an already congested route. It is important that the plan identifies the amount of land needed for new facilities, such as schools, and specifies requirements in terms of access and parking. It may be easier to provide facilities in association with larger new housing developments, in which case housing mix should be designed for families with children.
Question 25 In considering peripheral developments, it will be important to consider any deficiencies in social etc provision within existing adjoining areas. In this way, new development can be 'sold' to existing residents affected by new developments.
Questions 26 and 27.
New developments offer the chance for micro-generation and efficiency in energy use. Guidance should be prepared to ensure that developments are designed with energy efficiency in mind.
Question 27 Paragraph 5.12 is incorrect in implying the current transport situation is satisfactory. The motorways are struggling, and any disruption, such as the current strengthening of the M5 viaducts, creates major problems for long-distance and local travellers. Traffic on local roads has grown greatly in the 10 years since I have lived here. The peak now extends from about 3.30pm to
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nearing 7pm. Only yesterday i had to travel from Tipton to Sedgely at 1615; a 2.5 mile journey too 25 minutes! Local roads can be near to gridlock at peak times.
Industrial traffic mingles with local traffic to the detriment of both. There are clear benefits to be had by providing sites closer to main roads, so that firms to can relocate while staying within the area.
The Birmingham-Wolverhampton railway runs at capacity and offers little opportunity to increase the frequency of services, particularly serving local stations.
Walking and cycling need to be encouraged but this be requires safe and convenient routes? I can cycle to the station in 4 minutes and walk in 10, but to do so I have to crossing several roads, only one of which is safe to cross.
The metro extension to Brierley Hill will be welcome but the area needs to follow the lead set by Greater Manchester and develop a proper network: for example extending south to Stourbridge Junction.
Question 30.
A thorny question! One approach might be to use affordability contributions from Green Belt sites to fund affordable housing in the built-up area. This might prove attractive to developers, but might also exacerbate social polarisation. Evidence on wider traffic impacts of peripheral developments might be used as a leaver for contributions to improvements on key transport corridors. In reality only a restrictive policy on greenfield development will secure urban regeneration.
Question 32.
Support the idea of HIAs
Question 33
Policies to improve the environment in existing built-up areas should take account of health benefits. Policies to address lifestyle-related problems should be addressed through policies that make walking and cycling more attractive. More restrictive policies on fast-food outlets are needed, although this is a bit late given the proliferation of existing outlets.
Question 34a.
Yes. The impact of new developments on existing residents should also be considered as part of the strategic review. Often the impacts of a new development are felt away from the site - most obviously through increased traffic on already congested roads. It would be useful also to have health impact assessments for those existing areas where there are likely environmental factors, pollution, noise, air quality issues.
Question 38
If Green Belt developments cannot meet existing accessibility requirements can they be regarded as sustainable? Peripheral development will generate more car travel and longer distances. If a
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development cannot reach the standards set, would it be possible to require offset contributions to improve accessibility and public transport elsewhere (e.g. in adjoining built-up areas)?
Question 47
Yes. If it is necessary to develop Green Belt for housing then this policy should aim to recoup some of the higher development values realised for enhanced contribution to services. It important that new developments set aside sufficient land for provision of schools and the like. Greenfield sites are likely to appeal to those setting up free schools. Unfortunately this is socially divisive, but it may necessary to ensure that enough school places are provided.
Question 49
The policy on release of existing employment land should protect existing businesses and viable enterprises, but should also identify major sites that could be redeveloped for housing or other uses. It should also include criteria for assessing windfall redevelopments that cover the amenity of local residents and any existing traffic and parking problems. An adequate selection of sites suitable for relocating businesses should be identified.
Question 55
Policy should be retained/enhanced.
Question 56
It is not clear whether the list includes the Dudley Canal Portal. It should as there is a for improvements to the highway, public transport and pedestrian access to and from the site.
Consideration should be given to including the former Chance's glassworks given its key position alongside the canal, motorway and railway routes through the Black Country, and the recent formation of a Trust aiming to secure restoration.
It is important that all developments close to and adjoining the canals should enhance this important network of routes and attractions, improving access where appropriate. Opportunities to provide facilities for boat users should be encouraged as should the provision of shops, cafes and other services for boat users and those visiting the canals.
Questions 58-61 and 82
The relevance of policies for many of the district and local centres is open to question. Many smaller centres are dominated by fast-food outlets, It is also time to reassess the boundaries of some.
There may be a need to review policy criteria that apply to the new breed of medium size supermarkets (e.g. ADLI, LIDL) which are springing up in other locations (e.g. the Priory in Dudley). Not sure of the size of these in relation to thresholds for out-of-centre developments (covered by CEN6 and 7) referred to in paragraphs 6.1.11-13.
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Questions 69-73
There is a need to consider some conversion/redevelopment for housing within centres, even if this reduces retail floorspace. New housing can help to support, and lead to development, of a wider range of convenience shops - as in Birmingham centre.
Question 72
As above. Vacancy rates in all centres, large and small have remained high for many years. It is now time to accept reality. It must be remembered that in some older centres, what were once houses were turned into shops. It may be time to reverse the process.
Question 79 Need a restrictive policy on fast-food outlets in residential areas.
Question 86 Is there a policy covering the loss of public houses to other uses?
Question 88. Transport priorities will need to be reassessed in conjunction with the development of the strategic locations for housing and employment growth. As a resident, my view is that the area has major transport problems which can only be met by a much more ambitious programme for modal shift plus selective road improvements.
Connectivity to HS2 will be a major issue presenting opportunities and threats. HS1 has had mixed impacts in different parts of Kent, massively improving access for towns that are on the HS network, while adversely affecting the cost and quality of train services for many other areas.
Question 92
Support the concept of a coherent walking and cycling strategy, but reserve judgment on content of existing strategy. The canal network provides the most strategic long-distance routes, but unfortunately much of it is poor quality. Suggest you visit Sheffield/Rotherham to look at the River Don cycleway, or perhaps Leicester for cycle routes along former railways.
It is important that major new developments contain adequate facilities for cyclists and pedestrians, and where possible provide through routes that can create a longer route. Too many recent developments (e.g. Castlegate in Dudley) are bike/pedestrian unfriendly). In other cases opportunities to create new routes have been lost: e.g. the swimming pool and adjoining hew housing estates on Alexandra Road/Church Lane Tipton.

