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?

Dear Sir or Madam,

As residents of Halesowen, my family and I strongly object to the proposals made in the Black Country Core Strategy. Development of residential (22,000) and industrial property on and near to green belt land is outrageous, especially when so much 'brown' land is available due to the industrial heritage of the Black Country.

It seems the Black Country Core Strategy is ill thought out. How can it be cheaper to put in all the infrastructure needed to support such growth on Green Belt, as compared to the clean-up of brown sites for development which already have that surrounding infrastructure?

My family and I would like to see a proper cost benefit analysis done giving consideration to the above.

If allowed to go ahead thoughtlessly, our beautiful country side (Clent Hills, Illey, etc) and its nature will be lost forever - an ecology disaster.

I look forward to hearing your response to this objection detailing just what can be done to avert this terrible loss to future generations.

Kind Regards,

Mrs Shingler

Black Country Core strategy issues and options representations from CCDC

Please see attached the representations of Cannock Chase Council to the Black Country Core Strategy issues and options consultation.

I would be grateful if you could confirm receipt

Kind regards

Black Country Core Strategy
Issues and Options consultation July - September 2017
Response of Cannock Chase Council
Thank you for consulting Cannock Chase Council with regard to the first stage (Issues and Options) of the Black Country Core Strategy Review. Responses in relation to those questions of particular relevance to this District are set out below.
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?
This is difficult to conclude at this stage as much will depend on the emerging evidence as is acknowledged in paragraph 1.18. It is possible that some policies may be able to be 'stretched' or even stay the same, but in some cases significant changes may need to be made which could have cumulative impacts including cross-boundary implications, particularly in the light on ongoing work through the Greater Birmingham Housing Market Area (GBHMA) and the LEPS / WMCA.
It is noted that paragraph 1.27 (and 4.34) allows for sites to be put forward (via the Call for sites process) which lie within other authorities but adjoining the Black Country to enable cross boundary discussions to take place. As stated in paragraph 1.27, those sites would need to also be submitted to the relevant authority within whose boundaries the site lies (either all or in part) as these would also need to be considered thorough the Local Plan process for the authority in question. In these instances discussions would need to be had through the Duty to Co-operate in in the context of the emerging evidence base, ongoing strategic work as referenced above, and through any appropriate local plan reviews.
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? 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.
The impression is given on page 19 that the GBHMA study primarily relates to Green Belt but its scope is wider than that and the table should reflect the full scope of the study.
The above mentioned study includes landscape assessment which complements, but is a separate assessment to the Green Belt work. However, given the cross boundary implications, account should be taken of Landscape Character Assessment at the more localised level where such evidence exists. Cannock Chase Council has published (and updated) its Landscape Character Assessment so this will need to be given due consideration as work on the plan moves forward, as will consideration of other evidence of relevance such as that relating to the historic environment / landscape and setting. Further discussions on these matters would be welcomed as the detail of the plan starts to emerge.
Further discussion will be needed on transport to ensure that the full evidence base and most up to date situation is considered in relation to the appropriate stage of the plan.
It should also be noted that the evidence base on Cannock Chase SAC is in the process of being updated and so the Black Country authorities will need to continue to engage (as they currently are doing) in this process via the Cannock Chase SAC partnership. This is covered under key issue 5 and also in paragraph 3.61 but needs to be cross referenced to the evidence table.
Discussions are also ongoing in relation to the Cannock Extension Canal SAC and also the restoration of the line of the Lichfield and Hatherton canal and it is possible that further evidence may be required in relation to this and the advice and guidance of Natural England will be essential as the plan progresses, particularly if there are cross boundary implications from the emerging plan so dialogue under the Duty to Co-operate will need to be ongoing (again as already is the case).
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?
Paragraph 3.18 references the agreement to test the accommodation of an extra 3000 homes up to 2031 beyond local need to help address the shortfall in the wider HMA, however this will need to be considered in the light of the emerging evidence base in the GBHMA so the situation needs to be kept under review.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt review?
Yes, as this picks up the higher tier work which is ongoing at the GBHMA level, however discussions will need to be ongoing under the Duty to Co-operate in relation to more localised work to ensure alignment and consistency where there are cross boundary implications: Cannock Chase Council published its own Green Belt assessment in 2016. Comments submitted under Question 1 are reiterated here in relation to the Call for Sites process.
Green Belt options should not only be considered in terms of their suitability (or not) for development but also whether they can play a role in being utilised more effectively in terms of a Green Infrastructure network which can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) which can enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale. This should be explored further, in conjunction with partners across the HMA as work on the plan progresses.
Question 7: Do you think that the Core strategy vision and sustainability principles remain appropriate?
In principle, yes, however as set out in the response to Question 1 this will need to be kept under review in the light of the emerging evidence base. Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale.
Question 8: do you think that the Core Strategy spatial objectives remain appropriate?
In principle, yes, however as set out in the response to Question 1 this will need to be kept under review in the light of the emerging evidence base. Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale (potentially including that which may impact on the Cannock Chase SAC).
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?
In broad terms, yes although this will depend upon the detail of the emerging evidence (and see response to Question 1). Green Belt policy will need to be reconsidered however as new defensible and permanent boundaries may need to be set through this process.
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? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities eg proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
Firstly, there would need to be clear and justified evidence that the Black Country has explored every reasonable opportunity to deliver as much development as possible within its own boundaries so this will depend upon the evidence which is still underway. Secondly, any shortfall relating to the Black Country should be considered 'in the round' ie not just in terms of those areas which have a direct boundary with the Black Country but as a whole as per the evidence base which is currently being prepared across the GBHMA (which will also avoid the risk of any double counting).
Earlier questions have raised the matter of the Call for Sites potentially covering cross boundary options including sites in neighbouring districts and our response to questions 1 and 5 should therefore also be noted here.
Should export of growth be required, close working will be required to ensure sustainable development and alignment between the BCCS and neighbouring plans.
Question 19a / b - do you support Spatial Option E4? Should any factors be taken into account in an assessment of the opportunities?
Please see answer to question 15a.
Questions 26 / 27 and 28: Infrastructure
As the plan progresses, further discussions will be required on infrastructure issues depending on which sites / options are to be looked at further, as there may well be cross boundary implications which need to be addressed.
Questions 32 / 33: Health and Wellbeing
The role of sport and recreation could be strengthened (figure 10) as could the role of Green Infrastructure in providing for a range of needs.
Question 38: do you think that the current accessibility and density standards are appropriate for Green Belt release locations? If no, what standards should be applied in these locations and why?
As the adopted strategy does not allow for Green Belt release, presumably this means those standards set out in policy HOU2? Not all Green Belt sites will be the same as their context will vary on a case by case basis, and while the current policy allows for this to some extend further discussions will be needed in areas where there are cross boundary implications to ensure consistency between local plan approaches.
Question 49a: is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
Employment policy needs to be brought up to date to reflect the NPPF. Given the pressures on the need to find enough sites for housing poorer quality employment sites which are no longer fit for purpose should be considered for housing needs where appropriate and sustainable to reduce pressures elsewhere.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in policy EMP1? Do you think that distinguishing between Strategic high quality Employment Areas and Local Quality employment Areas is still appropriate?
The Core Strategy needs to reflect current national policy and guidance. As the plan (and evidence base) moves forward, delivering any net uplift (as per paragraph 6.58) will need to be explored further. As with housing, growth may well have strategic and cross boundary implications and further dialogue will be needed as the plan is developed.
Question 55: do you agree with the proposal to retain Policy EMP5?
Yes, it is important that the developers / owners of major new job-creating developments contribute to the recruitment and training of local people, which could also have cross boundary implications and benefits.
Question 56: Do you agree with the proposal to update Policy EMP6 in line with current priorities?
Yes. By promoting and enhancing the range of facilities within the Black Country it will provide visitors and residents with a range of activities which may reduce the pressures upon other, sensitive environments which are a draw for tourism, including the Cannock Chase SAC.
Question 74: In the context of the 'centres first' strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of strategic, town and local centres?
Yes - this approach is appropriate and consistent with the NPPF where supported by evidence and is designed to protect the vitality and viability of town centres which also has cross boundary implications.
Question 81: do you agree that the approach of strong control over out of centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Country Centres?
Yes - see answer to Question 74. This does not just relate to the vitality and viability of Black Country centres but also has implications beyond the Black Country.
Question 88: do you agree that the overall transport strategy supports all of the Core strategy spatial objectives? Together with questions 89 (proposed changes to the priorities for the transport network), 90 (changes relating to managing transport impacts of new developments), 91 (the efficient movement of freight), 92 (network for walking and cycling) and 93 (changes to Policy TRAN5 - travel and travel choices)
The transport implications of the plan will have far reaching consequences beyond the boundaries of the Black Country. Cannock Chase Council continues to engage proactively with a range of partnerships dealing with transport issues and will continue to do so as the detail of the plan progresses.
Re: Policy TRAN1 - Priorities for the Development of the Transport Network
Question 89 - Do you support the proposed changes to the priorities for the development of the transport network? Yes/No; Please explain why.
Reference should be made to completion of the £100m, Walsall-Rugeley, Chase Line electrification/linespeed upgrade, which will lead to faster and more frequent services north of Walsall to the west Coast Main Line at Rugeley Trent Valley. The route will also provide an alternative diversionary route between Birmingham and Stafford for long distance passenger and freight services, when the Birmingham-Wolverhampton-Stafford, Stour Valley route, is closed for maintenance.
Reference should be made to the future ownership of the M6T and also the future role of the parallel A5T, which has a dual carriageway section through the Walsall MBC area at Brownhills.
Reference should be made to the Chase Line Station Alliance
* Network Rail and WMR is developing an innovative 'Stations Alliance', which, together with Abellio, the new West Midlands franchise operator, is hoped to bring about substantial improvements to West Midlands rail stations.
* The Alliance has created a WMR Stations Vision so that they are instantly recognisable in the areas which they serve and also integrate properly into the community.
* Stations should act as 'Gateways,' with quality infrastructure and more facilities such as shops.
* Network Rail are only funded to maintain stations to CP3 standards and 7-9 year franchises, do little to incentivize operators to invest in stations.
* Funded by Black Country and Stoke and Staffordshire LEPs and West Midlands Rail work is already underway to develop some indicative Master Plans for two trial routes - the Stour Valley Line from Birmingham to Wolverhampton (exclusive) and Chase Line stations north of Walsall.
* Options for funding the works will also be considered as part of a commission, which is due to be completed by Autumn 2017.
* GHD consultants have been appointed and site inspections of all stations carried out on with the consultant and local authorities, was in June.
* The study is in two stages:- Stage 1 is to confirm the projects for outline development. It is anticipated that this stage will result in a shortlist of projects for further development.
* Stage 2 will develop outline a master plan for each of the prioritised stations from Stage
WMCA Transport Delivery Committee endorsed this approach on 3 April 2017.
Re: Policy TRAN3 - The Efficient Movement of Freight
Question 91 - Do you support the proposed changes relating to the efficient movement of freight? Yes/No; If no, please explain why.
R: Reference should be made to the proposed Mid Cannock road/rail interchange proposal by Pentalver. The facility would have the potential to be served by between 4 - 6 freight trains a day and serve the Black Country area.
Question 94: do you support the proposed changes relating to environmental infrastructure and place making?
Whilst already covered via policy CSP3 of the 2011 strategy, the role of Green Infrastructure could be strengthened through the new plan, particularly (but not exclusively) in relation to the Green Belt as it can serve a wide range of purposes (enhanced biodiversity, sport and recreation uses for example) to enhance quality of life and potentially mitigate for the impacts of development on both a local and strategic scale (potentially including that which may impact on the Cannock Chase SAC).
Question 96: Do you support the proposed changes relating to nature conservation?
The plan will need to ensure it takes into account any cross boundary implications as set out in the response to Question 2: the evidence base on Cannock Chase SAC is in the process of being updated and so the Black Country authorities will need to continue to engage (as they currently are doing) in this process via the Cannock Chase SAC partnership. This is covered under key issue 5 and also in paragraph 3.61 and potentially a policy may be needed to address SAC issues to align with the approach of other SAC Partnership authorities. The advice of Natural England will also be key to this issue.