Comments on Behalf of Persimmon Homes West Midlands
Planning Prospects Ltd - August 2017
Chapter / Page / Question / Paragraph: General Comment
Agree / Disagree: N/A
Comments:
Persimmon Homes West Midlands ("Persimmon") have instructed Planning Prospects Ltd to prepare and submit representations to the Issues and Options Consultation for the Review of the Black Country Core Strategy (BCCS). Persimmon have land ownership and development interests across the BCCS area, and have a successful track record in bringing forward new homes in this part of the West Midlands. These representations are intended to support and promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021. Persimmon expect to make a contribution at each of these stages, and as plan preparation moves forward it is anticipated that the comments made will become more detailed, technical and specific in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review is still to be set, detailed policy wording has not been formulated, and certain key elements of the evidence base have yet to be finalised the comments made on behalf of Persimmon are necessarily more strategic and general in their nature. In the main they seek to influence the direction of travel of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is not commented on in these representations this should not be interpreted as meaning that Persimmon necessarily agree (or indeed disagree) with it. Rather, these representations should be understood as a statement of principles, which will be fleshed out where appropriate in subsequent stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual chapters or questions around specific topics. The representations should be read as a whole to obtain a sense of the trajectory Persimmon consider the Review should follow. The short questionnaire survey (ten questions) has also been completed on behalf of Persimmon, and submitted separately.
However, a note of caution should be exercised at the outset. The Issues and Options Report (for example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but it must be remembered that over the relevant periods it has failed to deliver the overall targets in terms of new homes, employment land, offices and retail (Issues and Options Report Appendix C). This is not intended as an overt criticism, particularly in light of the challenging economic circumstances within which it has operated. However, it does serve to emphasise quite strongly the importance of ensuring the strategy and policy framework arrived at through the Review is
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formulated with great care so as to maximise the opportunity and likelihood for development requirements across all sectors in the Black Country to be met.
Chapter / Page / Question / Paragraph: Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
Agree / Disagree: Disagree
Comments:
It is considered that a "partial" review of the BCCS should be followed with a considerable degree of caution, if at all. The existing Core Strategy was focused on urban regeneration and accommodating development needs entirely within the urban area, whereas the Review will necessarily adopt a balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core Strategy was adopted in very different circumstances following the financial crisis at the end of the last decade. It catered for different needs, with no requirement to accommodate overspill growth from Birmingham, no certainty as to how employment land requirements would evolve in subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a "Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations, is considered outdated. It has proven challenging to meet development targets set by the existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and "stretched". The approach cannot be one that seeks to shoehorn the future strategy for the Black Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new strategy is required.
Chapter / Page / Question / Paragraph: Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details.
Agree / Disagree: Disagree
Comments:
The evidence set out in Table 1 is likely to be sufficient to generally support the various stages of the Review, but much depends upon the content and scope of the evidence to be prepared and until certain key documents become available it is not possible to say with certainty that they will indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green Belt Review, the second stage Economic Development Needs Assessment (EDNA) are likely to be fundamental in understanding needs and opportunities, and will be central to the nature of comments to be made by Persimmon in subsequent consultations.
To ensure an effective approach the scope of the evidence base documents should be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. It is considered that the scoping of the Green Belt Review
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particularly should be informed by a consultation process, to ensure that the exercise is ultimately completed in the most effective manner.
Chapter / Page / Question / Paragraph: Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
Agree / Disagree: Disagree
Comments:
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue fully, but a considerable degree of caution should be applied to the suggested approach which would see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the City is unprecedented, and needs to be addressed with certainty and quickly; it is essential that this housing need is met. It is not clear how the figure of 3,000 homes has been alighted on and is currently described as being "tested", but might be compared with the 3,790 homes which North Warwickshire Borough Council are already seeking to plan for as their contribution to meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full contribution in this regard. They are uniquely placed and well related to Birmingham such to make a significantly more meaningful contribution to support delivery of unmet need from Birmingham. The "testing" of some 3000 dwellings does not appear to be a fair proportion of the overall unmet need, given the scale and relationship of the Black Country to Birmingham.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt with quickly, fairly, comprehensively and transparently. The approach is an issue for now, and must be tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing some surplus employment land for housing, with a significant requirement to release Green Belt land, is supported. This represents a clear shift away from the existing BCCS approach with its almost exclusive urban focus, but one that is necessary if development needs are to be met on viable and deliverable sites.
It is essential that the Review provides for an appropriate level of housing and meets the full housing needs of the sub region. Government policy is advocating a step change in the delivery of new housing and the BCCS Review needs that step change in order to address past under delivery. The National Planning Policy Framework states in respect of housing that "The Government's key housing objective is to increase significantly the delivery of new homes. Everyone should have the opportunity to live in high quality, well designed homes, which they can afford, in a community where they want to live. This means:
* increasing the supply of housing
* delivering a wide choice of high quality homes that people want and need
* widening opportunities for home ownership; and
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* creating sustainable, inclusive and mixed communities, including through the regeneration and renewal of areas of poor housing".
It goes on to state that "to enable this, the planning system should aim to deliver a sufficient quantity, quality and range of housing".
There are significant negative impacts which would result from adopting low levels of housing growth and these must be recognised, not least the significant impact on housing affordability and increased house prices by a lack of supply.
A low level of housing growth would not meet housing needs, would not support the economic growth aspirations and could lead to unsustainable patterns of travel with people having to travel further distances between home and work.
New housing development supports and enhances new infrastructure and is a way of providing improvements to local social and community infrastructure which would otherwise be difficult to deliver through public sector means. Government policy seeks to ensure that those communities accommodating new development see directly the benefits in improved infrastructure in their communities.
In terms of the level of growth, it is important to fully consider a number of factors which influence the level of growth to be adopted and these are set out below. It is our submission that they all point to the need for some significant additional housing growth;
Population and Household Projections - A combination of natural population growth, net in migration into the HMA in line with historic trends, together with a general trend towards reduced household sizes and therefore an increase in the number of households suggests that a significant level of growth needs to be planned for. Levels of housing need to positively reflect and balance with aspirations for economic growth and grasp opportunities to meet housing needs for both open market housing and affordable housing. It is essential that the latest and most up to date projections are used to properly understand need.
Affordability - Indications of housing affordability suggest the need for higher levels of housing growth.
Economic Needs - There is a strong and essential need to support economic growth. The delivery of housing supports a vibrant economy. New housebuilding will provide for increased construction activity with both direct and indirect jobs and economic wealth creation. The availability of new quality housing supports business and wider economic activity, promoting the Black Country for inward investment. Housing and economic needs must be aligned to support job targets.
Infrastructure Requirements -The delivery of new housing will support the delivery of required infrastructure through Planning Obligations and CIL. These infrastructure projects are unlikely to be delivered through other public sector initiatives or viably provided through other land uses.
Availability of land - Whilst land is a finite resource and there will be pressure to protect Green Belt, it is essential that new development opportunities are identified that will be viable, deliverable and of suitability to the market. Whilst urban brownfield sites provide an opportunity for some growth, there needs to be some caution in over reliance upon urban regeneration if the under delivery of the past is to be avoided. Reliance is already made on SHLAA opportunities and windfall in order to reduce net need and this again needs some caution given the challenges to delivery of urban
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brownfield sites within the Black Country. The Review should more positively plan for a greater reliance upon more market focused, deliverable opportunities which identifiable and supported by evidence of delivery and viability. Land is available including sustainable Green Belt land to meet fully all needs including needs un-met needs from elsewhere in the HMA.
Chapter / Page / Question / Paragraph: Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
Agree / Disagree: Disagree
Comments:
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the requirement is appropriate. That said, and as expressed elsewhere in these representations, for the second stage EDNA to be effective it must be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. The Stage 1 report appears to have been informed by a narrow range of consultees, and unless this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly assessed. It is essential that the Review properly grasps opportunities for economic growth and the Black Country benefits from the prosperity of such growth. The Framework requires LPA's to do all they can to support sustainable economic growth and support the needs of business.
Chapter / Page / Question / Paragraph: Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
Agree / Disagree: Disagree
Comments:
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is characterised by an approach which protects the Green Belt and focuses development on Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the "exceptional circumstances" threshold for allowing development in the Green Belt has been met with the development needs identified through the Review. Persimmon support the conclusion that exceptional circumstances are in place now to justify review of the Green Belt. The Review of the Green Belt is in fact well overdue, having not taken place since the 1970.'s and particularly given the failings in the delivery of housing and employment growth by the regeneration focus of the strategy of the former BCCS. It is appropriate that this should take place as part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other neighbouring authorities. However in doing so, it is important that the review is comprehensive and to the fine detail required to properly consider the potential Green Belt merits of individual sites of all scales and sizes. It is essential that being undertaken as part of the Core Strategy, it doesn't merely focus on large scale releases or strategic areas, as a range of Green Belt sites will be require of all sizes if delivery is to be supported throughout the plan period and threat to deliver are avoided.
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That said, it is not possible to comment on whether the proposed approach to the Green Belt Review is appropriate or not until the methodology has been identified. As expressed elsewhere in these representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately completed in the most effective manner.
Chapter / Page / Question / Paragraph: Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
Agree / Disagree: Disagree
Comments:
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into account through the Review, subject to the comments made elsewhere in these representations about dealing fairly, comprehensively and transparently with accommodating the overspill need for homes from Birmingham, and ensuring the Green Belt Review is completed in a comprehensive and most effective manner.
However, as expressed elsewhere in these representations, a further key issue is the need to recognise the shortcomings of the existing BCCS, the extent to which over the relevant periods it has failed to deliver the overall targets in terms of new homes, employment land, offices and retail, and through the Review to ensure the policy framework becomes one which will ensure the development needs of the Black County are met and opportunities for growth are deliverable and viable and of sufficient interest to the market.
Chapter / Page / Question / Paragraph: Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
Agree / Disagree: Disagree
Comments:
The sustainability principles should be extended to include amongst their number the specific recognition that the Black Country authorities must assist as fully as possible with meeting the overspill development requirements of their neighbours (principally Birmingham).
Reference is made to a brownfield first approach and this needs to be taken with some caution and is not consistent with the requirement of national policy. The Framework advises on an approach which "encourages" the effective use of land by reusing land that has been previously developed, but does not set out a sequential approach. Such priority for brownfield sites has played a significant part in the failing in delivery of the previous BCCS. There needs to be some care in merely carrying forward the previous vision and principles of redevelopment as set out in the previous Plan.
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Chapter / Page / Question / Paragraph: Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
Agree / Disagree: Disagree
Comments:
It is clear that the legacy spatial objectives do not remain relevant and need to be thoroughly re-thought in order to present objectives which are relevant to the challenges today in the context especially of significant needs for housing and the failings or the previous regeneration approach. The spatial objectives are ineffectively framed around a strategy focused almost entirely on directing development towards the Regeneration Corridors. It is very clear that the BCCS Review will need to take a material change in direction and allow for the prospect of significant growth in the Green Belt in a range of locations and of different scales, as part of a balanced approach to accommodating growth. This must be recognised through the spatial objectives. It must acknowledge the requirement to accommodate development in the most sustainable manner and in the most appropriate locations including within the Green Belt.
Chapter / Page / Question / Paragraph: Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
Agree / Disagree: Disagree
Comments:
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic Centres are appropriate. However, greater emphasis must be placed on the recognition that this forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere in these representations it is considered that the Regeneration Corridor approach is no longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should deal generally with accommodating growth in an even handed and balanced manner outside the Strategic Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned growth required in the Green Belt.
Chapter / Page / Question / Paragraph: Questions 10, 11a, 11b - In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
If no, do you support Option 1B? Yes/No; If yes, please explain why.
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If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.
Agree / Disagree: Disagree
Comments:
The Regeneration Corridors are a dated and artificial construct, and this approach should be discontinued. They are insensitive to market and occupier needs. The approach should be simplified by removing the corridors and accommodating development through carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping existing employment land where appropriate, and expanding into the Green Belt. This should be coupled with a straightforward criteria based approach to the development of land that is not allocated. This would be an approach focused very much on the provision of land for development, rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban capacity, broadly defined, whilst also recognising that some development needs can only be met in the Green Belt.
There is no need for a sequential approach to first prioritise the role of the Growth Network and Regeneration Corridors which has failed to deliver in the past.
Green Belt sites will be best provided for on a wide range of smaller sites and some care needs to be taken upon reliance upon large scale urban extensions given the lead in time and challenges to their delivery. In order to address past failings in delivery and boost supply particularly in the short term, a wide range of small to medium size sites need to be identified in the Green Belt as a priority.
Separate submissions are being made on behalf of Persimmon to the "call for sites".
Chapter / Page / Question / Paragraph: Questions 12a, 12b, 13a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas.
What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
Agree / Disagree: Disagree
Comments:
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Promoting delivery and market certainty is more likely under Spatial Options H1 and this should be a strong influence in choosing this approach. Persimmon support the view expressed that there is considerable potential for "rounding off" and relatively modest incursions into the Green Belt for small to medium sized housing sites, and the "opportunities" identified in this regard in the table under paragraph 4.29 of the Issues and Options Report should all be recognised. Whilst there is some concern that such small sites may not contribute to infrastructure in significant ways, this is a matter which can be carefully planned for by the LPA's and cumulative contributions can be combined to support infrastructure provision without compromising CIL regulations.
Whilst there may be some opportunity for a very limited number of Sustainable Urban Extensions it must be a strong influence that the contribution such sites make to housing supply is only likely to be realised in the longer term. They are equally not always certain to make larger infrastructure contributions as they too invariable face viability challenges.
Separate submissions are being made on behalf of Persimmon to the "call for sites".
Chapter / Page / Question / Paragraph: Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
Agree / Disagree: Disagree
Comments:
The only circumstances in which any housing growth should be exported elsewhere in the HMA is if there is compelling evidence it cannot be accommodated within the Black Country, and there is a robust and certain framework in place to ensure that the homes will be required. An ongoing and open ended general process of discussion around this issue is unacceptable, as would be any policy in the BCCS Review which relegated it as a problem for another day. It is a problem for now. The export of housing from Birmingham is unprecedented in its scale, and the issue cannot simply continue to be passed down the line. At some point agreement needs to be reached in terms of how need across the HMA is going to be met, and the BCCS Review provides an ideal platform in this regard.
Persimmon do not support any contention at this stage that there is any sound reason why all housing need cannot be accommodated within the Black Country and there is no justification for exporting need to adjoining neighbouring Authorities.
Chapter / Page / Question / Paragraph: Questions 16 - 20
Agree / Disagree: Agree / Disagree
Comments:
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development on, the Green Belt. Large, regular, and unconstrained sites with immediate access to the Strategic Road Network are required to contribute towards meeting the need for employment land, particularly in relation to logistics led requirements. There remains a role for the recycling of
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brownfield sites to contribute towards meeting employment land needs, but this will not meet the requirements of the highly location sensitive large space occupiers that the Black Country should be seeking to attract.
It might be that sites within Sustainable Urban Extensions (Spatial Option E3) can also make some contribution in this regard, but this cannot be relied upon, particularly in the short term, and it is unlikely that SUEs will provide an effective mechanism to accommodate large scale requirements. Exporting growth to neighbouring areas (Spatial Option E4) should only be entertained as a last resort and if there is compelling evidence it cannot be accommodated within the Black Country.
This again speaks to the point made elsewhere in these representations that for the second stage EDNA to be effective it must be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. The Stage 1 report appears to have been informed by a narrow range of consultees, and unless this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly assessed.
Chapter / Page / Question / Paragraph: Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.
Agree / Disagree: Disagree
Comments:
The general approach to review HOU1 is of course appropriate, but comments have already been set out above in respect of concerns about adopting a brownfield first approach. Any housing trajectory needs to reflect and support early delivery with a significant shift away from and reduction in the amount of housing to be built on brownfield sites. Any level of need identified, must be met with realistic assumptions about supply. Undue reliance upon windfall merely circumvents the proper planning of an area and reduces certainty. Discounts should be applied for non delivery of commitments and allocations. Some over provision in supply is essential and can ensure a choice and range of sites and greater market interest. Allowances for large scale demolitions as in the past should be removed. Assumptions which increase the expected density of development should also be avoided. There is no meaningful market interest or appetite for increasing the density of housing in the Black Country and delivery would be better supported by reflecting market needs which are focused on sensible and modest density ranges often associated with suburban family housing.
Chapter / Page / Question / Paragraph: Questions 36, 38 and 40 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period?
Agree / Disagree: Agree / Disagree
Comments:
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The type of approach set out in Policy HOU2 and Table 8 is appropriate in general terms, although greater clarity should be provided to confirm that the standards are general ones, that their practical application is highly location specific, and will be considered on a site by site basis to reflect local circumstances. There should be no requirement to increase the density standards, and again it should be clarified that these (and indeed the accessibility standards) should be regarded as indicative only.
For Green Belt releases, site specific standards should be avoided and density should reflect local circumstances. There should be no separate standards for particular housing types; this would add an unnecessary level of complexity and risk hindering the delivery of such units where they might have been provided as part of schemes otherwise broadly acceptable for their provision.
The SHMA should be used as a general guide to the types of houses to be delivered, but must be applied generally, rather than rigidly, or again this will hinder delivery.
Chapter / Page / Question / Paragraph: Questions 44a and 45 - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
Agree / Disagree: Agree / Disagree
Comments:
The affordable housing requirement is appropriate, but on the clear understanding that the provisions of Policy HOU3 in terms of viability testing remain in place. There should be no increased requirement for Green Belt release sites. It is simplistic to assume these sites will have greater financial viability in circumstances where they are likely to have additional costs associated with utilities and infrastructure provision. A target of 25% subject to viability is appropriate.
Chapter / Page / Question / Paragraph: Questions 95a and 95b - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?
Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.
Agree / Disagree: Disagree
Comments:
Given the particular challenges faced by the Black Country authorities in terms of development viability and attracting investment it is difficult to understand why "Garden City principles" should be pursued. It is of course important to ensure that the best practicable standards of design and environmental infrastructure are achieved, but this can be done within a conventional framework of fairly standard criteria based development management policies, rather than applying an additional, unnecessary and distracting "Garden City" approach.
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Chapter / Page / Question / Paragraph: Questions 103a and 103b - Do you think that Policy ENV7 should be changed to allow increased energy efficiency standards to be accepted in lieu of renewable energy provision for non-domestic buildings? Yes/No; If not, please explain
Do you think that the 10% requirement should be changed? Yes/No; If yes, please specify what percentage would be more appropriate and to what type of site it should apply.
Agree / Disagree: Agree/Disagree
Comments:
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement for renewables applied and viewed more flexibly. This approach should be applied to housing as well as non domestic buildings

Introduction.