Full text is 54 pages. See scanned rep for more detail

Question 1:
Natural England's considers the environmental policies of the existing Core Strategy relatively robust. We, therefore, agree that the partial review should retain much of what is currently in place with regard to environmental policy with improvements, where necessary, to some policies to update these in accordance with new legislation and emerging environmental evidence. Where appropriate, the appropriate environmental policies should also be further strengthened in order to ensure the successful environmental transformation of the Black Country the Plan desires.

Natural England also considers that there should be a greater reference to the importance of the natural environment and landscape-scale green infrastructure (GI) benefits throughout the Plan. The necessary 'Environmental transformation' of the sub-region is indeed one of the core directions contained within the Plan's Vision; this direction and need is only further supported with the emergence of the Black Country Garden City aspirations. The benefits of GI to an urban area are well documented and are crucial to the delivery of high quality sustainable development. It can provide multiple benefits for people and wildlife, for health and well-being, for eco-system services, for the economy. As a result, we would recommend the Plan ensures the GI needs of the sub-region are front loaded as part of development decisions and referenced in development policy, where appropriate.

Question 2:
Natural England is unsure what the 'Strategic Mapping of the Black Country's Natural Environment' is. However, this may refer to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities.

This evidence, in a large part, meets the requirements of the Plan as detailed at paragraph 3.4. Natural England welcomes the planned preparation of a Habitat Regulations Assessment Screening Report at Preferred Spatial Option stage. (para 3.8).

Question 5:

Natural England generally supports the proposed evidence based approach to the Green Belt Review. In order to meet the housing demands of an area we recognise that it is sometimes necessary to release the most appropriate green belt land in order to best accommodate the needs of both the future and existing populations. The Sub-Region , in most parts, comprises tightly constrained built form, however, there are important pockets of valuable green space / infrastructure contained within which perform a variety of important functions for people and wildlife. It is, therefore, important that we ensure future development is planned such that the populations, new and existing, are able to receive the multi-functional benefits of GI which enhance quality of life.

We note the comments of the Black Country Local Nature Partnership (LNP) in response to this question recommending the evidence review is extended across the Black Country and not just the greenbelt. We believe that Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis' will be able to support you in this endeavour. We would advise you contact the LNP for further discussion on this issue as they suggest.

Question 6:
Key Issue 1 - Recommend inclusion of Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis'
For Key Issue 5 - Recommend inclusion of Natural England's 'Black Country Garden City: GI Evidence Base and Pinch Point Analysis'
Natural England welcomes the commitment to make provision for environmental infrastructure (Paragraph 3.35) and looks forward to working with you to help ensure this aim is fully realised.

We also welcome the recognition of the need to abide by the Habitat Regulations (Paragraph 3.38) but note that nationally and locally designated sites are excluded from this section. In consideration of their importance to the Sub region we would recommend reference to their respective value.

We welcome the inclusion of the reference to the Cannock Chase SAC and SAC Partnership and the Council's commitment to the undertaking of a fresh HRA screening exercise for the purposes of informing the Plan.

Question 7:
Natural England disagrees with the principle that brownfield sites will always be prioritised for development and it is our opinion that all sites must be assessed on the same merits regardless of location. Whilst the re-use of brownfield sites is encouraged in the NPPF, Paragraph 111 states that this is only when brownfield sites do not have high environmental value. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some areas of greenbelt. (Comment replicated and aligned with LNP response).

Question 8:
Given that paragraph 1.1 of this document states that one of the three main purposes of the strategy is to direct environmental activity to the right places it is surprising that there is no spatial objective that explicitly allows for the provision of green infrastructure. Environmental Infrastructure is one of the five strategic policies subsequently set out in the document but this would be greatly strengthened if it were backed up by an explicit spatial objective such as "safeguard existing environmental assets and take opportunities to improve environmental infrastructure to support wildlife populations and provide other ecosystem services". (Comment replicated and aligned with LNP response)

Question 11a, 12a, 13a and 13b:
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.

Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development. (Comment replicated and aligned with LNP response)

Questions 16 - 20
As with the spatial options proposed for housing, we would prefer the selection of sites for employment to be undertaken through evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently fully explored in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development. (Comment replicated and aligned with LNP response)

Question 21:
The definition of infrastructure in Policy DEL 1 is broad, including public open space and sustainable drainage but the provision of environmental infrastructure is not mentioned specifically in DEL1 nor Paragraphs 5.1 to 5.6 of this report except to say that environmental impacts should be mitigated. We would like to see the provision of additional environmental and green infrastructure explicitly covered in this policy and the LNP can provide advice and support for this. It is also our opinion that this policy should be no different in greenbelt or urban areas(Comment replicated and aligned with LNP response).

Questions 32 &33:
We would support the continuation of health and well being related criterion being interwoven throughout the various policies of the Plan provided the Council can satisfy itself that this is sufficient in order to secure to positive benefits from such aspirations. We particualrly weclcome the inclusion of Theme 2 - Planning for active lifestyles although it is important to recognise that simply provision of open spaces does not always provide the health benefits we desire. The quality of the open space, the sensory experiences, perceived safety, etc are also critical to encouraging utilisation and hence attaining the community benefits. Much of this comes down to management and manitenance of sites, however, it is also important to consider locational aspects of open space / GI as some existing areas may encourage use whereas others detract.

Question 36:
We disagree with both the assumption that housing densities should be different in greenbelt and urban areas and that there should be a minimum net housing density on brownfield sites. The ecological importance of brownfield sites can equal or greater than in the greenbelt and the need for green infrastructure is often higher in urban areas. The density of a development should depend on the needs of the residents and strategic goals and should therefore be assessed on a site by site basis. (Comment replicated and aligned with LNP response)

Question 38:
Whilst we understand the need for creating space-efficient developments we would like to see each housing application assessed on its own merits to a universal standard. (Comment replicated and aligned with LNP response)

Question 47:
The definition of healthcare facilities covered by Policy HOU5 should be extended to explicitly include the provision of multifunctional greenspace to allow healthy lifestyle choices as identified in section 6.11 of this report. (Comment replicated and aligned with LNP response)

Question 49ab:
Given that the NPPF requires the planning system to contribute to and enhance the natural environment in the pursuit of sustainable development, consideration could be given to releasing land for green infrastructure and nature conservation. This is essential as current evidence indicates that our existing network of designated sites is not sufficient to protect wildlife, that areas of publicly accessible greenspace are essential for our health and wellbeing and provide other ecosystem services often lacking in very urban areas. (Comment replicated and aligned with LNP response)

Question 65, 67, 69 and 72:
Strategic centres also have a role to play in providing access to green open space and providing ecosystem services. Each development should be assessed on its merits , and whilst intensive development may be appropriate in some situations in strategic centres, the need and opportunities for multifunctional green infrastructure should be considered in all locations. This is especially relevant to health and wellbeing if strategic centres are developed such that people both live and work in these centres. (Comment replicated and aligned with LNP response)

Question 94:
We welcome updates of environmental infrastructure requirements based on up to date evidence and recommend reference to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities.
Natural England and the LNP can also provide existing data, advice and support in developing new proposals.

Question 95a:
We refer your authority to Natural England's Black Country Garden City Part A GI Evidence Base & Pinch Point Analysis. This is an interactive Geographic Information Systems (GIS) tool which contains comprehensive and strategic Green Infrastructure (GI) evidence for the Black Country. It comprises detailed and layered social, environmental and economic information overlain with key housing sites data to identify the GI 'Pinch Points' (i.e. where GI intervention in the Sub Region should be prioritised). The GI evidence base considers the location of, and need for, 26 different GI functions across the Black Country relating to the needs of people and wildlife. It can inform both strategically and on a site specific basis as regards the areas greatest GI needs and opportunities. We consider this can align with the emerging Black Country Garden City principles and therefore help usefully inform development decisions towards the Garden City vision. NE is working alongside the Local Enterprise Partnership and is part of the Black Country Garden City Working Group to seek to realise these aims.
We also welcome the Para 6.148 reference to potential inclusion of agreed GCPs into Policy CSP3: Environmental Infrastructure.

Natural England understands the reasons for the proposed removal of the specific criterion relating to renewable energy generation as part of CSP3. However, the importance of such facilities should not be diluted in the Plan and we would recommend other policy support where appropriate.

Question 95b:
The application of the principals will vary on a site by site basis, as the environmental and social needs will vary between developments. The location of the site on brownfield or greenfield land is likely to influence the site specific requirements, but different standards should not be applied on the basis of a greenfield/brownfield categorisation. (Comment replicated and aligned with LNP response)

Question 96:
We welcome the proposed changes that provide additional protection to irreplaceable habitats and to bring the definition of mitigation in line with NPPF to require compensation for residual negative impacts. We further recommend that the proposed additional protection for ancient woodlands is extended to include other irreplaceable features such as ancient and veteran trees. The LNP can provide advice on the most accurate data sets available to identify such features. (Comment replicated and aligned with LNP response)
Natural England also welcomes the proposed inclusion of a requirement for appropriate biodiversity features as part of new development - such as natural green space, use of native planting and nest boxes.
We welcome also the inclusion of a reference to the Black Country Geopark.
Natural England would recommend your authority liaise with the LNP who are able to provide advice towards making this Policy and its application as robust as possible.

Question 97:
We feel that there could be a greater recognition that nature and natural features are an important constituent of place making and local distinctiveness and often have a strong relationship with historic character. (Comment replicated and aligned with LNP response)

Question 100:
Natural England recognises the difficulties that have emerged as a result of the inclusion of local projects ( such as the Hatherton Branch Canal Restoration Project) and whilst generally supports the principle of such initiatives, recognises that difficulties can arisen relating to the viability of such policies on grounds of technical challenges.
Recent discussions between NE and Walsall MBC (WMBC Policy EN4 Hatherton Branch Canal) have concluded that the viability of such projects are best considered at project level. For this reason, NE would support the removal of such initiatives from Core Strategy Policy and supporting paragraphs which, without the evidence to confirm technical viability, the deliverability of which remains in question.
We would add that reference to the supported principle of such initiatives would also be supported, provided the related paragraph made it clear that Council and Policy support would only be forthcoming where the evidence for its viability and deliverability was provided.

Question 101a:
We strongly agree with the principal of prioritising natural SUDs as this provides greater opportunity for SUDs to provide multiple functions and provide biodiversity features. (Comment replicated and aligned with LNP response). Natural England's BCGC Part A GI Evidence Base can assist in this.

Question 102a:
We support this policy but suggest additional clarification and strengthening as discussed in our responses to Questions 102b and c.

Question 102b:
Would recommend specific reference to Natural England's BCGC Part A GI Evidence Base in accompanying paragraphs

Question 102c:
We suggest further clarification on what constitutes open space as the policy does not specify publically accessible open space. We would welcome a definition that extends all sites that have developed nature conservation interest, are used informally for recreation or provide other ecosystem services. Reference again to Natural England's BCGC Part A GI Evidence Base

Dear Sir,

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





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ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
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-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
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Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

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 deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
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?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - 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.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
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?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

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

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?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

Dear Sirs,
This is a covering letter for CPRE's response to the Black Country Core Strategy. This consists of two documents:
* A response to the various questions ('Options response).
* A detailed report on demographic issues ('Housing and Employment Options').
CPRE is a campaigning charity, which is a coalition of a national charity and branches in most counties, which are mostly independent charities. CPRE West Midlands is a regional group of the national charity, whose scope is the West Midlands region.
Our regional chairmanship is technically vacant. As an interim measure, we have agreed a rotating chairmanship, which I currently hold. You may however like also to note the e-mail address of our regional secretary,
Yours Faithfully,
From the Acting Chairman

Black Country Core Strategy Issues and Options
Response for WM CPRE
Sept 2017

Introduction
1. The West Midlands Regional Group of the Campaign to Protect Rural England (CPRE) welcomes this opportunity to respond to the consultation on the Black Country Core Strategy Review and commend the professional nature of the work done by Officers so far.
2. As a charity with about 60,000 members, a branch in every county, over 200 district groups and more than 2,000 parish council members we work locally and nationally to protect, shape and enhance a beautiful, thriving countryside for everyone to value and enjoy.
3. This response was developed with the Staffordshire and Worcestershire Branches of CPRE, who are responsible for monitoring planning in the Black Country.
4. In developing our response we commissioned an independent consultant to
review the economic and housing evidence base and his report is attached.
5. We note that he has concluded that more clarity is needed on the benefits or otherwise of releasing employment land for housing to reach a firm conclusion and we suggest this is work the authorities may want to progress as they move towards a preferred option.
6. We do have some concerns about the wording of the on-line questionnaire, particularly the first two questions. In effect they ask respondents where extra housing and employment land should go as if the quantity of land required was fixed. This is not the case and, to avoid bias, respondents should have been asked whether they agreed with the assumptions about housing and employment need. We hope that this will be addressed in future consultations.