I am writing to you on behalf of Hallam Land Management, which has a long and successful reputation in working with local authorities to promote land for both housing, industrial, commercial and mixed-use development throughout the country. Their approach is to take a positive initiative in promoting land through strategic and local plans to ensure that homes and jobs are delivered for the benefit of local communities and for the wider economy.

For some time, Acres Land & Planning Ltd has been promoting a 10.68ha site (SHLAA site 222) at Sandy Lane in Codsall within South Staffordshire District on behalf of 'Hallam Land'. The site, although currently within the Staffordshire Green Belt nevertheless forms a logical extension to a recently approved housing development to the north of the village which was released from the Staffordshire Green Belt as a 'safeguarded site' in the previous South Staffordshire Local Plan.

The Black Country Issues and Options Document represents a first but very important step in the planning of the area within the wider West Midlands Metropolitan sub-region which also has a critical bearing on the surrounding local authorities including South Staffordshire. We therefore warmly support the integrated approach which the Black Country authorities are adopting and specifically the decision (referred to within paragraph 3.12 of the document) to assess the Black Country and South Staffordshire together as a joint housing sub-market.
The Issues and Options.

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?

The challenges facing the West Midlands (including the Black Country) are critical both in terms of the scale and complexity of housing needs and the changes now being experienced in the local economy. These are influenced by the pressures being felt from Birmingham, triggered in part by the potential growth being stimulated by the forthcoming construction of HS2 and other infrastructure projects but also the uncertainties created by the economic and political changes likely to stem from the decision to leave the European Union.

We broadly support the need for a partial review, retaining the basis of the existing Core Strategy - Hallam Land do not wish to prolong the exercise by starting entirely afresh and re-inventing those aspects of the planning strategy which already work effectively - but we do feel the review needs to be sufficiently far-reaching to challenge the current Core Strategy and to test its robustness thoroughly and also to reflect the changes in policy approach since the NPPF was introduced.

Hallam Land very much welcome the acknowledgement within paragraph 1.19 of the Issues and Options Document that not all growth can and will occur within the existing built-up area. We welcome the pragmatic approach which the Black Country authorities are taking towards the over-reliance on re-used brownfield and derelict sites in the area. The Black Country has a legacy of contaminated land including many sites with old mine shafts and other physical and technical challenges. These will not always be suitable for housing development and hence capping and re-use for commercial or recreational land may be the only viable option. Furthermore, as the Issues and Options report emphasises, the welcome growth in the regional economy means that fewer former industrial sites may be now available for housing.

We applaud the decision to review the Green Belt, jointly in the Black Country and in South Staffordshire. Although it is important to protect the concept of the green belt and to adhere to its principles, the Green belt must be able to respond to the inevitable pressures for urban expansion (unless other options can be delivered instead). Against a background where the GB boundaries have not been reviewed since the 1970's and are very tight (see Figure 5), this is both desirable and essential. There can be no sustainable case for imposing rigid Green Belt constraints which would otherwise impede growth in the Black Country which desperately needs it.

We agree that the existing two-tier forward planning approach should be retained. Most Local Plans are now currently emerging as single-tier plans, but this Core Strategy provides a strategic plan for a large part of the Metropolitan area. The individual Metropolitan Boroughs of Dudley, Sandwell, Walsall and Wolverhampton and those Districts surrounding the Black Country - such as South Staffordshire - will then develop the policies, identify the sites and implement the strategy.
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details.

Hallam Land acknowledges the list of strategic challenges and opportunities identified as 'Key Issues' in paragraph 3.1 of the Core Strategy document.

Within the first of these - the evidence base - Table 1 provides an exhaustive list of studies, research and evidence which has either been undertaken or is in progress to assist in the preparation of the Black Country Review. This is impressive, but the most important consideration is that the strategy should be consistent, integrated and holistic. The studies therefore need to be considered as a whole and should be compatible with plans and proposals which are emerging within the surrounding areas, especially in the Birmingham housing market and in Southern Staffordshire.
In that context, notwithstanding the reference to 'Working with neighbours' one document which, in our view, is lacking is a draft Duty to Co-operate Statement which shows the relationships between areas and the extent to which pressures for housing and jobs are being accommodated across the sub region.

In the absence of a wider West Midlands Regional Strategy, which places Birmingham and the Black Country in their broader context, it is really important to ensure that the Black Country is planned as part of a functioning sub-region. This may well emerge from the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study (due to be published later in September 2017) and within the WMCA Land Delivery Action Plan published (a few days ago) in early September 2017 and due to be considered by the WMCA Board.

The second document which is not referred to is the recently published WMCA Land Commission report published by the West Midlands Land Commission in February 2017 on behalf of the West Midlands Combined Authority (WMCA). This report attempts to address the pressures for and against delivery of development in the West Midlands Authorities' areas. The WMCA has yet to formally adopt the report, but it is currently being addressed by the GBSLEP and the WMCA.

The third document which is in the list, the West Midlands Combined Authority Strategic Economic Plan (SEP) - completed in 2016 - clearly needs to inform the review of the Black Country. The SEP is much more ambitious than both the statutory plans and the Strategic Housing Needs Survey (undertaken by PBA in 2015). The prospect of creating some 500,000 new jobs and 215,000 additional homes within the region (as advocated by the SEP) needs somehow to be reconciled with the more modest plans currently being pursued by the West Midlands' local authorities. Clearly unless the respective Metropolitan Councils plan for integrated housing and employment growth, it simply won't happen.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.

The assessment of housing need in the Black Country is extremely complicated, since it is surrounded by local authorities on all sides. The Housing White Paper advocates a standardised approach to housing needs assessment which should narrow the areas for debate in settling OAN (Objectively Assessment Need) figures. This may work where housing markets are relatively self-contained with identifiable economic and housing catchment areas - but this is clearly not the case for the Black Country.

The Black Country housing market tends to operate at two levels - both as a strategic market stretching across the whole West Midlands Metropolitan sub-region with people moving in and out both regionally, nationally and internationally, and also as a complex network of local markets, catering for the many smaller communities which have traditionally constituted the Black Country.

On the demand side, it is not just a case of looking at the consequences of people living longer and families and households breaking down more often, but also a result of stronger in-migration both from elsewhere in this country and abroad which fuels household formation. The Black Country has traditionally become a lower-priced housing market area accommodating households with a wide range of skilled, semi-skilled and unskilled jobs. It therefore tends to act as a 'reception area' for inward international migrants in addition to catering for both intra-regional movement and local demand. The 78,190 does not contain allowances for economic growth or providing additional affordable housing.

Figure 6 adds 3,000 dwellings as a contribution to supply in the wider Greater Birmingham Housing Market Area. This should logically be a demand component but is presented as a one-off contribution to help meet a neighbouring OAN. Whilst pragmatically we understand the way in which these numbers have been devised (as a gesture to help resolve 'Birmingham's needs'), in reality it might be more robust to explore the intra-regional migration patterns to see whether 3,000 is a realistic contribution to the integrated housing market. We are inclined to feel that the Black Country should be absorbing more of the 'Birmingham boom' which is arising in part from the growing attractiveness of Britain's second city. OF course, a West Midlands Regional Plan would have been able to tackle this exercise. Sadly, the Duty to Co-operate mechanism is very blunt instrument in resolving cross-boundary issues.

With that in mind it is difficult to simply 'rubber stamp' the broad assessment outlined in the Issues and Options document. We therefore reserve judgement on the proposed OAN of 78,190 homes (2014-2036) until further work has been undertaken to explore both the sub-regional needs and examine how the Black Country OAN relates to the Districts around it - especially South Staffordshire (and Telford and Wrekin which has historically acted as destination for out-migrants from the Black Country) to determine whether the 78,190 figure is robust.
On the supply side, we acknowledge the broad thrust of the 5 stage assessment within Figure 6, (although it would be logical if the order of the items in the histogram was consistent with the diagram). It's upside down.

A few points are relevant here:-

Firstly, the number of completions (2011-2014) should be a matter of fact, however it may be worthwhile looking at the mixture of dwellings delivered against need to see to what extent they match demand/requirements. Other Districts outside the Black Country may be better placed to provide new family housing,

Secondly, the existing 'supply' registered in the SHLAA may be a helpful guide towards the capacity within the urban area of the Black Country - however it is not clear whether all the SHLAA sites have been tested for availability and constraints and what proportion of those sites are deliverable and at what density. Further work needs to be done on this to clarify the status of 'committed' sites.

Thirdly, paragraph 3.15 states that identified sites and windfall sites have a potential to deliver around 8,335 homes (2026-36) but it is not clear whether there is any overlap between the 'potential' windfalls and the SHLAA sites and/or the scope for increased density housing allocations in town centres.

Fourthly, paragraph 3.16 refers to the scope for the re-use of employment sites of which 300ha (delivering 10,400 homes) may release land over the 10 year period from 2016-2026. However, the document acknowledges that this may reduce as a source of housing land, especially if the West Midlands economy continues to improve. It makes little sense to re-direct employment development onto greenfield land within Green belt (thereby displacing jobs from local communities) if housing is then being steered to sub-optimal contaminated sites within the urban areas which are more expensive to remediate to residential standards.

Fifthly, there is no mention within the assessment of replacement housing to cater for older homes (or sub-standard property) reaching the end of its life. This element is normally built-in to the demand side of the equation, but in the Black Country the decaying housing stock and/or system built housing affected by design and construction problems could further reduce the supply available. (We have not investigated this aspect and more work may need to be done on this).

Finally, the residual figure of 24,670 dwellings which (according to paragraph 3.18) may need to be accommodated within the green belt (in the Black Country or elsewhere) will need to be balanced against other options if the sequential approach towards land allocation within the Housing White Paper is implemented. Against that background, the 'value' of the Black Country Green Belt in meeting the 5 key purposes of green belt will need to be measured against the merits of releasing arguably less sensitive green belt sites in South Staffordshire or indeed negotiating to release non-green belt land in the former New town of Telford, where the infrastructure is already in place and there is a growing industrial base.
Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.

The nature of the economy has changed significantly over the last 10-15 years. Although the Black Country is the traditional home to extractive industries, manufacturing and especially metal-bashing much of this heavy industry has moved to other countries to be replaced by higher value manufacturing and services - including distribution. At the other end of the scale, the economy now encourages smaller-scale initiatives with a sharp rise in small businesses and self-employment.

It is therefore much more difficult to gauge the employment land requirements since the more traditional industrial estate forms only a partial element of employment needs. Employment may also be transient and not necessarily place-based. Recent history has shown that there is a pressing need for readily available large employment sites to meet the one-off inward investment such as JLR which tends to create large numbers of jobs, both in direct and spin-off employment. Similarly, distribution now requires much larger loading bays with high spans which can accommodate the needs of the current market. The West Midlands Strategic Employment Sites Study and the Black Country & South Staffs Sub-Regional High-Quality Employment Land Study will provide an important part of the evidence base.
We therefore support the portfolio approach to the provision of employment sites.

At the more localised level the town and local centres are becoming less attractive to the major retail multiples and more popular with local specialist shops, coffee shops and restaurants and entertainment venues. Disappointingly, despite Birmingham and the Black Country being world famous for the historic canal network, there is no reference at all to the potential of the canals in creating and boosting the local economy. The only reference to canals is within Policy EN4 where a cautionary approach is taken due to the possible ecological implications of restoration. Yet many examples exist within Wolverhampton, Walsall, Dudley and Sandwell where the canals have been at the heart of urban regeneration and others could be in future. There are also opportunity sites elsewhere in Telford where this applies.

The Economic Development Needs Assessment (EDNA) suggests the review should plan for up to 800ha of additional employment land for the Black Country from 2014-2036 which reflects the loss of around 300ha to housing and reflects the economic growth aspirations of the Black Country SEP. This residual figure assumes that a further 90-170ha of employment land is released within South Staffordshire to reflect the needs of the Black Country. Logically this will also have a housing implication within South Staffordshire rather than just within the Black Country despite serving the Black Country's needs. Clearly if this is the basis for the employment target - the same principle must also apply to the housing target. Otherwise we make no detailed comment on the 300ha 'gap' figure which emerges as the employment land requirement within paragraph 3.27 of the document.

Key issue 5 - Protecting and enhancing the environment.

It is self-evident that planning policies should be devised to protect the environment and to avoid damage to Special Protection Areas (SPA's), RAMSAR sites, water quality and other aspects of the natural environment.

We are extremely sceptical however about the outcome of the environmental impact work of the Cannock Chase SAC Partnership. Local authorities involved have sought to impose a levy on house-builders operating within the 15km catchment zone on the assumption that increased 'pressure' will be imposed on Cannock Chase from the building of houses within the area. Having examined this consultancy work in depth previously, we are not convinced that the study undertaken on behalf of Natural England has demonstrated that the 'pressure' on the wildlife necessarily arose from newcomers. Rather it was caused by specific 'user groups' or people acting irresponsibly for example mountain bikers, horse riders, dogs, or people starting fires, some of whom already live locally or are travelling from further afield.

On a more general note, the implication that the use and enjoyment of public open spaces should be discouraged through the imposition of a 'dwelling tax' on housing is counter-intuitive. It conflicts with Local Councils' own tourism strategies (which try to attract people to the Chase) and is contrary to wider public health objectives within planning which promote walking, cycling and taking other forms of exercise. The Cannock Chase SAC Partnership and Natural England therefore need to re-assess their evidence base carefully and review this policy so that it does not impose a burden on builders or indirectly future residents of the Black Country and those people moving to those parts of Districts such as South Staffordshire and Stafford and those places which lie within the 15km catchment of the Chase

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?

We welcome the recognition that the implications of future growth in and around the Black Country will require a systematic review of the Black Country green belt and that this will be done in a consistent way with the other local authorities in the Birmingham and Black Country housing market area. The emerging Greater Birmingham and Black Country HMA Strategic Growth Study, being produced by GL Hearn provides the right context for the Black Country Green Belt review and it is logical (as suggested in paragraph 3.47) that this should also cover the South Staffordshire area which falls into the same general housing market area and maintains strong economic links.

The completion of the Preferred Spatial Option report for the Core Strategy Review in September 2018 seems a sensible timescale in view of the complexity of the task.
Since the development of Green Belt is regarded as a last resort, we think it would be logical to also dovetail the strategic housing and green belt review with the exploration of options to deflect housing provision to Telford which has long served to cater for the needs of people from the Black Country with ambitions to move.

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?

The key issues outlined in paragraph 3.1 are as follows:

* Updating the evidence base
* Meeting the housing needs of a growing population
* Supporting a resurgent economy
* Supporting strong and competitive centres
* Protecting and enhancing the environment
* Reviewing the role and extent of the green belt
* Keeping the Black Country connected
* Providing infrastructure to support growth
* Working effectively with neighbours.

We agree that, subject to the caveats wish we have listed above, these key issues outlined in Part 3 represent the factors which need to be taken into account through the Core Strategy.

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?

Yes. We broadly support the Core Strategy Vision and sustainability principles. However, although we accept that ideally it may be desirable to 'put brownfield first' in terms of the authorities' priorities, in practical terms this is not always feasible. In any event, a 'brownfield first' strategy for housing is not actually Government policy. Authorities are expected to encourage and promote the development of brownfield sites for housing but this may not necessarily mean putting brownfield before greenfield development. The market would grind to a halt if they did so.

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

The 10 objectives seem broadly sound as a basis for planning and regeneration of the review period. However, although there is a mention of existing housing areas in Objective 4, there is no actual reference to providing an adequate level of new housing, in places where people want to live. Furthermore, the Objective 3 which refers to 'Model sustainable communities on redundant employment land in the Regeneration Areas' does not reflect the change in stance within the review which will now be looking at a wider portfolio of sites, including some Green belt sites both with the Black Country and South Staffordshire. There is also no reference to working in partnership with neighbouring authorities or the private sector, something which is essential to achieve delivery.

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

Yes. We agree that policies CSP1 and SP2 remain relevant. But they may be rather too prescriptive in trying to direct development to specific centres, locations and corridors. The Review provides the opportunity to gauge to what extent the current
Core Strategy has succeeded both in focusing development on preferred locations but more important in boosting and regenerating the Black Country. These policies may have unintended consequences if they tend to deflect growth elsewhere.

It may also be appropriate to consider whether there are other places in the Black Country which now need a boost other than the main centres and corridors. Since most of the Black Country is within built-up areas there may be a case for more flexibility with a greater focus on design rather than location. We would also suggest that the canal network provides an opportunity for water-based regeneration which can improve the environment through waterside development and create a rich mixture of residential, small scale commercial and recreational development.

Question 10 - In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
If no, do you support Option 1B? Yes/No; If yes, please explain why.
If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question 11b - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.

Yes. The Regeneration Areas will need to be extended. We don't have fixed views about the merits of options 1A and 1B. Indeed a 'one size fits all' approach may lead to a contrived solution which becomes difficult to deliver in practice and stifles development which could otherwise legitimately occur. According to Government policy the use of the Black Country Green Belt should be viewed as a last resort, hence there should logically be a pointer towards Option 1B in preference to 1A. The canal routes could provide employment areas where regeneration could result in more housing as part of mixed used development thereby improving the overall environment and bringing the Black Country's history and culture to life. We agree that using green belt in South Staffordshire rather than the Black Country should be considered where pressure and potential impact may not be as great. The scope for exporting some housing needs to Telford where green belt is not an issue and infrastructure is already in place, should also be seriously considered.
Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.

Question 12b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).

The designation of Green belt is based on 5 specific purposes, most of which are relevant to the Black Country. However, Green Belt is a strategic policy tool, not an instrument of landscape or recreational policy - although in some cases they may well function as recreational areas in practice. We feel there is a valid case for rounding-off parts of the Green belt in the Black Country and in South Staffordshire. The Black Country, especially Walsall, has a network of green wedges which separate smaller communities which would be hard to justify on current criteria and in some cases are less sensitive as green belt.

The criteria for selection of site review, should be related to the initial reasons for designation of green belt. This is consistent with the findings of the West Midlands Land Commission Report which suggests that there should be review of the Green Belt within the whole West Midlands Metropolitan Area and that it should be consistently applied and related to those areas of land which perform poorly against the five statutory purposes of the green belt.

In defining new areas and boundaries, as suggested within the NPPF (which was unchanged from the former PPG2) local authorities should look for clear defensible boundaries such as rivers, roads, railways and tree lines or field boundaries where the case for striking a green belt edge is stronger.

There may also be a case, as the Government's Housing White Paper suggests for redefining green belt boundaries on their outer edge to retain the width of protection for towns. In addition, although green belts are not intended to be an environmental or landscape policy, there is a strong case (as the Landscape Institute has suggested) to adopt a separate landscape or recreational strategy for some green belt land to strengthen its positive role in providing value for society (including those residents of the urban areas who may lack accessible public open space, rather than being an enclave of protected green land for people who occupy high value or more exclusive homes.

In South Staffordshire there are also areas where green belt could be rounded-off without damaging its purpose, such as north of Codsall on land being promoted by Hallam Land at Sandy Lane (SHLAA site 222) which would extend a recently consented site and where the 5 purposes of the green belt would not be compromised. We have submitted a separate contribution under the 'Call for Sites' including the Sandy Lane, Codsall site.


Question 13a - Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas.
What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.

Question 13b - What infrastructure do you think would be needed for different sizes of SUEs?

Question 13c - Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?

Question 13d - Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?

There may well be cases where larger sustainable urban extensions are deemed appropriate. However, comparative assessment work would need to be undertaken and a strong case demonstrated if large areas of green belt were to be sacrificed to development. The Housing Green Paper emphasises that the use of green belt land for development should be a 'last resort' and rightly points towards peripheral rail stations as providing an obvious focus for larger scale development.

Inevitably, larger free-standing settlements in the green belt would take longer to develop albeit they would deliver a broad range of services. Easy access to jobs and public transport would need to be an essential pre-requisite to any sustainable urban extension. Suitable SUE's would need to conform to essential criteria to justify their selection in the first place - though the precise nature of the SUE would no doubt emerge through public and private sector negotiation and partnership.

Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details.

We have already mentioned above that other options rather than encroaching onto the Black Country green belt, do exist. The larger South Staffordshire villages which are served by public transport provide a logical case for growth. In the case of Codsall/Bilbrook there are 2 railways stations and the village is within cycling distance of the new i54 JLS plant and the Pendeford Business Park close by. Carefully selected green belt releases in these locations offer good potential links between homes and jobs whilst exploiting the wide range of facilities which Codsall enjoys. The Sandy Lane site, promoted by Hallam Land will be surrounded on three sides by development, once the adjacent Watery Lane site is built, and is ideally suited for development.
Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?

Question 15b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.

Question 15c - Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.

Telford New Town has long provided an opportunity for a new life for people moving out of the Black Country since its designation in 2017, indeed the original purpose of the New Towns were to serve the wider housing needs of the West Midlands Metropolitan area. Although Telford has since lost its formal New Town designation and no longer has Assisted Area status, it still retains the culture and ambition for growth and enjoys much of the infrastructure needed for growth which has already been provided at public expense. There are potential strategic sites in Telford, for example at Wappenshall to the north of the town, which are well linked to both existing and planned industrial jobs as well as having an attractive environment and close proximity to all the facilities existing in a burgeoning new community.

Strangely, Telford & Wrekin Council currently seems reluctant to continue its natural growth trajectory, or even to reach its original population target, but the Telford Local Plan Inspector has recently rejected the submitted housing strategy within the emerging Local Plan Review, and sought higher housing numbers, a justification for the selection of sites within and an early review within the Proposed Modifications.