Overarching Comments
7. CPRE is in favour of a continuation of the centres and corridors approach and the ongoing stress on urban regeneration. This, however, has been put under threat by the assumed housing and employment land need.
8. As set out in the attached report we believe there is additional capacity which reduces (or removes) the need for Green Belt housing. We also believe that the level of employment land needed is not as high. There may be some need for larger employment sites, but this needs to take account of land available in adjacent authorities, including (as it stands) all of Four Ashes.
9. In principle we support industrial land which is no longer suitable being used for housing, but this is a complex issue which requires further analysis.
10. We believe it will be as important what type of housing is provided and there needs to be adequate affordable and social housing. In particular there is a need to address directly both accommodation for the elderly, whose numbers will dramatically increase, and housing for young people who are struggling to enter the market.
11. We are concerned that a review of Green Belt appears to be being driven solely by numbers, rather than by policy considerations and that allocations in the Green Belt could undermine urban regeneration.
12. We are in favour of strong policies to support centres, but these need to be framed within a changing environment where some centres may need to shrink or diversify to meet future needs.
13. We want to see a dramatic improvement in public transport provision which supports the regeneration of the Black Country.
14. We also believe more consideration should be given to air pollution, both from
transport and other sources. The issue with diesel cars has increased the awareness of this and yet it is appears to be only obliquely addressed in the strategy.
15. Lastly, the strategy needs to continue the strong emphasis on environmental improvement, including developing the Garden City idea, and it needs to acknowledge the value of the countryside within the Black Country's boundaries.

Responses to Individual Questions

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?

Yes, we agree that a partial review is appropriate. However, we are concerned that some elements are being dealt with out of context with the wider conurbation. In particular, while accepting there may be a need for some larger high quality employment sites across the Combined Authority Area, the basis for this would be wider than the Black Country. Sites such as Peddimore are already going ahead, and we do not believe it would be helpful to over-allocate competing large sites, which would lead to loss of Green Belt and might not be fully occupied.

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.

Yes, the evidence does provide a basis for the review. However, we do not fully agree with the conclusions drawn on housing and employment land as set out in the attached report. This impacts on our response to later questions. We cannot comment on the Green Belt review as it stands since we do not have details as yet.

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.

No, we do not, as is set out in the attached report. In particular we are concerned in supply terms about the double counting of homes resulting from the market uplift identified in South Staffordshire, the questionable need to provide for under-provision from 2011 to 2014, especially as there was over provision in 2015 and no adverse market signals in those years except in South Staffordshire where there was over-provision. Furthermore the Oxford Economic Analysis which, unlike SNPP, allows population migration based on relative economic success, suggests that, even under the most fortuitous circumstances, that is to say delivery of the SuperSEP, some 6,000 households will migrate out of the conurbation beyond those accounted for in the SNPP figures. Since Oxford's Economic Analysis is being widely relied on, this hypothesis should be further tested.

There is a further problem with the trend analysis because it relies on Unattributed Population Growth which SNPP does not. Further analysis should be done discounting UPC, which results from a variety of causes but may not be indicative of the future to reach a reasonable view on likely housing need.

This is particularly important because, while the majority of household growth comes from aging households, about a third comes from migration. We cannot be sure international migration rates will stay as high in a post-Brexit world while out migration to other parts of the UK may continue unabated.

In terms of the supply we cannot identify reasons to disagree with the position taken except in relation to large windfalls and current industrial land. It is clear that many current industrial sites, if they became vacant, would not be considered suitable for industrial use and become housing sites. In other words there is a large pool of potential windfall sites. The assessment of existing industrial land potentially suitable for housing seems to vary across the four boroughs but is clearly very substantial. In other words, even if the policy to release industrial land to housing is not taken forwards, sites will come forward. That being the case the local authorities should, in our view, be less cautious in their approach to large windfalls and assume a continuation at current rates.

Without including additional industrial land these factors could still add up to some 12,500 more homes available than is being suggested and substantially reduce the supposed deficit.

It also is important to understand these factors, because put together all these elements could mean the proportion of elderly people in the population was higher than currently envisaged making the type of housing created even more important.

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.

No, we don't. There is a broad range of figures for future employment need. Much of what is needed for smaller sites can be found based on the available employment land, even assuming the current trend continues. In terms of larger sites the EDNA identifies a need for larger sites, with none currently available over 20 hectares, (although the extension to i54 in South Staffordshire would fulfil that requirement.) To meet SuperSEP requirements it suggests there is a need for roughly 300 hectares of land not currently identified, the majority for logistics. It then discounts 170 hectares of land out of 270 has total at the Four Ashes site for no obvious reasons since it is clearly within the area and would serve the Black Country. This might leave 130 hectares but even that has to be seen in the light of the SuperSEP as a wider strategy, which includes large sites such as Peddimore in Birmingham.

In our view there may be a need for a very limited release of sites over 20 hectares across the SuperSEP area and these are unlikely to be found in the conurbation but, the result of releasing very large amounts of Green Belt land in the Black Country and competing with Four Ashes, Peddimore and other existing business parks and logistics sites, (both in the West and East Midlands,) is likely to be both oversupply and underused sites, which would severely harm the countryside and encourage unsustainable patterns of travel.

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?

No. The approach to the Green Belt review is consistently wrong. It is identified as being solely to identify enough land to meet the housing and employment figures in the SHMA and EDNA. But this does not justify exceptional circumstances.

The NPPG guidance is clear:

However, assessing need is just the first stage in developing a Local Plan. Once need has been assessed, the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as green belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need.

In other words, even if both the OAN is correct and the housing supply figure is correct, which we question (see answer to Question 2), the Green Belt review should not simply identify land to meet that need, it should seek to establish whether the level of land provision should be lower that the OAN because of the constraint of Green Belt.

In other words, Exceptional Circumstances should only be established if there are strategic justifications for the releases.

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?

We agree with most of them. We do not agree with the assumed figure for housing or that it is 'inevitable' that Green Belt will have to be released. That is a policy choice which needs to be assessed taking account of the high level of proof for 'exceptional' Green Belt release.

The key issues do not address the social impacts of the Core Strategy adequately and in particular fail to place sufficient emphasis on the housing needs of an aging population, which is clearly evident in the demographic evidence.

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 supported the principles of the Black Country Core Strategy. In particular we supported the emphasis on urban regeneration and the importance of environmental improvement and enhanced public transport provision to deliver an area people wanted to live in. We also supported the principle of Corridors and Centres. There is a serious risk in our view that the approach to housing and employment land, driven by theoretical numbers rather than strategy, will undermine this approach and rather than lead to improved delivery will export housing and employment into the Green Belt, encouraging unsustainable patterns of development.

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, they should be retained and updated. Their aspirations need to guide the approach to current needs. They should not be diluted.

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?

We do not have any examples to give.

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?

Even if we accepted the figures we do not believe the evidence is good enough yet to make a fully informed choice. Further work needs to be done in the development of the Preferred Option to identify consistently how much employment land might be available across the boroughs and how likely it would be to remain in employment use. This work needs to come to conclusions as to the relative benefit of either use, so that a realistic figure of land that would be better in housing use can be produced. One important element in achieving this will be to ensure there are up to date registers of brownfield land for all the authorities.

Prior to that we favour an approach somewhere in the middle, albeit we do not believe the need for Green Belt release is likely to be as high as is being claimed.

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.

We have no sites we can comment on.

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.

We do not have a categorical view on either option, although it is important that both are considered on their merits and it may be the choice varies from location to location. While some small sites at the edge of the conurbation may have less impact on the aims of Green Belt, they can represent important community assets, they may have wildlife value and they may act as important Green wedges into the city. On the other hand SUEs can be highly intrusive and may not be close to existing transport networks. We would, therefore, suggest both are considered as options, should such land be needed, and that the criteria for sites should have strong ecological and transport elements as well as addressing the purposes of Green Belt.

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).

We have no sites to offer.

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.

See answer to Question 12a.

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

Clearly it depends on size but access to services would be critical, as well as access to transport. Larger SUEs may be more at risk of poor connectivity so that would need to be addressed both in location and in terms of ensuring the internal design supported sustainable transport.

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?

We have no sites to offer.

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?

Yes, if SUEs are developed there should be policy guidance in terms of tenure and infrastructure. In particular there should be identified provision for older households and their needs should be considered in the overall master-planning as well as affordable housing for young people. Furthermore, such master plans should be given force as planning documents by being adopted as Area Action Plans. This is particularly important where a SUE is involves multiple owners.

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

We have none to offer at this stage.

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?

In most cases exporting homes is likely to exacerbate problems in other Local Authorities. However, where OANs in neighbouring authorities have been increased on the basis of migration trends, and those trends rely on migration from the Black Country, it may be that some of those OAN figures should actually be deemed to reduce need in the Black Country, thus avoiding double-counting.

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

We have none to offers at this stage.

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.

It depends how far out the export is.

Question 16 - Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access)

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

Assuming land is needed, we do not support any one of these options in particular. The approach should be varied according to the landscape and transport impacts, as well as Green Belt aims. It will be important that any sites which are released are not just justified by numbers but serve a strategic need for the sub-region. This may mean restricting such releases to sites over 20 has.

Question 17 - Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links?

See Question 16. Rail Access should be important in this case and access to public transport for employees.

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

We do not offer any sites.

Question 18 - Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access)

See Question 17.

If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

See Question 17.

Question 19a - Do you support Spatial Option E4? Yes/No; Any further comments?

See Question 17.

Question 19b - Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country)

See Question 17.

If you think there are any potential locations that should be considered, please provide details.

See Question 17.

Question 20 - Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.

See Question 17.

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.

We do not have any suggestions to offer at this stage.

Question 22 - Do you have evidence of a requirement for new social infrastructure to serve existing needs?

Yes/No; If yes, please provide details of the type of facility and where it should be located.

Not at this stage. But note our concern about the aging population who will have specific needs.

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

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 24 - Do you have evidence of pressure being placed on the capacity of current social infrastructure which could be exacerbated by new housing? Yes/No;

If yes, please provide details.

Not at this stage. But note our concern about the aging population who will have specific needs.

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

Not at this stage. But note our concern about the aging population who will have specific needs.

Question 26 - Do you have any evidence of a requirement for new physical infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

See our later comments on transport infrastructure.

Question 27 - Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.

The rail network is under considerable pressure with lines such as the Chase Line carrying large increases in passengers. New development outside the conurbation could exacerbate this. There are issues of parking, for example at Stourbridge Junction, where it has reached capacity restricting passenger growth on that line. A balanced approach to the provision of car parking and public transport access is needed to ensure rail growth is maximised.

Question 28 - Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?

Yes, all types.

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.

No comments at this stage.

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.

Green Belt sites inevitably compete with brown field sites. One of the purposes of Green Belt is to support urban regeneration. We do not believe the need for Green Belt sites is as great as anticipated, but (if they are designated) phasing should be used to control how much land comes forward at once, thus supporting urban regeneration.

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?

No comment at this stage.

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

We welcome the use of health impact assessments of the strategy. We would like to see a strategy to increase the health of the population from cradle to grave, which would include encouraging access to open space and the countryside for all members of the community and improving walking and cycling provision and take up.

We are less convinced of the reliance on sustainability appraisals for new sites, particularly large scale Green Belt incursions. SAs are likely to assume some sort of development will go ahead at the site and then seek the best option. SAs are useful in terms of how individual sites are developed but are not designed to answer the question: is releasing the site at all necessary or desirable?

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?

There are a whole range of interventions which are needed to improve health and well being. The Garden City approach, with its emphasis on environmental improvement and enhancement, is one element. Providing improvements to sustainable transport modes is another key element. Addressing the quality of existing housing stock is also needed. Providing local facilities, for health, education and leisure is also key and ensuring these are accessible to all.

There is also a need to specifically address the needs of the increasing number of older people. This includes policies to ensure there is adequate supply of housing which is suitable for older people in locations where they have access to facilities. This will also reduce the prevalence of loneliness and other health issues among the elderly.

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?

Yes, provided there is a proper assessment of alternative approaches rather than just how to deliver the site.

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

In terms of detailed design, environment, permeability and access to public transport are key. There is also a need to ensure enough housing is with design features for those less able.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.

We support the reduction in the discount figure. We support a windfall allowance, although, as set out above, we believe the level of larger windfalls should assume a continuation of current trends. Consideration of how to achieve more mixed used development in centres and a reduction in vacancy rates should also be considered.

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?

Table 8 is useful but, given the issue of an aging population, the table should also include a provision for housing which is designed to meet that specific need.

We would support an increase to 40 dph, provided there was flexibility for sites where environmental or local character meant that was not appropriate.

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

We are content with 15 homes but the policy needs to require all developers to establish that they have sought to use land in an efficient way, even under 15 homes.

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?

While we are content with 15 homes the policy needs to require all developers to establish that they have sought to use land in an efficient way. If that is not deemed practical it may be worth reducing it to 11 homes.

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?

We do not believe that Green Belt sites should have lower access standards. It is important that the inevitable impacts on sprawl and sustainability are mitigated by the provision of local facilities and by the use of good urban design. In particular, Green Belt developments have typically been poorly designed for public transport accessibility and walking and cycling. However, whatever standards are implemented, local character and environmental considerations must also be considered.

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.

There is a need to ensure housing for the elderly and the disabled is fully accessible and takes account of the deterioration in mobility that may lead to people being unable to stay in their own home. However, this might be better resolved with a separate policy which sets out the requirement for housing for the elderly, along with the criteria for ensuring that meets their needs.

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.

They can assist but the need is not only to identify how many houses with a particular number of bedrooms but to ensure new housing is provided to meet specific needs, such as the increase in older residents and the need for affordable homes for young people.

Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:

Yes, a policy is required. This could help in a modest way to ensure small windfall sites come forward for development.

Question 41b - A target for each authority? Yes/No; Any further comments

We do not have a view.

Question 41c - A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?

We do not have a view.

Question 41d - Another approach altogether? Yes/No; If yes, please specify.

We do not have a view.

Question 41e - Do you support the use of a variety of local approaches to Houses in Multiple Occupation (HMOs) across the Black Country? Yes/No; If no, please explain why.

This is an issue in some areas of the Black Country, which can undermine an area if there is not the infrastructure to support HMOs. Not only can it lead to traffic congestion, it can overwhelm local health and education provision. Some HMOs appear to be of poor quality and not necessarily managed in a way which benefits the local community. As we understand it Local Authorities have powers to require planning permission where there is a problem with HMOs. While, it is probably not for the Core Strategy to be prescriptive it could refer to those powers.

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.

Yes, we agree there is a need for sufficient affordable homes.

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

We are concerned about the way in which thresholds work. If the threshold is 15, it encourages developers to bring forward schemes for 14 houses, so that they do not have to comply with the more onerous requirements above the threshold. Where there is an affordable housing requirement of 35% (and some councils are managing 40%) affordable, and the threshold is 15, the developer of a 15-house site will have to provide 5.25 affordable houses, but the developer of 14-house site will provide zero. Since affordable houses are less profitable, the threshold provides a perverse incentive not to build affordable houses. Given the need a lower threshold might be desirable, (always taking account of local character.) and this would be in line with NPPG but we would like to see consideration of how to ensure affordable homes on smaller sites.

Question 43b - If no, should it be reduced to 11 homes or more? Yes/No; If no, what threshold should be used?

Given the need a lower threshold would be desirable, taking account of local character. This seems to be in line with NPPG. We share the concerns expressed in the Preferred Option that an increase in the provision of starter homes which are not genuinely affordable may impact on other affordable tenures and would welcome work to try and address this issue within the current regulations.

Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site?

Yes /No; Any further comments?

Consideration needs to be given to the location of the sites. See answer to Question 45.

Question 44b If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?

Consideration needs to be given to the location of the sites. See answer to Question 45.

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.

Yes, we would support this provided those Green Belt sites were also designed to be in sustainable locations with good access to local facilities as affordable housing is likely to be needed disproportionately by people with mobility issues or without access to a car.

Question 46 - Do you agree with the proposed new gypsy, traveller and travelling showpeople accommodation targets? Yes/No; If no, please explain why.

Gypsies and other travelers are as entitled to a home as much as the settled community, but the location of their sites should be subject to the same criteria as for the settled community. The frequency of recent incursions on to public and other open space suggests there is a significant unmet need, which ought to be met. We are not able to comment on the specific figures but agree that sufficient sites need to be supplied to avoid illegal encampments. No Green Belt sites should be released unless exceptional circumstances can be proved.

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.

Yes, there is a need to address the availability and funding of all relevant facilities. There is a need to identify in this policy the impact of provision of housing for the elderly so that locational decisions on facilities are taken in the light of where the less able may be living.

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.

We support the current policy.

Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.

Yes. Since employment land may become vacant that is not allocated and there is a need to examine its potential for release for housing and balance the benefits of alternative uses. In some cases these may not be housing. It may even be the land would be better used for open space or nature conservation. Perhaps the policy should allow for that.

Question 49b - 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.

See answer to 49a

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.

The overall provision of employment land may not be as relevant as the changing nature of jobs today means they are less dependent on land allocations. If land goes out of employment use because a factory closes, for example, it may not be as important to replace that land as to provide the kind of sites needed for new jobs.

Do you think that distinguishing between Strategic High Quality Employment Areas and Local Quality Employment Areas is still appropriate? Yes/No; Please explain why.

Yes, provided the Black Country is seeking to improve the quality of existing sites and not simply relying on new allocations.

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?

We do not have a view at this stage.

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?

We do not have a view at this stage.

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?

Yes, we support this approach. High Quality land should not be squandered, both because it is needed to high quality jobs and because it can lead to environmental and countryside impacts if it has to be replaced

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 agree that a balanced portfolio is likely to be a better approach.

Question 55 - Do you agree with the proposal to retain Policy EMP5? Yes/No; If no please explain why.

Yes.

Question 56 - Do you agree with the proposal to update Policy EMP6 in line with current priorities? Yes/No; If no, please explain why

Yes.

Question 57 - Do you support the proposal to merge Policy CEN1 and Policy CEN2, given that both policies focus on the overall strategy in the Black Country, including the hierarchy of centres? Yes/No; If you have any comments on Policies CEN1 and CEN2 please provide details.

Yes, provided the emphasis is retained and not diluted.

Question 58 - Do you think there is any evidence to suggest that the hierarchy of centres is not appropriate going forward in the context of the regeneration strategy? Yes/No; If so, please provide details.

No. Depending on where new housing goes there may be a need for additional local provision but the main four centres should remain the backbone of the spatial strategy.

Question 59 - Have all the appropriate centres within the Black Country been identified? Yes/No; If not, please specify additional centres.

Yes.

Question 60 - Is there evidence to suggest that identified centres are no longer performing as a centre or at their identified level in the hierarchy? Yes/No; If yes, do you agree that they should be moved / removed within or out of the hierarchy?

No.

Please explain why.

Question 61 - In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments

No. Depending on where new housing goes there may be a need for additional local provision but the main four centres should remain the backbone of the spatial strategy.

Question 62 - Do you agree that the Strategic Centres should remain the focus for large scale comparison retail (clothes, white goods etc), office and major commercial leisure development in the Black Country? Yes/No; Any further comments?

Yes, as well as seeking to increase housing provision within and close to those centres.

Question 63 - Do you agree that the targets for comparison retail floorspace and office floorspace should be revisited as part of this review to take into account current and future trends? Yes/No; Any further comments?

We are not able to give a detailed response but in general we consider that the policy should encourage a balance of development in the centres so they are attractive places to visit which serve a variety of needs. This may even mean a reduction in retail and an increase in leisure. It is probably as important to consider the quality of the retail offer and ensure anchor stores remain or are introduced.

A key element in the future of the main centres (and smaller ones) will be masterplanning to ensure there is a balance of provision. The introduction of a variety of uses will help centres to thrive. It is probably not for the Core Strategy to be too prescriptive but it should also not assume the pattern of retail will remain the same.

Question 64 - Is there a need to set targets for convenience retail floorspace in the Core Strategy? Yes/No; Any further comments?

We are not able to give a detailled response. A balanced approach is required and in some cases it may be better to reduce retail floorspace on the edge of centres to encourage a balance of uses. In particular the role of larger supermarkets may change in the future and require less land allowing for more mixed use on those existing sites and the introduction of smaller convenience stores.

Question 65 - Should the Core Strategy set any targets or policy requirements for leisure development in the Strategic Centres? Yes/No; Any further comments?

The strategy should encourage leisure facilities to be located in centres where they are accessible to all. This should include night time facilities as long as there is suitable planning to avoid and manage any anti-social behaviour.

Question 66 - Should the Core Strategy set new housing targets for the Strategic Centres through the review? Yes/No; Any further comments?

The strategy should encourage housing in centres. It should not only consider how much is needed but what kind of housing will best support those centres and, more widely, the overall strategy. For example, encouraging young entrepreneurs or professional workers to move into the centres may be key to developing the future economy more widely. In general we would like to see more use of upper stories over shops for housing.

Question 67 - Do you think there are any other uses and/or developments that should be planned for in the Strategic Centres? Yes/No; Please provide details.

There is a need to encourage the greening of centres, including provision of trees and other green features which have been lost in many. Their links to local green space, (for example Walsall Arboretum,) should also be promoted.

There is also a need to ensure centres are walkable with access to centres by sustainable modes from surrounding areas encouraged.

Question 68 - Do you agree with the proposal to re-examine the detail and appropriateness of the existing conditions for retail growth at Merry Hill through the Core Strategy review? Yes/No; Do you have any further comment to make on this issue?

We support the current conditions.

Question 69 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country Town Centres? Yes / No; Please explain why.

Some flexibility is desirable provided it leads to a balance of uses and especially improves the quality of the centres.

Question 70 - Do you think there are any specific developments or uses that should be supported in any particular Town Centre? Yes/No; Please provide details.

We have no examples.

Question 71 - Should the Core Strategy set housing targets for the Town Centres? Yes/No; Please explain why.

Yes, the core strategy should seek housing within town centres but these might exceed any targets.

Question 72 - Should more types of uses be encouraged and more flexibility be allowed to ensure the regeneration and vitality of the Black Country District and Local Centres? Yes/No; Please explain why.

This will vary from centre to centre and some flexibility is required. In particular the contraction of the retail area may in some cases create a more viable centre, both by allowing for housing in the centre and other uses which may attract people to the centre, but it must still be able to accommodate sufficient retail needed to perform its function.

Question 73 - Are there are any specific developments or uses that should be supported in any particular District or Local Centre? Yes/No; Please provide details

We have no examples.

Question 74 - In the context of the 'centres first' strategy, should the threshold approach be reviewed to consider the appropriateness, scale and impact of development in and on the edge of Strategic, Town, District and Local Centres? Yes/No; Please explain why.

We support the threshold approach but have no comment on individual levels.