Wappenshall provides scope for the delivery of 2,500 new homes within a restored canal-side environment lying adjacent to the built-up area of Telford, close to the major industrial estates of Hortonwood and Hadley and in a location where public-sector land owned by HCA can be levered into the scheme. The Proposed Modifications to the Telford & Wrekin Local Plan now provides a further opportunity to examine new initiatives - such as Wappenshall, which could bring all round housing, economic, recreational and tourism benefits to the town.

Telford provides a natural destination for current residents of the Black Country who could still commute the 15 miles to jobs at i54 or Pendeford Business Park using the M54 motorway or travel by train. Alternatively, there will be further job provision locally which would enable people to start a new life and career whilst retaining their close links with the Black Country - just as previous generations have done before them.

Questions 16 - 20, Spatial Employment Options (E1 - E4).

We have no specific comments to offer on the alternative Employment Options for the Black Country.

Question 21 - Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.

Yes. we would expect Policy DEV1 to be reviewed as a matter of course as part of the review of the Core Strategy, which could include the imposition of infrastructure requirements to meet future community needs, subject to any changes in the CIL regime which may be announced in the coming months, following the CIL review.

Questions 22-28, Social and Physical Infrastructure.

We have no further comments on these aspects.

Question 29 - Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.

Question 30 - Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.

The use of generalised and site-based viability assessments are likely to be important in determining whether schemes can progress and if so, what level of infrastructure - social and physical - they can support. Paragraph 5.28 indicates that some 25% of potential housing sites and 30% of employment sites in the Black Country are unviable to develop. This legacy of contaminated land often precludes the development of sites and makes affordable housing difficult to deliver on others.

In addition to the mechanisms outlined in paragraph 5.24, such as clawback, or phased viability assessments, it may be possible to link or cross-subsidise green belt and brownfield sites. This has been suggested previously albeit often flounders unless the two sites are in the same ownership where delivery can be assured. Green belt sites would (in general) be capable of offering a higher level of infrastructure which could tip the balance in terms of justifying their release. Grant aid, for example through the Black Country LEP, the WMCA or by using the HCA's new £3bn Home Building Fund which is designed to assist with infrastructure could assist.

The West Midlands Combined Authority has just released (September 2017) its Land Delivery Action Plan which includes funding initiatives to assist in the delivery of land for housing.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?

The Black Country is a prime example where additional public funding may be necessary to lever out sites for regeneration. In addition to those areas of support from Government, HCA, LEP's and now WMCA there could be Heritage Lottery funding where for example there are old canal structures are involved. As para 5.38 indicates, the Housing White Paper signals potential changes to the CIL regime which may result in a standardised tariff rather than the present CIL floorspace formula.

It is also possible that the Government may encourage the Black Country to pursue its Garden Village bid, which could then be accompanied by associated funding for development and renewal.

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No; If no, please provide details

Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No; If yes, is a new policy needed to address such issues for example?

Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No; Any further comments?

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

Health and Wellbeing is becoming an essential element in the planning process and there are many potential initiatives and measures which could be employed to raise levels of health and wellbeing which could help to stem multiple deprivation in the Black Country, for example:

* Travel modes - including the encouragement of walking and cycling,
* public open space - including facilities to encourage more exercise and improvement of quality of life
* reduction in diesel emissions for example through traffic restraint and pedestrianisation and the possible removal of speed humps,
* the juxtaposition of land-uses to encourage better home/job relationships including the promotion of working from home,
* possible education on diet and exercise - especially for children.

A Health Impact Assessment will be required.
Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

We certainly support the need to update the Policy HOU1 figure and to review the trajectory and the balance between brownfield and greenfield development, now that the Councils in the Black Country recognise that some future housing development will need to go onto the green belt. The maintenance of a generous 5 year housing land supply is an essential element of the NNPF as part of the commitment to 'boosting housing delivery' within paragraph 47 of the document, which should apply to all four local authorities. It is unclear however how the housing provision and housing land supply for South Staffordshire will work, bearing in mind it is outside but integral to the Black Country.

If the Black Country authorities are planning to reduce the degree of flexibility on the delivery of strategic sites (as indicated in paragraph 6.22 and also introduce a 505 per annum small site allowance then there will need to be plenty of leeway in the provision on sites to ensure that targets are met.

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?

Question 37a - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why

Question 37b - If no, should it be reduced to 11 homes or more? Yes/No; If no what other threshold should be used and why?
Question

Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?

Question 39 - Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.

Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.

We are not in favour of applying specific housing mix criteria for sites, unless they are sufficiently large where a mix and variety of dwellings is important. The housing mix should be related to the specific site circumstances and ideally determined through pre-application discussions. They should not be prescriptive.

It is logical to apply higher density expectations to sites close to public transport modes, whether within the green belt or not, but it may be dangerous to impose specific standards which fail to reflect the circumstances of particular sites we therefore support the proposal within paragraph 6.28 to remove this paragraph from the Plan.

Paragraph 6.30 refers to the growing need for Sheltered and Extra Care dwellings, estimated at about 5% of the requirement. The Councils should encourage the delivery of this type of property, but it will not be feasible to expect market sites to deliver an element of extra-care and sheltered accommodation which tend to have
somewhat different locational requirements.

Finally, it may be tempting to apply housing requirements on density, mix and type according to the Council's SHMA but unless the expectations can be supported in terms of viability and deliverability they will not actually materialise.

Question 41 - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
A target for each authority? Yes/No; Any further comments - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
Another approach altogether? Yes/No; If yes, please specify.

Government warmly support the idea of self-building as an opportunity for more people to get onto the housing ladder and a policy encouraging self-build plots would be sensible. However, self-builders tend to want specific isolated plots where they can 'do their own thing' or require custom built homes which are separate from larger standard housing sites. Any idea that builders should specifically reserve plots for self-builders could be self-defeating. In practice, small housebuilders will cater for self-build or custom building if it means selling a plot or a house in a different way.

Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.

Question 43 - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why. If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?

The Councils should set the target for affordable homes at the level which emerges from the evidence obtained from the SHMA. With the definition of affordable homes set to change to include starter homes it is admittedly difficult to pin down exactly what counts as affordable and what doesn't. The Black Country authorities should therefore set the right policy climate to encourage more affordable homes to come through. Where so many sites ae affected by contamination and site stability issues the ability to subsidise affordable housing may be problematic. Affordable housing may therefore need to emerge through public subsidy through Registered Providers and housing trusts, rather than necessarily through cross-subsidy.
Question 44 - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments? If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?

The current 25% quota is probably a helpful guideline, unless evidence from the SHMA demonstrates that a higher (or lower) percentage is justified. The lower level of subsidy now expected from developers (80% of market price) may make a high overall quota easier to achieve. This will be guided by the outcome of the SHMA which may assist in identifying the range and type of affordable housing needed, but this may well change over time and in any event, will need to be determined on a site by site basis.

Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.

There is every likelihood that green belt sites will be capable of delivering higher levels of affordable housing, but on the other hand may not be the most appropriate location for accommodating people without cars or access to employment. If there is a broad overall policy guideline but with a site by site assessment, this is likely to produce the most satisfactory result.

Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing developments? Yes/No; If no, please explain why.

Question 48 - Do you agree that the requirement in HOU5, to demonstrate there is adequate alternative provision to meet the needs of the community served by a facility which is to be lost, should be reviewed? Yes/No; If yes, please explain why.

In a situation where Sandwell and Dudley both have CIL plans and policies but Walsall and Wolverhampton currently don't, creates a difficult situation in terms of producing a standardised policy for the Black Country as a whole.

S106 agreements have the ability to adapt to the circumstances of the specific site and reflect its viability and deliverability. But there are clear advantages of incorporating the funding of 'strategic' facilities through a pooled CIL policy - if the viability of each site is not prejudiced.

In principle, it is right that community facilities should be funded through developer contributions, however public funding for infrastructure is currently being reassessed through the Government's CIL review and it may be sensible to await the outcome of this report before formulating policy on this aspect.

Question 49 - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why. If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.

It is probably desirable to keep Policy DEL2 to enable the authorities to manage the release of poorer quality employment land. The Core Strategy has identified a higher than expected take up of employment land within the Black Country and hence the local economy should not be prejudiced by the lack of employment availability if it is needed. Furthermore, the Black Country needs a pool of poorer and cheaper sites in sub-optimal locations to find places for 'unneighbourly uses' such as scrap yards, storage sites and other uses which need to find a home somewhere.

Question 50 - Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/No; Please explain why.

The scenario described in paragraphs 6.53 - 6.58 paints a very fluid picture on employment supply and need, with the turnover of sites catering for emerging needs but with a lack of larger strategic sites which could provide more jobs for the wider Black Country and south Staffordshire economy. We feel there is a need for a total employment land stock as a general guideline, but that the LEP needs to carefully review the nature of the economy so that growth is not held back by a lack of land.

Question 51 - Do you think that the criteria used to define Strategic High-Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

Question 52 - Do you think that the criteria used to define Local Quality Employment Areas are appropriate and reflect actual market requirements? Yes/No; If not, how do you think the criteria and/or terminology should be amended?

Question 53 - Do you think that Strategic High-Quality Employment Areas should continue to be protected for manufacturing and logistics uses, with the other uses set out in Policy EMP3 discouraged? Yes/no; If not, what alternative approach do you recommend?

This strays outside my client's interests. However, we feel that the policies need to be reviewed against the background of the High Quality Strategic Sites Study (2015) and the practical evidence coming forward from the Black Country LEP and the WMCA on the type of strategic sites which are likely to be needed and the extent to which these need to be 'ring-fenced' from more general employment sites.
Question 54 - Do you agree that the current approach in Policy EMP4 is no longer fit for purpose and should be amended to reflect a portfolio based approach? Yes/No; If no, what alternative approaches would you recommend?

We would support the views of EDNA that there needs to be a broad portfolio of sites rather than a single overall target. This should relate to sites within South Staffordshire as well as the Black Country.

Question 88 - Do you agree that the overall transport strategy supports all of the Core Strategy spatial objectives? Yes/No; Please explain why.

Question 89 - Do you support the proposed changes to the priorities for the development of the transport network? Yes/No; Please explain why.

Question 90 - Do you support the proposed changes relating to managing transport impacts of new developments? Yes/No; If no, please explain why.

Question 92 - Do you support the proposed approach to providing a coherent network for walking and cycling? Yes/No; Please explain why.

The Black Country is at the centre of the national trunk road and rail network, but at the same time has a network of local communications which serve the myriad of localised Black Country communities. It is important that any transport strategy recognises this dual role and that there is a focus on maintaining and improving the metro, bus, cycling and walking networks within the Black Country - also using the traditional canal network as a regeneration opportunity.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place-making? Yes/No; If you think that any other changes should be made to Policies CSP3 or CSP4, please provide details.

Question 95 - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied? Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

It is important that the Environmental networks within the Black Country are developed and improved to boost the image of the area and provide the enhancement in the landscape and environment to support the local economy and provide a platform for residential development.

The promotion of a Garden City for the Black Country was a positive initiative to raise the profile of the area and attract funding, but bearing in mind that the Black Country Garden City proposal incorporated a wide range of disparate and unconnected sites the traditional concept and principles of a Garden City are unlikely to be easily translated into the Black Country context.

Question 98 - Do you support the proposed changes relating to Design Quality? Yes/No; If you think that any other changes should be made to Policy ENV3 please provide details.

We support the proposal to remove the reference to the Code for Sustainable Homes since this has been deleted as a requirement from the NPPF.

Question 99 - Do you think that national standards for housing development on water consumption, national access standards or national space standards should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why. Should any standards be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

We are not convinced that there is a need to apply national standards for water consumption, national access standards or minimum space standards to schemes in the Black Country, unless there is a clear justification, all of which would tend to make housing less affordable. The same principle would apply for both brownfield and greenfield (and green belt) sites. Most builders adhere to Building for Life specifications and Building Regulations are becoming ever more stringent to cater for access and environmental standards.

Question 100 - Do you support the removal of the reference made to canal projects? Yes/No; Do you think that any other changes should be made to Policy ENV4? Please provide details.

Whilst there may be a case for the removal of references to specific canal projects we would expect to see a rather more positive strategy for both canal restoration and for regeneration relating to the canals to encourage exploiting the historic assets which the Black Country is famous for and enjoys.

Question 118 - Do you agree with the proposal to streamline and simplify the Core Strategy Monitoring Framework? Yes/No; If no, please explain why

We have no objection to removing redundant or superfluous monitoring targets and information to simplify and streamline the process. However, since the Black Country Core Strategy is being reviewed in tandem with the South Staffordshire Local Plan there may be a need for a monitoring schedule to link the two, so that South Staffordshire is able to assist in bringing forward sites to meet the Black Country's needs.

Question 119 - Do you think that a new Core Strategy policy is required? Yes/No; If yes, please explain why and provide details of the suggested policy.

We agree that there may be a case, as outlined in paragraph 6.2.6 to address changes to green belt so that they relate to specific sites rather than general areas, since new GB boundaries need to be properly defined and the 'exceptional circumstances' adequately tested.
Appendices B and C.

The monitoring figures within Appendices B and C indicate that the Black Country has fallen a little behind in its housing output (-3039) compared with its overall target for the cumulative plan period so far. Whilst this is not significant, it demonstrates that measures need to be taken to link the availability of sites with Southern Staffordshire where there are sustainable opportunities which are more readily available and to undertake a coherent and consistent review of the green belt to address the shortfall of sites.

Call for Sites - potential options.

We have already referred above to the Sandy Lane site at Codsall and will be submitting this as a potential opportunity to extend an existing consented site north of the village which was previously 'safeguarded' green belt land and together with the existing built-up area now surrounds the Sandy Lane site on three sides.

We have also referred to a potential strategic site at Wappenshall north of Telford which can be developed in conjunction with HCA land and has been promoted through the Telford & Wrekin Local Plan. Telford provides a genuine opportunity to take-up surplus requirement from the Black Country, to address a shortage of supply where green belt would not be affected.

I trust this submission is helpful in formulating your emerging Core Strategy review.

Yours sincerely

John Acres

ACRES LAND & PLANNING LTD

STW is a regulated utility company with statutory responsibilities for the provision of water and sewerage services across the English Midlands and Central Wales. As a result of changing processes in relation to clean water provision and wastewater treatment, significant areas of land are no longer required by the business for operational purposes and as such are surplus to requirements. STW is currently undertaking a programme of rationalising its land holdings and is seeking to dispose of redundant operational assets for alternative uses through a process of Irrevocable Sign Off (ISO). Proceeds from the asset disposal are reinvested back into the core business to improve services for its customers.
The purpose of this representation is to provide general comments on the Issues and Options consultation document, particularly in respect of STW's landholdings in the Black Country. Details of the STW sites have been submitted via the concurrent 'Call for Sites' exercise.
STW are keen to work collaboratively with the Black Country Authorities to deliver a 'sound' Core Strategy (BCCS) which meets the identified housing and employment needs in the BCCS area. We would welcome a meeting with the Councils' officers to discuss in greater detail STW's site review programme and potential development opportunities offered by it that could make a significant contribution to meeting the anticipated future housing or employment needs of the Black Country region.
STW is generally supportive of the approach taken by the Black Country Authorities to maintain the existing 'two-tier' local plan approach whereby strategic planning issues across the Black Country area are addressed through the BCCS with site allocations and detailed policies being pursued via specific Local Plans for each Local Authority constituent area.
However, it is evident from the content of the Issues & Options Report that the scale of forecast housing and employment needs will not be delivered within the 'centres/corridors' framework of the current Core Strategy or within the existing Black Country urban area generally.

As the Issues & Options Report recognises, accommodating all future development needs will necessitate the release of Green Belt land. STW supports the need to review the Green Belt to ensure that appropriate sites are brought forward in the most sustainable locations to be of benefit to the needs of residents and businesses and in order to support the growth expectations and aspirations of the Black Country region.
We would question however, whether it is appropriate at this stage and prior to the conclusion of on-going research and evidence (including Green Belt Reviews and SHLAAs) to potentially pre-determine that the 'centres/corridors' approach of the current BCCS should be maintained as a core element of the reviewed Core Strategy, and that the subsequent choice for accommodating growth should follow the sequential stages outlined at Table 2.
Rather, given the growth requirements and the acknowledgement that Green Belt land release will be required, we would encourage the Core Strategy process to consider the most appropriate and deliverable distribution of development to meet the strategic objectives and growth ambitions, within the context of national policy and with reference to the existing urban area but without, at this stage, potential constraints imposed by the existing strategic policy framework.
Such an approach may also enable a degree of flexibility to the pattern of distribution of housing and employment, that best reflects the needs of the market and therefore likelihood of delivery.
STW also generally supports the recognition that sites outside the Black Country may have potential to contribute to Black Country needs, albeit within the context that an authority or - as here - authorities should seek to meet the their own needs within the own areas if possible.
In association with this representation to the Issues & Options report, GL Hearn has submitted a number of STW sites to the call for sites exercise. The sites submitted are:
Walsall:
Goscote Works (14.9ha)
Land at Walsall Wood (10.9ha)
Land at Willenhall, Walsall Road (10ha)
Sandwell:
Land at Roway Lane (3.4ha)
Land at Bescot (12.9ha)
(existing allocated residential site - Policy HOC8 Sandwell Site Allocations and Delivery DPD)
Land at Ray Hall Lane (30ha)
Dudley:
Enville Street, Stourbridge (1.4ha)
Wolverhampton
Barnhurst, Oxley Moor Road (12.9ha)
We anticipate being able to provide further information in respect of these sites in the near future, additional to that provided via the current call for sites response.

As referred, STW as a major landowner within the Black Country area, is keen to work collaboratively with the Black Country Authorities to deliver a 'sound' Local Plan which meets the identified housing and employment needs of the Black Country region, and potentially the wider Birmingham area.
As a major landowner, with a number of sites across the region that offer significant development potential, STW considers it could make a significant contribution to delivering the Black Country's residential and/or employment growth requirements.
We would welcome discussions with the Black Country Authorities to discuss and further explore the potential development opportunity of the STW's sites and how they may contribute to delivering the residential and economic growth targets.
In the meantime we trust that this representation will be taken into full consideration in the preparation of the next stage of the Core Strategy.

Key Issue 3 - Supporting a resurgent economy - Question 4

Do you agree or disagree with the approach set out in the relevant section and / or question?

Disagree - we do not consider the employment land requirement identified is appropriate.

The EDNA is a well-researched and presented study. However, we are concerned that the overall employment land requirement identified by it (800 hectares) and the subsequently identified gap between anticipated need and supply (300 hectares) has been underestimated significantly. Unless this is corrected, it will be difficult to plan properly for the right quantity and quality of new employment land and this, in turn, will seriously hinder the economic revival of the sub-region.

We consider that the overall employment requirement (800 hectares) is a significant underestimation for the following reasons: -

* The EDNA assess three methodologies for estimating future land requirements but ultimately only relies on two (employment growth and past development trends), discounting inexplicably the third method (GVA based growth in manufacturing) which projects a far greater requirement.

* Past development trends have been constrained, by difficulties in the delivery of sites, have ignored the contribution made by strategic sites just outside the boundaries of the Black Country, and do not represent long term demand levels being experienced by the market.

* No specific allowance has been made for any losses of employment land, either current or planned (to 2026) or potentially required to accommodate housing growth (2026 to 2036).

* No allowance or margin has been made for market churn, to introduce an element of choice, or to hedge against uncertainty despite referring to this in the study's scope.

* The overall requirement equates to 38 hectares per annum and is significantly lower than the requirement projected by WECD in its 2014/2015 studies of 56 hectares per annum and does not align with the West Midlands Combined Authority Strategic Economic Plan (SEP) which is seeking much further and faster growth.

The first four reasons are considered in more detail below.

WECD is to be congratulated on their analysis of the potential employment land requirement based on future GVA growth in manufacturing. This is particularly relevant to the Black Country due to the significance of this sector to the sub-regional economy and its renaissance in the wider West Midlands in recent years. Paragraph 3.11 of the EDNA refers to 15% of the UK's high value manufacturing being carried out in the Black Country, along with producing 20% of the UK's aerospace output. In addition, reference in the same section of the report is made to Wolverhampton being ranked as the number one western European city for manufacturing in terms of job creation.

The GVA "growth in manufacturing" model projects an overall employment land requirement of between 400-500 hectares as a base line and between 1,310-1,593 hectares based on the super SEP scenario. It is the latter figure that corresponds with the 250 hectares projected by the employment growth methodology, which is ultimately preferred in association with the past development trends of 540 hectares (in order to derive a total requirement of 800 hectares).

A full rationale for employing the GVA growth based projection is provided in paragraphs 6.25 to 6.28 of the EDNA. In paragraph 6.27, it states

"Review of past trends shows that the relationship between land requirements and output in the manufacturing sector is relatively strong/resilient in comparison with the relationship between employment and land requirements."

In addition, in paragraph 6.34 (second bullet point) it notes that the GVA growth model is in alignment with the conclusions of the WECD 2014/15 studies in terms of its annual requirement projected.

Despite these observations, the employment growth model is ultimately employed, resulting in a significant deflation of the overall requirement. The principal reason for this is provided also in the second bullet point to paragraph 6.34. It reads:

"However, it may be questionable whether such a level of demand would be (financially) sustainable over the long term (i.e. development of a site/sites equivalent to 70 hectares per annum each year to 2036 would require significant investments, given the quality and availability of land in the area."

Effectively, the GVA growth model for projecting the requirement has been discounted because of concerns about how to deliver the quantity and quality of land required. It is right for there to be concerns about delivering the supply of sites - and this is why a different approach to the Core Strategy is required (as acknowledged by the Issues and Options) - but this should not be a factor in determining the overall and true requirement in the first place.

With regard to past development trends, paragraph 5.9 acknowledges that past development rates over the measured period (2001-2013 - reference Figure 5.1) could have been constrained by "shortage of suitable stock or availability of resources to pursue development/completion." In addition, there are two other factors, not referred to by the report, which could have led to a distorted and reduced completion rate than that recorded (i.e. 25 hectares per annum). These are:

* The period takes in the recession of 2008-2012, when very little employment development took place. Since 2012, there has been a significant level of development but this has not been recorded for the purposes of calculating the average annual rate.

* No account has been taken of development just outside the Black Country (within South Staffordshire such as i54) which is considered to contribute to the sub-regional needs of the Black Country.

The true development rate of the past 15 years of land serving the needs of the Black Country (i.e. from 2001 to 2016) is likely to be significantly greater than 25 hectares per annum. Moreover, it is to be re-called that the economic objectives of WMCA and the Black Country are to accelerate growth and associated development considerably above and beyond current development rates.

Paragraph 3.23 of the Issues and Options states:

"For all scenarios the EDNA assumes that the 300 hectares of occupied employment land already allocated for housing through Local Plans is lost to the employment land supply over the Plan period."

However, we can find no such reference in the EDNA to making any allowance for the loss of employment land in projecting the overall requirement, although it should. Paragraph 4.19 of the Issues and Options rightly states that any employment land displaced would need to be made up elsewhere.