Question 75 - Should thresholds apply to all main town centre uses (Yes) or just retail uses (No)? Please explain why.

There is a case for considering thresholds for some leisure uses where these impact on other centres.

Question 76 - Is the approach set out in Policy CEN6 appropriate in the context of supporting local community needs? Yes/No; Please explain why.

Yes, it remains important to provide local facilities.

Question 77 - Does the wording of the criteria clearly achieve the objectives of the centres strategy? Yes/No; Please explain why.

Yes.

Question 78 - Should the policy clarify that this policy applies both to applications in edge-of-centre and out-of-centre locations, and should this also be referred to in the relevant centres policies? Yes/No; Please explain why.

Yes.

Question 79 - Should the policy set what types of uses this policy applies to and set out any further types of material considerations that could be relevant for the determination of certain proposals, for example, the location or concentration of hot food takeaways, premises selling alcohol or gambling operations? Yes/No; Please explain why.

Yes, this is important as the aim is to provide day to day facilities which support the community.

Question 80 - Should the policy clarify that those schemes of multiple units, where individual units are below the set figure, but the cumulative figure is above, also need to meet the relevant requirements of other centres policies? Yes/No; Please explain why

Yes.

Question 81 - Do you agree that the approach of strong control over out-of-centre development is still appropriate in the context of the strategy to ensure the vitality and viability of the Black Country Centres? Yes/No; Please explain why.

Yes, large out of centre retail is not likely to be sustainable and will not provide access for all parts of the community.

Question 82 - Is 200sqm (gross) an appropriate scale of development above which the impact tests should apply? Yes/No; Please explain why.

We do not have a view on the exact level.

Question 83 - Should Policy CEN7 provide more guidance on accessibility? Yes/No; If yes, please explain why .

Yes, that would be helpful, provided that guidance is to ensure a development is as sustainable as it can be and the guidance is not considered a justification for development in principle.

Question 84 - Do you think that Policy CEN8 is still appropriate for managing car parking in centres and will ensure the network of Black Country Centres are maintained and enhanced over the plan period? Yes/No; Please explain why.

Yes, in general. There is a need to ensure parking serves the whole of centres and to avoid restrictions, for example, of parking to individual supermarkets or leisure facilities which then harms a centre or adds to traffic movements in the centre. We raised concerns when the plan was originally devised that lower parking standards where public transport is poor could encourage developments which were very car dependent in those locations. We remain concerned about this and the review needs to consider the evidence in relations to this and whether parking standards at out of centre locations are tight enough to ensure there is an incentive to encourage use of alternative modes.

Question 85 - Should Policy CEN8, with regards to pricing of car parks, continue to be applied to Strategic Centres to ensure that pricing of parking is not used as a tool of competition? Yes/No; Please explain why.

Yes. And also to ensure car parks serve the whole of the centre and not a single retailer which reduces footfall across the centre and can lead to additional congestion if people park twice. The control of Long Stay car parking, in particular, remains critical to supporting public transport. Short stay car parking should not be so expensive it puts people off visiting a centre.

Question 86 - Do you think that there are other centre uses or centres issues that need to be addressed in the centres policies? Yes/No; Please provide details.

None come to mind.

Question 87 - As shopping, leisure and other commercial trends continue to change, should the revised Core Strategy have a policy to reallocate out-of-centre attractions that are no longer viable for town centre uses for alternative uses such as for employment uses or housing? Yes/No; If no, please explain.

Yes. The Core Strategy needs to consider this as well as anticipating a reduction in store size from major supermarkets and other stores as they refurbish or replenish their estate. In particular where new facilities in a centre reduce the need for out of centre uses alternative uses of those sites may be desirable.

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

Yes, in general we support the strategic aims. However, we do not believe the ambition is adequate in terms of public transport improvements and support for walking and cycling.

As well as on-road provision for sustainable modes we would support extensions to the network of Green Routes offering links into the countryside (including across into Worcestershire and Staffordshire).

We also believe there is still a case to consider demand management options which will support modal change and also fund public transport improvements. However, without ongoing work on this it is hard to be more prescriptive.

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

We generally support the proposals to improve public transport in the sub-region. However, we consider they lack the necessary ambition. In particular we would like to see a rail network developed systematically across the region, including the links centered round Walsall including to Wolverhampton, Sutton Coldfield, Brownhills as well as the through route from Lichfield to Stourbridge. This would require consideration of additional heavy rail lines on the Wednesbury to Brierley Hill section or alternatively Metro extensions along the whole route. We support improvements to the bus network but these need to be integrated with rail. We agree that rail freight should be encouraged but this needs to be at an appropriate level. We are not in favour of the massive Four Ashes Proposal in South Staffordshire.

We are concerned that hard shoulder running is being progressed simply to deal with congestion on motorways with little consideration of the impact of the additional traffic. While this is in many cases preferable to motorway widening we would like to see analysis of the comparative benefits of investing that money in public transport options.

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

The provision of charging points is welcome. However, this does not address congestion issues so it is important that policies to change behaviour are pursued as well.

Question 91 - Do you support the proposed changes relating to the efficient movement of freight? Yes/No; If no, please explain why.

We support the use of Bescot for a rail freight interchange, taking full account of the impacts on local people. We are not in favour of Four Ashes which we consider is too big. We regret the fact that the proposal is being taken through the NIC process rather than being subject to local scrutiny that would examine how well it fits in with the needs of the Black Country and whether its impact on Green Belt, the environment and local roads is acceptable.

Question 93 - Do you support the proposed changes to Policy TRAN5? Yes/No; Please explain why.
In general terms we support the development of a Key Route Network. The development of new technology is also welcome but should be seen alongside encouraging modal shift.

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.

We support the emphasis placed on environmental enhancement and place making. However, CSP3 and CSP4 do not sufficiently emphasise the rural character of parts of the Black Country. Even if there is some development in the Green Belt the environmental policies should emphasise the value of this remaining countryside in terms of landscape, amenity, farming, environmental and biodiversity .

Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?

We support the Garden City approach in general provided a balance is properly applied between landscape, biodiversity and other aspect of the environment.
Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

In general we would like to see the application of similar approaches to density, character and environmental enhancement. However, this needs to be sensitive to local character and landscape which this may influence how specific sites are developed.

Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?

We welcome the inclusion of ancient woodland.

Question 97 - Do you support the proposed changes relating to Historic Character and Local Distinctiveness? Yes/No; If no, please provide details of any other changes that should be made to Policy ENV2.

We support the need to protect historic assets, including those which are not designated. The review should include an assessment of the effectiveness of the current policy in relation to non-designated assets, for example, the integrity of areas of Victorian terracing. This should be used to review these policies and how they can be enhanced.

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 high quality design but are not able to comment on the details.

Question 99a - Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

We support the need to reduce water consumption but are not able to comment on the details.

Question 99b - Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Yes, there is a need to ensure homes are fully accessible, taking account of local character. This will become more important with an aging population.

Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.

Yes, there is a need to ensure homes have adequate space standards, taking account of local character. This will become more important with an aging population.

Question 99d - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.

Not in general, but may depend on local circumstances.

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.

No, we do not understand the removal of reference to canal projects. We agree they need to be determined at a local level, but the reference in the core strategy is important because the network is a strategic as well as a local asset. The policy could be up-dated to acknowledge the fine grained nature of such projects and allow flexibility within a broad approach.

The policy should also add that canals act as an important link between town and countryside in the sub-region.

Question 101a - Do you support the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects? Yes/No; Further comments?

Question 101b - Do you think that any other changes should be made to Policy ENV5? Yes/No; If yes, please provide details.

We are not in a position to comment.

Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain

See 102c.

Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space?

Yes/No; If no, please explain

See 102c

Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes should be made. Yes/No; If yes, please provide details.

We support the need for policies to protect and enhance open space across the sub-region. We believe it should be central to the policy for regeneration.

It needs to also be acknowledged that many open space areas on the edge of the conurbation act as links to the surrounding countryside and are often integral with it. Improvements to open space which have countryside benefits (such as the large scale tree planting creating a country park at the Grange in Walsall) should be encouraged as well as promoting planting in gardens and institutional grounds.

It is also important to stress the need to ensure these areas continue to be managed and not allowed to decay.

Question 103a - 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

We are not in a position to comment.

Question 103b - 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.

We are not in a position to comment.

Question 104 - Do you support the proposed changes relating to Air Quality?

Yes/No; If you think that any other changes should be made to Policy ENV8 please provide details.

Improving air quality is critical to the health and well-being of the sub-region. We have no comments on the detail.

Question 105 - Do you think that Policy WM1 identifies all of the key waste issues that need to be addressed in the Core Strategy, in accordance with national policy?

Yes/No; If not, please specify what changes should be made to the Policy.

If you have any evidence that can be referred to in the Waste Study, please provide details.

We support the approach of aiming to reduce waste and deal with waste within the subregion as close to where it arises as is practical. New or extended waste sites should be assessed on their impact on the landscape and countryside.

Question 106a - Do you support the approach set out in Policy WM2? Yes/No; If no, please explain why.
See 105

Question 106b - Are there any strategic waste management sites that no longer need to be protected? Yes/No; If yes, please provide details

Question 106c - Are there any new sites that do need to be protected? Yes/No; If yes, please provide details.

See 105

Question 107 - Do you think that there are any strategic waste management proposals that should either be removed from or added to the list in Policy WM3?

Yes/No; If so, please provide details.

See 105

Question 108 - Do you agree that Policy WM4 provides an appropriate level of control over the location and design of new waste management facilities? Yes/No;

If no, what changes do you think should be made to the Policy?

See 105

Question 109 - Do you agree that Policy WM5 provides an appropriate level of control over resource management for new developments? Yes/No; If no, what changes do you think should be made to the Policy?

We support the approach of aiming to reduce waste and deal with waste within the subregion as close to where it arises as is practical. New or extended waste sites should be assessed on their impact on the landscape and countryside.

Question 110 - Do you think that Policy MIN1 identifies all of the key minerals issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/no; If no, what changes should be made to the policy?

We do not have a comment at this stage.

Question 111 - Do you agree with the proposed change to 'prior extraction' requirements, to maintain a size threshold in urban areas and increase the threshold for green belt sites to 3 ha? Yes/No; If no, what evidence do you have to justify an alternative approach?

We have concerns about raising the threshold in Green Belt. Where development occurs in Green Belt it needs to take account of minerals. The policy does not imply mineral extraction will occur only be considered. The policy could be strengthened to take greater account of both the impact on the landscape/environment of extraction and any benefits to be gained.

Question 112a - Are there any key mineral related infrastructure sites that no longer need to be protected? Yes/No; Please provide details

We are not able to comment.

Question 112b - Are there any other sites that do need to be protected? Yes/No; If yes, please provide details.

We are not able to comment.

Question 114 - Do you have evidence of workable, viable deposits of brick clays outside the areas of search, which could justify defining new areas of search?

Yes/No; If yes, please provide details.

We are not able to comment.

Question 115a - Do you have evidence of any realistic possibility of fracking in the Black Country? Yes/No; If yes, please provide details.

It seems unlikely that fracking sites would be realistic in the Black Country. Should they exist they would inevitably be in areas of countryside and policies to address them should take account of the impact on landscape and biodiversity as well as the safety and suitability of the access to the site (as defined in NPPF), especially given the reliance on OGVs (the heaviest form of HGVs) to carry equipment and waste water to and from the site. Any policy would need to clearly apply to testing and monitoring as well as production.

Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy?

Yes/No; If yes, please provide details.

See 115a

Question 116 - Do you think that Policy MIN5 identifies all of the key issues that need to be addressed in relation to new mineral developments in the Core Strategy, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

We do not have a comment.

Question 117 - Do you agree with the proposed approach to updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy? Yes/No; If not, what alternative approach would you suggest

We do not have a comment.

BLACK COUNTRY CORE STRATEGY REVIEW - ISSUES AND OPTIONS RESPONSE BY BARBERRY DEVELOPMENTS LTD.

We are instructed by Barberry Developments Ltd. to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportun ity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation webs ite. We trust you take our comments into considerat ion and look forward to being notified of future stages of consultation on the Core Strategy.

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?

No, we consider that the review needs to go furthe r than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphasis on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a variety of reasons relating to ownership, viability , market perceptions, site suitability etc.

The approach of the SCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework. Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different economic climate to the adopted docume nt. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors . It is, however, advised in the "delivery" section of the emerging Core Strategy (paragraphs 2. 5 to 2.11) that the level of concentration in the growth corridors is "less than participated". One of the reasons for this is that more windfall sites will come forward than
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Appendix C - Black Country Monitoring Summary, of the emerging plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developments have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated ". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4 , new evidence identifies a significant requirement for additional employment land. As a consequence , the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attractive to the market.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the M5.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience difficulties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementatio n rate needs to be identified in respect of the windfall element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgement with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discussions with the adjoining Authorit ies to the Black Country, including South Staffordshire, Wyre Forest and Bromsgrove whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographica l linkages.

We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites can be made available to meet the needs of the market. This will also help with early delivery and will help Local Authorities to maintain a five year housing land













supply and also to boost significant ly the supply of housing in accordance with the requirements of paragraph 47 of the Framework.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "be significantly " for supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2. 10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly , business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available , it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable , sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission.

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Author ities. The housing market areas should not be confined to the administrative boundaries of the Black Country Author ities. ( HL to review)

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 any particular areas, please provide details.

We consider that a more in depth analys is needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.

As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Authority boundaries.

We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Authorities. This strengthens our












view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Author ities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward. Our experience to date has been that the programmes have been time consuming, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

As a starting point, we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to visit the HMA but build upon the work undertaken in establishing the Greater Birmingham HMA part of the preparation of the Birmingham Development Plan. HMAs over lap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whether the HMA boundary remains valid for the purposes of its assessment. This approach is, however, entirely missing.

It should also be noted that the SHMA does not fully address affordable housing requirements. It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordab le housing need is not a direct component of the demographic part of the objectively assessed needs assessment. As such, an updated calculation of this nature is not included in the SHMA. It is for the client Authorities to consider whether more new homes over and above the objective ly assessed housing needs figure identified in the SHMA should be provided in the plan area to address more affordable housing need through policy adjustments.














The Framework advises that paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things , "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore , provide a complete picture of housing need within the subject Authority areas.

The SHMA is not, therefore, in accordance with national guidance in this regard. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore, there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing Core Strategy where there has been significant under delivery in the Growth Netwo rk. As referred to in our response to Question 1, there is clear uncertainty regarding for delivery of a significant number of the housing sites identified on the existing employment land by the current development plan documents. It is necessary for the emerging Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure take account of non-delivery of proposed housing allocations. At the present time the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). It is, therefore , our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 11.6% of flexibility to supply and to take account of the delivery in delivering the urban regeneration sites.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78,190 units over the plan period, this produces an annual requirement of 3,554 units per annum which is also far in excess of what has ever been achieved annually in the BCCS. We consider that this is a challenging figure in terms of the current supply, over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25,000 units identified.

We note that the overall supply from the urban area depends upon some 42,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5 , the latter identifying the problems in releasing employment sites), we consider that the local plan strategy which relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.

The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.












It is apparent, therefore, that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefore, the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfie ld/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locations which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness , viability, delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to 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.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerging plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate
expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.

In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network.

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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 agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release in adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vita l role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework. That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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.

We believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly , reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified.

We believe that elements of the evidence base require further examinat ion including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.

There appears to be some confusion in the plan as to the extent of the gap identified . The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery , this is not taken into account affordable housing needs. Furthermore, the emerging plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore, less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified .











This suggests that the contribution from greenfield/Green Belt sites from within the BCCS area and from Authorities adjoining it will need to be increased significantly.

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfall from the early part of the current local plan period.

For these reasons, Greenfield I Green Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to ' comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.

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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employme nt and within the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investment may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the MS, should be identified.

We also have concerns that the regeneration corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:





'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period.'

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?

We agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the SCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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?

We do not comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No.

We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overreliance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore , that overall the Greenfield requirement should provide some 40,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No .

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfield I windfall sites and that there is no real certainty that further employment land can be released over the plan period to provide housing opportunit ies. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context, we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.





Paragraph 47 of the Framework requires housing opportunit ies to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunities, will not provide any certainty to the development industry regarding the provision of housing through the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Ability to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximately 150 - 750 units.

Question 128 - Do you think there are any potential locations that should be considered? Yes/No.

Yes, we specifically consider that land at Kingswinford bordered by the 84178, the A449 Kidderminster Road and the A4 101 should be released for development. The site extends to 26 hectares and could provide a mix of market and affordable housing and supporting open space and landscaping. Further details have been submitted through the "Call for Sites".

Question 13A - Do you support Spatial Option H2? Yes/No.

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a minimum/maximum size, mix of uses, mix of housing types, accessibi lity 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 settlement/services , proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.

We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.















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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire, Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following criteria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area.

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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise , it will be important for the BCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the BCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged .

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

We suspect that, generally speaking, there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Authorities to work with landowners and developers in this regard together with the relevant strategy consultees .

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CIL contributions .










We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.

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 .

At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Authorities should adopt realistic expectations as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorities do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards . Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forward. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions , including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No. If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding . It is for this reason that we endorse a











higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).

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.

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significantly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the BCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Gree n Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employment sites.

In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajectory for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability, ground conditions, failure to release employment sites, we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the BCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.




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

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield. It will be necessary to have regard to site constraints, parking requirements, offset distances, green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is important not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the density will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfield sites , particularly if these are expected to accommodate significant areas of green infrastructure .

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances . High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking , relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developab le should be considered.

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 .

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

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.



No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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 .

We believe it would be prudent to keep the affordable homes target as origina lly set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No .

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

Question 44A - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on site? Yes/No .

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No.

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore , greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.

Question 47 - Do you think that Policy HOUS should be expanded to cover other types of built social infrastructure and set out standards of built social infrastructure to serve major housing developments? Yes/No.

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector




since the surgeries generate a rental income so that there is a development/ investment market ready to provide the product. It does not need to be funded from contributions from residentia l development.

Education provision will need to be carefully researched so that a capacity in schools is ident ified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No .

We believe that the policy does need to be refined in order to ensure that land which is not necessa ry to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprentices hip programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards . We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No.

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements. The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.













Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No.

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently, the amount of land which will need to be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No .

The introduction of National Space standard does have implications for viability since it introduces a signif icant additional cost to new house building without any necessary uplift in values. It can, therefore , have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country . Yes/No.

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No .

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of Nationa l Space standards.

Question 101A - Do you support the proposed changes relating to f lood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A flexible approach will be required from the Local Authorities when assessing individual schemes. In particular, a joined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

Question 103A - 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.

We consider that the benefits of higher energy efficiency, as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money investing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes.

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.

We are instructed by Clowes Developments to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportunity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation website. We trust you take our comments into consideration and look forward to being notified of future stages of consultat ion on the Core Strategy.


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?

No, we consider that the review needs to go further than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphasis on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a variety of reasons relating to ownership, viability , market perceptions, site suitability etc.

The approach of the BCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework . Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different economic climate to the adopted document. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors. It is, however, advised in the "delivery" section of the emerg ing Core Strategy (paragraphs 2.5 to 2.11) that the level of concentration in the growth corridors is "less than LONosifrticipated' ToKf?dmmffiT the I\ SQXtl R this is that more windfall sites will come forward than
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To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




expected outside of the Growth Network . These windfall sites have assisted in housing delivery. Append ix C - Black Country Monitoring Summary, of the emerg ing plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developments have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy , seeking to focus new residential development on poor quality employment land, will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employme nt land. As a consequence, the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attractive to the market. These would include sites capable of providing high quality housing, attractive to existing residents ion the Black Country who are seeking to move within the area, as well as an occupier seeking accommodation and which are moving to the Black Country for economic reasons i.e. the move is associated with inward investment.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the M5.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience difficulties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementation rate needs to be identified in respect of the windfa ll element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgeme nt with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discussions with the adjoining Authorities to the Black Country, including South Staffordshire, Wyre Forest and Bromsgrove whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographical linkages.





We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites, including high quality , can be made available to meet the needs of the market. The exercise should take a long-term view of development needs, providing a boundary which can endure beyond the plan period. This will also help with early delivery and will help Local Authorities to maintain a five year housing land supply and also to boost significantly the supply of housing in accordance with the requirements of paragraph 47 of the Framework.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework , housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission .

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Authorities. The housing market areas should not be confined to the administrative boundaries of the Black Country Authorities. ( HL to review)

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 any particular areas, please provide details.

We consider that a more in depth analysis needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.

As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Authority boundaries.












We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Authorities . This strengthens our view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure . In so doing, the objective should be to ensure that the needs of all are met, including those currently residing in the Black Country and who are seeking higher quality housing and those who are moving into the Black Country for economic reasons. The provision of such housing can also achieve a 'churn' in the current stock .

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Authorities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward . Our experience to date has been that the programmes have been time consum ing, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78, 190 units over the plan period, this produces an annual requirement of 3, 554 units per annum which is also far in excess of what has ever been achieved annually in the BCCS. We consider that this is a challenging figure in terms of the current supply, over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25 ,000 units identified.












We note that the overall supply from the urban area depends upon some 42 ,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5, the latter identifying the problems in releasing employment sites), we consider that the local plan strategy which relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.

The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.

It is apparent , therefore , that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefore , the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfield/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locations which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness , viability, delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to 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.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerging plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.












In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network .

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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 agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release in adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vital role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework . That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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.

We believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly , reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified .

We believe that elements of the evidence base require further examination including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.












There appears to be some confusion in the plan as to the extent of the gap identified. The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery, this is not taken into account affordable housing needs. Furthermore, the emerging plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore, less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified . This suggests that the contribution from greenfield/Green Belt sites from within the BCCS area and from Authorities adjoining it will need to be increased significantly .

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first ' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40 ,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfa ll from the early part of the current local plan period.

For these reasons, Greenfield I Gren Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to 'comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.













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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employment and within the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investment may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the M5, should be identified.

We also have concerns that the regeneratio n corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:

'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period. '

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?

We agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the BCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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?

We do not comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No .












We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overreliance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore , that overall the Greenfield requirement should provide some 40,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No.

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfie ld I windfall sites and that there is no real certainty that further employment land can be released over the plan period to provide housing opportunities. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context, we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.

Paragraph 47 of the Framework requires housing opportunities to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunit ies, will not provide any certainty to the development industry regarding the provision of housing through the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Abil ity to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximate ly 150 - 750 units.

Question 13A - Do you support Spatial Option H2? Yes/No.

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a 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 settlement/services, proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.



We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.

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 opportun ities 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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire, Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following crite ria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area. These sites should contribute to a portfolio of high quality sites.

Question 15B - Do you think that there are any potential locations that should be considered? Yes/No.

We consider that land immediately adjoining the administrative boundary of Dudley in the Kingswinford area should be released from the Green Belt to provide an urban extension. This would provide housing which would use facilities in the Kingswinford area. We have identified land on the attached plan at Lawnswood. The site would be able to provide high quality housing, as part of the overall provision of housing needs for the Black Country, in a location in which we would be able to take advantage of nearby education, sport and High Street facilities. Being situated close to the A449 also means that occupants would be able to reach other parts of the Black Country for employment and leisure purposes.

We have completed a "Call for Sites" form which explains the development potential of this area in more detail.

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.












Yes, we believe that the best way to ensure that housing provided outside of the Black Country will meet the needs of people, who would otherwise live in the Black Country is to ensure that the location of new development has good functional and geographic links with the Black Country. As noted in our response to Question 15b, sites can be released which immediately adjoin the Black Country and administrative area or are in settlements with strong functional and physical/geographic links with the Black Country. Clearly, there is nothing to stop people migrating from the Black Country into the surrounding Shire Aut horities, regardless of housing provision, and, therefore , the provision of additional housing outside of the BCCS, but which will meet the needs of people living in the Black Country, will ensure that the needs of Black Country residents can be met either within the Black Country itself or in settlements which are suitable to serve it.