Reference is made in Figure 7.1 of the EDNA to 203 hectares of employment land identified for housing in Local Plans and a further 280 hectares of employment land that could be considered for release subject to there being an adequate supply of employment land. However, these references are made in Section 7 which covers the supply of employment land to meet employment requirements.

The Issues and Options also makes open reference to the potential loss of significant levels of employment land to help meet housing need. Paragraph 6.54 states that the overall effect of Policies EMP2 and 3 of the Core Strategy is a contraction in employment land from 3,392 hectares in 2016 to 2,754 hectares in 2026 - a loss of 638 hectares. In addition, consideration seems to be being given to the loss of a further 300 hectares from 2026 to 2036, as a potential option to address the significant need for housing.

It is unclear how the significant projected losses of employment land over the plan period to 2036 have been taken into account by the three principal methods employed by WECD in projecting the employment land requirement. In our experience, it is usual practice that an adjustment is made to the requirement for employment land to compensate for any likely future losses of employment land.

The EDNA sets out in paragraph 1.7 the principal means and methodology of developing a picture of future requirements. These include:

"Due to the presence of uncertainty in the projections of employment (and to introduce an element of choice) a margin is added equating to two years' worth of development." (Our emphasis).

However, we can find no express allowance being made in Section 6 for this factor. In addition, it has been practice elsewhere (e.g. G L Hearns's Leicester and Leicestershire HEDNA of January 2017) to provide a margin equating to five years' previous development, rather than just two.

We also hold concerns about the estimation of supply. Paragraph 3.26 of the Issues and Options refers to 394 hectares of land either currently available or likely to come forward within the Black Country itself. We cannot understand how this figure has been sourced from the EDNA.

The EDNA assesses supply and presents this in Figure 7.2. This provides a total of 263 hectares on 119 sites. It is to be noted that much of this land is not currently vacant but occupied (i.e. Categories B and C) and, therefore, cannot be guaranteed to come forward for development. Indeed, elsewhere in the report it is noted that the loss of existing employment land to other uses up to 2016 has not been as great as previously projected due to the greater economic resilience of existing businesses.

Of the 263 hectares presented in Figure 7.2, only 227 hectares (on 99 sites) is identified to be of Premium, Very Good or Good quality (Figure 7.4). This suggests the remaining 36 hectares is not of sufficient quality and should not be counted towards supply.

8 Premium sites are listed totalling 82 hectares. None are greater than 17 ha and half are less than 10 hectares. Generally, we consider high quality strategic employment sites should be greater than 20 hectares. This is to be able to accommodate larger requirements of up to 25,000 sq m (250,000 sq ft) and provide a range and cluster of different sized buildings. The larger the size of the site, the greater the agglomeration benefits, including provision of ancillary facilities, such as a food and drink outlet, public transport investment, and open amenity space.

In addition, there are issues of availability, access, residential amenity and deliverability with 6 of the 8 sites , as follows: -

* Dandy Bank Road, Tansey Green and Dreadnaught Road (12 ha) - Significant proportion occupied by Dreadnought Tiles, with no known plans to move operations. Site neighbours residential property.

* Phoenix 10 (16.5 ha) - Site highly contaminated and unstable, with remediation a complex and lengthy process. Access to strategic road network is unsuitable for a site of this size.

* Former Moxley Tip (10.37 ha) - Delivery issues in terms of ground remediation and stability. Will require grant funding to come forward.

* Former Willenhall Sewage Works (9.7 ha) - Major issue with site access, with site adjoining residential property on two sides.

* Former Gasholders (8.7 ha) - Residential property fronting Darlaston Road is a significant constraint which could require acquisition with CPO powers. Site will also require significant ground remediation.

* Rear Long Marston Site (7.3 ha) - Site constraints include ground contamination, land stability, flooding, access, vacant possession, and the effects of a recent fire.

At JLL we are involved in a number of the Premium sites and are hopeful that all can be delivered to the market. However, given the significance and long standing nature of some of the constraints, the need for 3rd party input (in the form of grant funding, CPO and current sitting tenants/operators) there is an obvious danger that some of the Premium sites will not come forward and it would be unsafe to place total reliance on them.

Even if all of the Premium sites were delivered during the plan period they would satisfy only a small fraction of the total requirement (800 hectares). Assuming a 20% reduction in the gross site areas to generate realistic development site areas (for reasons articulated below), the 8 sites would contribute 65 hectares. This constitutes just over 8 % of the total requirement and is equivalent to just 1.5 year's demand (based on an annual requirement of 40 ha per annum).

In paragraph 3.26 of the Issues and Options, an assumption is made that a further 90-170 hectares of land in South Staffordshire has the potential to contribute towards meeting Black Country needs. The contribution from South Staffordshire is broken down with 90 hectares made up of remaining land from three of the four Freestanding Strategic Employment Sites identified by the 2012 South Staffordshire Core Strategy (i54, ROF Featherstone and Hilton Cross) and proposed extensions (by the draft South Staffordshire Site Allocations) to i54 (40 hectares) and ROF Featherstone (22 hectares). No allowance has been made for the remaining land at the other Freestanding Strategic Employment Site (Four Ashes). This site was discounted by WECD in its 2014/15 study as a potential contributor to the sub-regional economy of the Black Country as it was deemed to be located too far away from the Black Country.

It is to be noted that the proposed ROF Featherstone allocation extension has been subject to quite extensive objection through the Site Allocations process (including from Historic England and the National Trust on its impact on the listed building Old Moseley Hall). There is still a high degree of uncertainty of how this long vacant site will be delivered, particularly in respect of access, without significant grant funding. This position needs to be carefully monitored.

The other assumed contribution from South Staffordshire is that the proposed West Midlands Interchange will contribute 80 to 100 hectares to the sub-regional employment land portfolio. These proposals are also uncertain as an application for a Development Consent Order for a SRFI has yet to be made. In addition South Staffordshire Council has made it public that it is not supportive.

In any event, this proposal will serve a much larger catchment area than the sub-region and will represent qualitatively and quantitatively a very specific and narrow market sector - i.e. big box B8 warehousing in buildings greater than 500,000 sq ft. In addition, it is difficult to see how this can contribute to the sub-regional land supply if the adjacent Four Ashes Freestanding Strategic Employment Site has already been discounted on the basis it is too far removed from the Black Country in order to serve its needs.

Finally, it is unclear if the supply of sites has been measured in gross or net developable terms. Generally, gross areas for sites are provided. However, the requirement for sites, specifically those generated by the employment growth or GVA growth methods, are calculated on a net developable basis.

Generally, the difference between a gross site area and the developable area of a site (which includes the development plots and main estate roads) is between 20 to 30%. As an example, the site being promoted by Nurton Developments - Hilton Park, Junction 11 of the M6 - has a gross site area of 88.9 ha but a maximum developable area of 64.9 ha. This constitutes a reduction by 27%.

For these reasons, we consider that the contributing supply is likely to be an over-estimation, possibly to a significant degree. Many of the sites are small in size and a number will not be delivered over the plan period.

Overall, we consider the need and supply of employment land must be re-assessed, otherwise there is a real danger that an insufficient quantum and range of employment land will be promoted. This in turn will threaten the ambitious economic strategy for the sub-region, as stated clearly elsewhere in the Issues and Options. We would be happy to be involved in any such reassessment, working with WECD, to ensure that this part of the evidence base to the Core Strategy Review is as robust as possible and provides a firm platform for planning the right quantity and quality of employment land to serve the Black Country.

Key Issue 6 - Reviewing the role and the extent of the Green Belt - Question 5

Do you agree or disagree with the approach set out in the relevant section and / or question?

Agree

Paragraph 3.47 states that the Green Belt Review will be carried out in conjunction with South Staffordshire Council. Two reasons are provided:-

* A large proportion of Black Country urban fringe extends into South Staffordshire.

* Strong housing market and economic links between the Black Country and South Staffordshire.

The second reason is corroborated in terms of economic links by both the EDNA and elsewhere in the Issues and Options. The EDNA, in Section 4, sees both South Staffordshire and Birmingham as areas of strong economic transactions with the Black Country. It concludes that these two areas, along with the Black Country, comprise a natural FEMA.

Paragraph 3.60 refers specifically to the relevance of South Staffordshire in terms of employment land. It states:

"South Staffordshire also has a crucial role to play in contributing towards meeting the employment land needs of the Black Country, reflecting the interlinked economies of the area. The South Staffordshire land portfolio is largely focused on meeting demand for large, highly accessible premium sites that cannot be physically accommodated in the Black Country. These sites include the hugely successful i54 business park which is home to a number of international businesses including Jaguar Land Rover."

However, it is vital that the scope of the Green Belt Review looks beyond just the urban fringes of the Black Country, particularly in terms of employment land. Good employment land, particularly larger strategic sites (which are in short supply in the Black Country), have specific requirements. These are:

* Quick and direct access to the national motorway and strategic road network, avoiding congested A or minor roads, particularly those that have to route through built-up or residential areas.

* Good penetration to the local job market, with particular regard to good existing or potential public transport links.

* Sufficient size to accommodate large buildings or a cluster of different sized buildings (with sites generally larger than 20 hectares required).

* Slightly removed from existing or proposed housing to allow total flexibility in terms of use, building design (i.e. height of buildings) and operation (ie 24/7).

* A pleasant, well designed and landscaped setting, with amenities for occupiers, in order to attract and retain staff.

Such sites, by their very nature, are not usually found either within the built up area of the Black Country or on the urban fringe to it. Instead, their area of search will extend further into the Green Belt along the principal motorway and A route network serving the sub-region.

It is essential that the scope of the Green Belt Review recognises this and has a suitably wide geographical remit. Otherwise, some of the best potential employment land opportunities will be overlooked.


Strategic Options 1A and 1B - Question 11a

Do you agree or disagree with the approach set out in the relevant section and / or question?

Comment

We support both Options 1a and 1b, but consider Option 1b to be preferable if the release of existing unsuitable employment land is managed appropriately.

We support both options as they recognise that a radical approach is required - i.e. releasing significant areas of the Green Belt in order to accommodate the relevant pressures for both housing and employment. With the latter, there is an express acknowledgement that there is a need to increase the employment land stock, as recommended by the EDNA.

Option 1b is considered by the Issues and Options to be a more radical approach as it looks to restructure some of the existing Regeneration Corridors, with some existing employment land being replaced by housing. However, this process is part of a long term recycling of land where unsuitable existing employment land, particularly those areas poorly located in terms of road access and with no future prospect, is best developed at the end of its economic life for more sustainable uses such as housing.

Moreover, the ability of the Growth Network to yield good quality employment land is diminishing. Most of the obvious well located large brownfield sites have already been developed. The Premium sites now identified by the EDNA are all relatively small and most are heavily constrained.

Option 1b recognises this and looks to the Green Belt where there are much clearer and better opportunities for development, particularly for large Premium employment sites. As such, we see Option 1b as a much more effective and deliverable strategy.


Strategic Option Area 2B - accommodating employment land growth outside the urban area - Questions 16 - 19

Do you agree or disagree with the approach set out in the relevant section and / or question?

Comment

We consider all four options need to be properly explored given that there is a significant need for new employment land outside the existing Growth Network and Regeneration Corridors. As referred to in our response to Question 4, we consider that the actual need for new employment land, particularly for large Premium sites, is much more significant and pressing than currently projected.

In settling on an option, or combination of options, it is vitally important to choose sites that will best respond to what the market requires. The market requirements, or characteristics, for best quality land are set out in our response to Question 5. For ease of reference, these are:

* Quick and direct access to the national motorway and strategic road network, avoiding congested A or minor roads, particularly those that have to route through built-up or residential areas.