We consider that the provision of high quality sites is an important part of the approach, since there will encourage existing residents to stay in or close by in the Black County . Furthermore, such sites will help to support the economic objectives of the BCCS by providing housing for inward investment related house moves.
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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise , it will be important for the BCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the BCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged.

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

We suspect that , generally speaking , there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Authorities to work with landowners and developers in this regard together with the relevant strategy consultees.

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CIL contributions.

We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.

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 .













At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Author ities should adopt realistic expectat ions as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfie ld sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorities do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards. Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forward. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. Furthermore, some of these sites will not be in locations which are attractive to those seeking new housing. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions, including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No . If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding. It is for this reason that we endorse a higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).

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.





Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes. The locationa l criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living,which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significant ly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the BCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employme nt sites.


In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajectory for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability, ground conditions, failure to release employment sites , we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the BCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.

Question 36 - If you think that the current access ibility and density standards set out in Policy HOU2 and Table 8 should be changed, what standards should be applied instead, for example, should the minimum net density of 35 dph be increased to max imise brownfield housing delivery? Yes/No.




The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield . It will be necessary to have regard to site constraints, parking requirements, offset distances , green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is important not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the density will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfie ld sites, particularly if these are expected to accommodate significant areas of green infrastructure.

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances. High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should be considered.

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 .

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordab le housing.

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.

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger fam ilies.












Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach. This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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.

We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No.

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders. It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

Question 44A - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on site? Yes/No.

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No .

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as education, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites . We believe, therefore, that a flat rate of 25% across the BCCS area should be adopted.

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

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a developme nt/investmen t market ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the













Education Funding Agency also need to be taken into account when assessing education requirements .

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No .

We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Author ities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No .

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements . The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.

Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No .

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently , the amount of land which will need to




be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No.

The introduction of National Space standard does have implications for viability since it introduces a significant additional cost to new house building without any necessary uplift in values. It can, therefore, have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country. Yes/No.

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No .

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of National Space standards .

Question 101A - Do you support the proposed changes relating to flood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A flexible approac h will be required from the Local Authorities when assessing individual schemes. In particular, a joined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

Question 103A - 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.

We consider that the benefits of higher energy efficiency , as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money invest ing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes .

We are instructed by Bloor Homes to submit a response to the Black Country Core Strategy Review - Issues and Options consultation. We welcome the opportunity to comment and to input into the preparation of the Core Strategy at the outset. We have responded to the questions as per the consultation document and have submitted the comments via the online consultation website. We trust you take our comments into consideration and look forward to being notified of future stages of consultation on the Core Strategy.


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?

No, we consider that the review needs to go further than a partial review. Whilst the overall strategy of supporting further housing and employment growth with an emphas is on regeneration should be supported, it is clear that the desire to achieve major regeneration of identified areas has failed, for a var iety of reasons relating to ownership, viability, market perceptions, site suitability etc.

The approach of the BCCS is based upon the revoked West Midlands Regional Spatial Strategy and it was produced prior to the adoption of the Framework. Furthermore, there was a significant shift in the amount of housing and employment land that is required that the Black Country Core Strategy needs to respond to. The emerging Core Strategy is also being prepared in a significantly different econom ic climate to the adopted document. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.







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To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




The adopted Core Strategy seeks to deliver development by focusing the majority of new housing employment land requirements through a Growth Network and a series of Regeneration Corridors. It is, however, advised in the "delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of concentration in the growth corridors is "less than participated". One of the reasons for this is that more windfall sites will come forward than expected outside of the Growth Network. These windfall sites have assisted in housing delivery. Appendix C - Black Country Monitoring Summary, of the emerging plan advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement set by the adopted Core Strategy for the plan period to date. The windfall developme nts have effectively bolstered housing delivery whilst the housing allocations within the Regeneration Corridors and Growth Network generally have under delivered.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it is transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constra ints than expected.

It is, therefore, our view that the approach of the adopted Core Strategy seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employment land. As a consequence, the emerging Core Strategy should prepare an approach that places less reliance on the delivery of housing on employment land.

This means that the trajectory of the current plan is unlikely to be met since it now relies heavily on windfall sites, some of which are not suited to market requirements or are also subject to contribution and viability problems.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (Green Belt) opportunities which are capable of being delivered in the new plan period and which will be attract ive to the market.

We consider that a portfolio of new strategic sites would be identified in the emerging plan with capacities of 150 to 500 units plus. Such sites are more likely to be deliverable in the plan period although we do see the opportunity for a major mixed use urban extension to the south west of Junction 3 of the MS.

The identification of a range of sites will ensure that there is adequacy of supply and will avoid reliance on major urban extensions which can experience diff iculties in terms of funding and timing.

We also consider that a realistic approach needs to be taken to sites coming forward and that a non implementation rate needs to be identified in respect of the windfall element of the housing requirement. This is particularly important given the considerable reliance given to windfall sites in the current supply figure and the acknowledgement with Review department that there have been problems experienced in bring forward brownfield sites.

We also believe that the strategy needs to encompass wider discuss ions with the adjoining Authorities to the Black Country, including South Staffordshire , Wyre Forest and Bromsgrove

To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




whose administrative boundaries adjoin or are close to the Black Country and where there are functional and geographical linkages.

We believe it is important that the Green Belt releases are phased for the early part of the plan period so that a mix of sites can be made available to meet the needs of the market. This will also help with early delivery and will help Local Authorities to maintain a five year housing land supply and also to boost significantly the supply of housing in accordance with the requirements of paragraph 47 of the Framework .

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "be significantly " for supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites would be "deliverable and available" in order to be allocated. The employment led regeneration approach of the emerging Core Strategy has failed this test at least to some degree.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites concentrating the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver this. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the allocations test put in place by paragraph 47 of the Framework . To be considered deliverable, sites should be available for development now and be achievable for a realistic prospect that housing will be delivered on the site. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted development plan, by the emerging Core Strategies own omission.

Finally, we consider that a more robust SHMA should be undertaken focusing on the Black Country and the adjoining Authorities. The housing market areas should not be confined to the administrative boundaries of the Black Country Authorities. ( HL to review)

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 partic.ular issues that should be taken into account in considering development on any particular sites or any particular areas, please provide details.

We consider that a more in depth analysis needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.




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As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Autho rity boundaries.

We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Author ities. This strengthens our view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Author ities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward. Our experience to date has been that the programmes have been time consuming, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014 to 2036 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.

National guidance requires Local Authorities to meet the full, objectively assessed needs in the market and affordable housing in their housing market area, as far is consistent with policies set out in the Framework. The objective is to boost significantly the supply of housing.

We have already commented in respect of our responses to Questions 1 and 2 that the SHMA needs to be reviewed and this could lead to an increase in the overall requirement for the Black Country Authorities.

As a starting point, we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to visit the HMA but build upon the work undertaken in establishing the Greater Birmingham HMA part of the preparation of the Birmingham Development Plan. HMAs overlap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whet her the HMA boundary remains valid for the purposes of its assessment. This approach is, however, entirely missing.

It should also be noted that the SHMA does not fully address affordable housing requirements . It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordable housing need is not a direct component of the demographic part of the objectively assessed








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needs assessment. As such, an updated calculation of this nature is not included in the SHMA. It is for the client Authorities to consider whether more new homes over and above the objectively assessed housing needs figure identified in the SHMA should be provided in the plan area to address more affordable housing need through policy adjustments .

The Framework advises that paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things, "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore, provide a complete picture of housing need within the subject Authority areas.

The SHMA is not, therefore, in accordance with national guidance in this regard. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore , there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing Core Strategy where there has been significant under delivery in the Growth Network. As referred to in our response to Question 1, there is clear uncertainty regarding for delivery of a significant number of the housing sites identified on the existing employment land by the current development plan documents. It is necessary for the emerging Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure take account of non-delivery of proposed housing allocations. At the present time the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). It is, therefore, our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 11.6% of flexibility to supply and to take account of the delivery in delivering the urban regeneration sites.

The current completion rates are significantly below what is required for even the current local plan figure and are significantly below the figure of 3,690 units per annum identified above. Even at 78,190 units over the plan period, this produces an annual requirement of 3,554 units per annum which is also far in excess of what has ever been achieved annually in the SCCS. We consider that this is a challenging figure in terms of the current supply , over half of which is dependent upon existing housing supply in the urban area and is largely made up of brownfield windfalls.

In this context we believe that it is going to be important to significantly change the balance of the current supply with a far greater reliance on greenfield/Green Belt sites than the 25,000 units identified.

We note that the overall supply from the urban area depends upon some 42 ,507 units from existing sites in the urban area and a further 8,335 units from the urban area, much of which appears to come from former employment sites.

Given the problems in releasing employment sites in the current strategy (see paragraph 3.16 and paragraph 2.5, the latter identifying the problems in releasing employment sites), we consider that the local plan strategy wh ich relies on some 65% of provision on urban brownfield/windfall sites (using the draft figure of 78,190) is wholly unrealistic given that, to date, the current local plan has failed to meet existing requirements.













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The components of the supply in the urban area (completions plus existing housing supply plus estimated further housing supply) total some 56,520 units which equates to a requirement of 2,569 units per annum over the new plan period. However, that required completion figure is in excess of what has been achieved to date through the current local plan, which relies entirely upon brownfield windfalls in the urban area, that figure being 2,325 units per annum.

It is apparent , therefore, that the current supply of brownfield/windfall sites is unlikely to produce sufficient units to meet its share of the housing requirement and, therefo re, the contribution which this makes to the overall requirement should be reduced (this will be consistent with our argument about adopting a non completion rate) and the contribution from greenfield/Green Belt sites outside the existing urban boundary should be increased. This will require contributions to be made from greenfield/Green Belt sites within the BCCS administrative area and also from sites in sustainable locat ions which are well related to the Black Country in neighbouring authorities.

Although we reserve our position on this point, we would expect that the contribution from the existing brownfield windfalls to be reduced by some 25%, to reflect the problems of market attractiveness, viability , delivery etc and with a consequent increase in the greenfield/Green Belt allocations.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the plan strategy with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA area of sustainable locations in order to ensure delivery.

Question 4 - Do you consider the employment land requirement identified to the Black Country up to 2036 in the EDNA is appropr iate and in line with national guidance? Yes/No . If not, please explain why they are not appropriate and in line with national guidance.

It is not clear if the land requirement fully encompasses land to be lost to residential development and other uses. The current supply of housing identified in the emerg ing plan requires a significant contribution to be made from former employment sites. It has been noted, however, in the Issues and Options document that employment sites have failed to come forward at the rate expected, partly owing to problems in site delivery but also partly because of recovery in the demand for the stock of existing employment sites.

We expect that demand to continue for local and sub regional requirements on appropriate sites.

In addition, we believe there will be a demand for large, greenfield sites to encourage inward investment and we consider that sites should be identified to the north and south of the Black Country which are well connected to the existing motorway network.

We consider that the employment requirement should be based on a net addition in order to take account of any losses to alternative land uses.

We agree that a range of sites will need to be allocated including, as noted above, high quality sites to attract inward investment.

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We also question whether the figure of 394 hectares of employment land can be regarded as being realistically deliverable and we believe that further assessment about the delivery of this land should be undertaken.

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 agree that a review of the Green Belt is an imperative element of the new strategy. This needs to be completed in time to inform the Core Strategy Review to be published in September 2018.

We consider the review will need to assess the implications of land release 1n adjoining Authorities including South Staffordshire, Wyre Forest and Bromsgrove.

Green Belt sites in both the Black Country Authority area and in these other authorities will have a vital role to play in providing the necessary housing supply to meet the housing requirement over the plan period. They will need to make an early contribution to housing supply and should not be phased for delivery in the latter part of the plan period.