* Good penetration to local job market, with particular regard to good existing or potential public transport links.

* Sufficient size to accommodate large buildings or a cluster of different sized buildings (with sites generally larger than 20 hectares required).

* Slightly removed from existing or proposed housing to allow total flexibility in terms of use, building design (ie height of buildings) and operation (i.e. 24/7).

* A pleasant, well designed and landscaped setting, with amenities for occupiers, in order to attract and retain staff.

We consider that Options E2 and E4 are most likely to fulfil these requirements. Moreover, given the scale of the shortfall of employment land (i.e. the gap between the projected requirement and identified supply), which we believe will grow once reassessed in the light of our comments to Question 4, we consider that Option E4 will be required, particularly in respect of finding larger Premium sites.

Nurton Developments is promoting just such a site at Hilton Park, Junction 11 of the M6 motorway. This site has direct access to the A460 at Junction 11 and has a gross area of almost 90 hectares (developable area of up to 65 hectares) and is capable of accommodating close to 250,000 sq m of industrial and distribution floorspace in a range of buildings from 2,500 sq m to 25,000 sq m of B1c, B2 & B8 use to meet the sub-regional needs of the Black Country and the local needs of South Staffordshire.

We have submitted a Call for Sites form for the site and support this with a Development Prospectus. This prospectus provides much greater details of the site, introduces some indicative proposals, considers the site's connectivity and sustainability credentials, and assesses the contribution the site makes in terms of the Green Belt.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered that for the second stage EDNA to be effective it must be informed by far wider
consultation with landowners, developers and employers than appears to have been the case with
the first stage exercise.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should be informed by far wider consultation with landowners,
developers and employers than appears to have been the case with the first stage exercise. The
Stage 1 report appears to have been informed by a fairly narrow range of consultees, and unless this
is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly
assessed.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
There is considerable potential for "rounding off" and relatively modest incursions into the Green
Belt for small to medium sized housing sites, and the "opportunities" identified in this regard in the
table under paragraph 4.29 of the Issues and Options Report should all be recognised. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The only circumstances in which any housing growth should be exported elsewhere in the HMA is if
there is compelling evidence it cannot be accommodated within the Black Country, and there is a
robust and certain framework in place to ensure that the homes will be required. An ongoing and
open ended general process of discussion around this issue is not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. Agreement needs to be reached in terms of how need across the HMA is going
to be met, and the BCCS Review provides an ideal platform in this regard.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, and unconstrained sites with immediate access to the
Strategic Road Network are required to contribute towards meeting the need for employment land,
particularly in relation to logistics led requirements; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of brownfield sites to contribute towards meeting employment land needs, but
this will not meet the requirements of the highly location sensitive large space occupiers that the
Black Country should be seeking to attract.
It might be that sites within Sustainable Urban Extensions (Spatial Option E3) can also make some
contribution in this regard, but this cannot be relied upon, particularly in the short term, and it is
unlikely that SUEs will provide an effective mechanism to accommodate large scale requirements.
Exporting growth to neighbouring areas (Spatial Option E4) should only be entertained as a last resort
and if there is compelling evidence it cannot be accommodated within the Black Country.
This again speaks to the point made elsewhere in these representations that for the second stage
EDNA to be most effective it should be informed by far wider consultation with landowners,
developers and employers than appears to have been the case with the first stage exercise. The
Stage 1 report appears to have been informed by a somewhat narrow range of consultees, and unless
this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly
assessed.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The type of approach set out in Policy HOU2 and Table 8 is appropriate in general terms, although
greater clarity should be provided to confirm that the standards are general ones, that their practical
application is highly location specific, and will be considered on a site by site basis to reflect local
circumstances. There is no requirement to increase the density standards, and again it should be
clarified that these (and indeed the accessibility standards) should be regarded as indicative only.
For Green Belt releases, site specific standards should be formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. There should be no
separate standards for particular housing types; this would add an unnecessary level of complexity
and risk hindering the delivery of such units where they might have been provided as part of schemes
otherwise broadly acceptable for their provision.
The SHMA should be used as a general guide to the types of houses to be delivered, but must be
applied generally, rather than rigidly, or again this will hinder delivery.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

see attachment

1. Introduction
1.1 These representations are made on behalf of IM Properties Limited in respect of the Black Country Core Strategy Review Issues and Options Report (the 'I&O Report').
1.2 They are not site specific but concern the approach of the review to the provision of appropriate levels of employment land to meet the needs of the Black Country and the aspirations of both the LEP and the West Midlands Combined Authority in their Strategic Economic Plans.
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2. Response to Questions
Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?
2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March 2012. It is based on circumstances and needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change in plan making.
2.2 The West Midlands Combined Authority's Strategic Economic Plan ('WMCA SEP') (June 2016) provides a city-regional perspective on economic growth and the consequential need for more housing. It envisages an additional 50,000 jobs across the West Midlands by 2030 over and above the 450,000 assumed in the current plans of the 3 LEPs and their constituent Councils, including the Black Country. This also has consequences in terms of housing, with 215,000 homes needed over the same period, about 50,000 more than in the current evidence base underpinning local plans.
2.3 Furthermore, the vision of the WMCA SEP is built on the premise of delivering an extra 1,600 hectares of brownfield land for "first class employment land of national significance", which the Black Country will play a crucial role in meeting. With concerns on the viability and size of regenerating brownfield land for employment uses of "national significance", it is imperative that the Black Country Authorities also assess greenfield land to deliver strategic employment sites.
2.4 This scale of ambition, which underpins the devolution deal which established the WMCA and is founded upon rebalancing the national economy, major investment in new infrastructure, including HS2 and its Connectivity Package to all parts of the West Midlands, the focus of the Midlands Engine and the Government's Industrial Strategy, will transform the Black Country over the next 15-20 years.
2.5 The Spatial Strategy therefore needs to be comprehensively reviewed and rethought. Others will make the case (including our subsidiary company IM Land) for a review of the Green Belt in order to accommodate a minimum of 14,270 dwellings which cannot be accommodated within the urban area, even allowing for an increase in urban capacity of 10,000 dwellings. This assumes the redevelopment of some existing industrial sites within the urban area for residential use.
2.6 The counterpoint is that the local economy, whilst sustained on many smaller businesses which rely on urban locations, requires modernisation and the ability to attract inward investment, both within the Enterprise Zones and in new locations which are highly accessible and attractive to modern occupiers. This will require a thorough review of employment land supply, its suitability to meet modern requirements and
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market demand, and the potential for new sites to be identified which may require Green Belt release.
2.7 In this regard, a study of Strategic Employment Sites in 2015 (by PBA/JLL) on behalf of the West Midlands Local Authority Chief Executives group identified the need for a second stage of work to address what it concluded was an impending shortage of major employment sites. This reflects the policy vacuum since the demise of the WMRSS which had a suite of policy responses to identify Regional Investment Sites and Regional Logistics Sites. As current sites are used up, there is no policy response in preparation. IM Properties Limited has raised this as a matter of urgency with the LEPs within the WMCA area and proposed a brief for a second stage of work.
2.8 It is positive therefore to see in the WMCA Land Delivery Action Plan being considered at the WMCA Board on 8 September that a number of strategic studies are proposed, including one to review "modern business requirements". It is disappointing however that this falls short of a commitment to the second stage of the Strategic Sites Study but is however a positive direction of travel. This work should align with and provide strategic context for the further evidence base work required to support the Black Country Core Strategy Review.
2.9 A full review of the BCCS is therefore essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs.
* All policies and objectives of the emerging BCCS Review are consistent with national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the shortcomings of the adopted BCCS.
Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?
2.10 See response to Q1 in respect of employment studies. This will also need to be supplemented by appropriate work on strategic infrastructure.
Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?
2.11 The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.
2.12 As part of this, the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
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2.13 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.
2.14 The methodology for the Strategic Locations Study, made available in July 2017, is very broadbrush and it is currently unclear if the strategic nature of the study will be repeated by the Black Country review or a more fine-grained approach taken which uses the Strategic Locations Study as a fixed starting point.
2.15 Furthermore, the Strategic Locations Study is premised on addressing the shortfall in housing supply with no equivalent assessment of how much employment land is needed. The review would be fatally flawed in our view if it proceeds without a clear understanding of the need for development including both housing and employment.
Q11a. Do you support Strategic Option 1A? Yes / No; If yes, please explain why. If no, do you support Option 1B? Yes / No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
2.16 There is a need for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both will require significant new land and infrastructure to support this level of growth, and this will require a different spatial strategy to the current one.
2.17 There is currently a deficit of 57 ha gross of employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality employment land. This does not distinguish between different types of employment, including different use classes and size or characterisation.
2.18 The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas and provide the backbone of the Black Country economy. In some cases, their loss to residential would negatively impact business in the area and remove local, sustainable job opportunities. Whilst there is pressure for increasing residential capacity and density within the existing urban area, care needs to be taken in ensuring a balance of what constitutes a sustainable pattern of development.
2.19 Further employment land supply evidence is required to achieve this balance between protecting smaller urban sites and the need as identified in our response to Q1 to provide larger high quality sites to meet the needs of modern industries and new operators, and their requirements for better accessibility to markets. This will facilitate the redevelopment of some urban sites for housing, but the Black Country faces choices with an overall employment land deficit of 300 ha and growth ambitions which will not be met simply by the regeneration of constrained urban sites. A number of larger employment allocations in more accessible locations will be needed.
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Q50. Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why. Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/ No; Please explain why.
2.20 The NPPG sets out that Local Planning Authorities are required to publish information at least annually that shows progress with Local Plan preparation. The Core Strategy should therefore continue to set a target for the total employment land stock to ensure the Annual Monitoring Report can be measured against a specified target.
2.21 Considering there is an acknowledged surplus in local quality employment land (146ha) and a large deficit of 218ha in high quality employment land, the Core Strategy should continue to distinguish between strategic high quality and local quality employment areas and provide suitable policy responses for each category. As set out in the response to Q11a above, there will be potential for the reallocation of some of this surplus local quality land for housing, whilst protecting the more important and productive sites. There will also be choices to make between the ability to enhance the quality of existing larger sites or employment areas and identifying new sites at strategic locations, including within the Green Belt if the Black Country's economic strategy and the WMCA SEP ambitions are to be met.
Q54. Do you agree that the current approach in Policy EMP4 is no longer fit for purpose and should be amended to reflect a portfolio based approach? Yes/ No. If no, what alternative approaches would you recommend?
2.22 As per our response to Q1, a full review of the BCCS is essential to ensure the plan is prepared in the current planning context, all policies are consistent with national planning policy and it comprises a strategy that will deliver against identified needs. Policy EMP4 is therefore no longer fit for purpose and should be replaced within the emerging BCCS Review.
2.23 Also, as explained in response to Q50, the replacement policy should reflect the nature of different employment sites, in particular highlighting the different roles performed by strategic high quality or local quality employment areas and responding to the requirements of modern industry (which will be the subject of further study).
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3. Conclusion
3.1 IM Properties Limited welcomes the opportunity to engage with the Black Country authorities in respect to the emerging BCCS Review.
3.2 Since the Black Country Core Strategy (BCCS) was adopted in February 2011, the West Midlands Regional Spatial Strategy has been revoked and the National Planning Policy Framework has been published, representing a significant change in the planning policy context. The Black Country's ambitious housing and employment needs are now much greater, and the area has not been meeting the targets set out in the BCCS. A full review of the Plan is therefore necessary to ensure it is robust and meets the requirements of national planning policy.
3.3 In meeting the proposed level of growth, some Green Belt release will be necessary. It is important that this review takes full account of the needs of modern industry and updates the evidence on strategic employment land requirements.