We also think it is important that the Green Belt Review extends beyond the current plan period in order to provide a lasting Green Belt boundary in accordance with the advice set out in paragraphs 83 and 85 of the Framework. That advice suggests that the boundaries should be set so that they are capable of enduring beyond the plan period. If necessary, safeguarded land between the urban area and the Green Belt should be identified in order to meet long term development needs "stretching well beyond the plan period' .

We would suggest that the Green Belt Review should be conducted in order to provide for development needs up to 2051.

Question 6 - Do you agree that the key issues set out in part 3 are 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.

We believe that an extensive review needs to be undertaken in order to ensure that an appropriate strategy is arrived at. Clearly, reliance upon the existing strategy will fail to meet the housing requirement and employment land requirement identified.

We believe that elements of the evidence base require furthe r exam ination including the SHMA and also the likely delivery of housing and employment from existing brownfield windfalls and existing sites.

There appears to be some confusion in the plan as to the extent of the gap identif ied. The policy talks about 22,000 homes but then also identifies a further 3,000 units as a shortfall in the housing area. It is unclear if the current shortfall of 3,000 units has been addressed.

In this context there may be a need to identify a further 28,000 homes over and above the existing, alleged, capacity in the urban area.

There is a need to continue to plan for a growing population. However, the SHMA underestimates delivery, this is not taken into account affordable housing needs. Furthermore, the emerg ing plan housing requirement will need to take into account the fact that not all housing allocations deliver. As a consequence the housing requirement will need to be significantly











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above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and need of 22,000 dwellings is, therefore , less than that actually required.

This figure may increase further when proper account is taken of the true delivery capabilities of the land in the existing urban area. So far, the current local plan has failed to deliver development rates which would meet with the housing requirement for the new plan period and indeed do not even meet the requirement which will be needed from the current supply identified. This suggests that the contribution from greenfield/Green Belt sites from within the SCCS area and from Authorities adjoining it will need to be increased significantly.

The Green Belt release should not be seen as a matter of a last resort but needs to be part of an overall strategy with early releases needed to ensure supply of housing sites in the early part of the plan period.


Question 7 - Do you think that the Core Strategy Vision and Sustainability principles remain appropriate? Yes/No. If not, what alternative would you suggest?

We are content with four of the five Core Strategy Vision and Sustainability principles but the fourth bullet point, 'Brownfield first' is no longer relevant. As we have explained in our responses to previous questions, the reliance on Brownfield development needs to be significantly reduced. It is already acknowledged that a significant number of homes, 22,000 - 25 ,000 may have to be allocated on Greenfield I Green Belt sites (these could be still higher if the current shortfall is to be rectified) and if an update to the SHMA reveals the need to release new land to meet affordable housing needs. We have already explained that we are concerned that there is an over reliance on Brownfield sites and that this could, overall, increase the requirement for new development on Green Field I Green Belt sites to some 40,000 units which will be approximately half of the overall housing requirement, once account is taken of the shortfall from the early part of the current local plan period.

For these reasons, Greenfield I Green Belt sites will have to be released at the same time as the Brownfield supply in order to ensure an adequate supply in the early part of the planning period. This is entirely consistent with paragraph 17 of the Framework which, whilst encouraging the reuse of brownfield sites, does not seek to prioritise their use over greenfield sites.

We would also question whether or not the reference to 'comprehensive approach to development' has any real meaning in terms of delivery of individual sites. We consider that if 'comprehensive ' development is required this can still take place on a phased basis so long as new development achieves a comprehensive approach in due course.

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

We consider that spatial objectives two and three need to be reviewed. Whilst we would continue to support the delivery of high quality employment and with in the regeneration corridors, which will also be helpful to local business, it should be recognised that inward investme nt may require high quality Greenfield sites on the edge of the Black Country. The availability of land 6a54 was a considerable benefit in bringing JLR to the Black Country and the opportunity for similar scale developments should be seized through the local plan review process. In particular, we consider that further strategic employment development on the north side of the Black Country and also to the south east, adjoining Junction 3 of the M5, should be identified.











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We also have concerns that the regeneration corridors have failed to deliver wide spread change throughout the Black Country and that they may not provide a basis for sustainable communities in the new plan. In this context, we believe that this particular objective should be replaced with the following:

'Identification of a series of deliverable housing sites on Brownfield and Greenfield within, adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period. '

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?

We agree that the policies should be changed. The growth network strategy will not provide for the new housing and employment requirements for the Emerging Local Plan and need to be amended to reflect the fact that a significant proportion of both housing and strategic employment sites will have to take place on Greenfield I Green Belt sites outside of the current urban boundary and indeed on sites outsides of the BCCS administrative area.

The presumption in favour of using Brownfield sites first also needs to be altered so that an appropriate portfolio of residential and employment sites can be developed over the planning period.

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?

We do not comment upon specific regeneration corridors but we believe that they will all need to be reviewed to see if they are fit for purpose. In particular, they should be examined to see if the employment elements are still likely to be required by the existing and new local businesses. Where it is clear that significant change in the regeneration corridor are unlikely to happen during the new planning period, alternative provision should be made.

Question 11A - Do you support Strategic Option 1A? Yes/No.

We consider that Option 1A is to be preferred to Strategic Option 1B. That said, we believe there continues to be an overre liance upon Brownfield I windfall sites in the existing supply and there is also an over reliance on Brownfield windfalls in the estimated further housing supply.

We consider, therefore, that overall the Greenfield requirement should provide some 40 ,000 units of the overall requirement which itself should be increased to 81,290 units.

Question 11A - Do you support Option 1B? Yes/No.

We do not support Option 1B. We believe that there is a considerable overreliance on Brownfield
I windfall sites and that there is no real certainty that further employment land can be released








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over the plan period to provide housing opportunities. Indeed some of the existing housing allocations need to be reviewed as they will remain in employment use.

In this context , we consider that the Option 1B would not meet the objectives of the housing policies of the Framework particularly those which require the planning system to deliver significantly increased supply of housing land.

Paragraph 47 of the Framework requires housing opportunities to be deliverable and to meet the full, objectively assessed needs for market and affordable housing in the housing market area.

A review of the current local plan strategy has demonstrated that there is considerable uncertainty about reliance on a portfolio of Brownfield windfall sites we consider that strategic Option 1B, which is largely reliant upon such a source of housing opportunities, will not provide any certainty to the development industry regarding the provision of housing throug h the plan period.

Question 12A - Do you support spatial Option H1? Yes/No. What criteria should be used to select suitable sites? Eg. Ability to create a defensible new Green Belt boundary, size, access to existing residential services.


We believe that spatial Option H1 - Rounding off is to be preferred to spatial Option H2 - sustainable urban extensions. We believe that the 'rounding off' approach is more likely to deliver a series of well-planned and well located developments throughout the plan period thereby maintaining a deliverable supply of housing land for the house building industry. This could include sites of approximately 150 - 750 units.

Question 13A - Do you support Spatial Option H2? Yes/No.

What should the characteristics of Sustainable Urban Areas (SUEs) B? E.g. a 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 settlement/services, proximity to the existing growth network, potential to support urban regeneration.

In general terms we do not support Spatial Option H2 in that we believe a range of smaller strategic sites should be provided in the Green Belt in order to ensure a deliverable supply of housing land in the plan period.

We consider that some modest size sustainable urban extensions could be provided. These should have the capacity to support a primary school and local facilities.

We would not favour sustainable urban area extensions of greater size than this as we do not consider that they would be deliverable in the plan period. In this context we believe that modest scale SUEs could be provided as part of a blended Spatial Option H1.

















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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?

We believe that it will be necessary for sites to be released outside of the Black Country administrative area in order to meet the housing requirements of the BCCS.

In particular, we believe that sites should be identified in South Staffordshire , Wyre Forest and Bromsgrove districts which could accommodate some of the overspill.

We consider that locations should be selected which could fulfil the following criteria.

A. Be situated immediately adjoining the Black Country administrative boundary and with the ability to achieve easy access to the existing urban area: or

B. Be located in settlements in close proximity to the Black Country.

By these means people from the Black Country will be able to find suitable housing in locations which still afford them the opportunity to support the economic growth of the Black Country and will remain in employment in the Black Country area.

Question 158 - Do you think that there are any potential locations that should be
considered? Yes/No

We believe that Hagley will provide an appropriate location for sites to be released which meet the needs of the Black Country . Hagley is very well related to the Black Country, lying just to the south of the edge of Stourbr idge. It is a sustainable settlement, being the second most sustainable settlement in Bromsgrove District with both primary and secondary schools, a railway station, local facilities and can access the Black Country through the primary road network.

We have ident ified two opportunities for sites to be released at Hagley through the "Call for Sites" process on behalf of Hagley Hall Estate.

The site addresses are as follows:

1. Western Road I Stourbridge Road
2. Stoney Lane I Stakenbridge Lane I Kidderminster Road

The Call for Sites response provides more information regarding the suitability of these two sites for development.

We can confirm that, subject to the release of the sites from the Green Belt through the Bromsgrove District Plan, both sites can be made available in the early part of the plan period and will provide high quality, sustainable developments which will fulf il the housing requirements of residents of the Black Country.




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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.

Yes, we believe that the best way to ensure that housing provided outside of the Black Country will meet the needs of people, who would otherwise live in the Black Country is to ensure that the location of new development has good functional and geographic links with the Black Country. As noted in our response to Question 15b, sites can be released which immediately adjoin the Black Country and administrative area or are in settlements with strong functional and physical/geographic links with the Black Country. Clearly, there is nothing to stop people migrating from the Black Country into the surrounding Shire Authorities, regardless of housing provision, and, therefore, the provision of additional housing outside of the BCCS, but which will meet the needs of people living in the Black Country, will ensure that the needs of Black Country residents can be met either within the Black Country itself or in settlements which are suitable to serve it.

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.

Policy DEL1 may need to be reviewed to ensure it is compliant with the policies of the Framework and the PPG. Otherwise, it will be important for the SCCS Authorities to work with neighbouring Authorities to ensure that sites which are released to meet the Black Country's needs outside of the SCCS area are also supported by appropriate infrastructure. Some of this may also have to be outside of the BCCS area, particularly for the larger urban expansion sites which may provide local facilities, green space, primary schools etc.

The important point here is to ensure that statutory undertakers are involved with the local plan process at an early stage in order to ensure that necessary infrastructure including highways, drainage and power are available for the development envisaged.

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

We suspect that, generally speaking, there will need to be incremental improvements in social infrastructure provision to meet the requirements for the occupants of new development over the plan period. This will need to be assessed in detail with social infrastructure providers and it will be necessary for the BCCS Author ities to work with landowners and developers in this regard together with the relevant strategy consultees.

We should state from the outset that the provision of doctor's surgeries should be regarded as a "private sector" matter. Doctor's surgeries are generally self-funding and do not need to be the subject of Section 106/CI L contributions.

We believe it is likely that some new infrastructure will have to be provided for individual schemes in terms of local highway improvements but this will have to be assessed on a case by case basis. This will probably be best assessed at the local level.




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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.

At this stage we have no comment to make other than to confirm that viability is an important issue which needs to be addressed when dealing with sites. We would say at this stage that the Authorities should adopt realistic expectations as to what social and environmental infrastructure can be borne by individual developments .

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.

We have commented previously that the new plan will need to shift the emphasis away from urban regeneration to a more balanced provision of brownfield and greenfield sites. Part of a problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now developing a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

Furthermore, given the problems in bringing forward any brownfield sites for a variety of reasons, it will be necessary to ensure that greenfield opportunities can be brought forward in the early part of the plan period in order to ensure an appropriate supply of land.

We should add that our experience of working in the Black Country is that Local Authorit ies do need to understand the constraints of developing in the Black Country, particularly in respect of highway and urban design standards. Many of the sites are difficult to develop and the Council's will need to apply development management considerations flexibly in order to ensure that sites can come forwa rd. Many brownfield sites present physical and topographic challenges which can influence the formation of layout and design solutions. All of these factors need to be taken into account when individual planning applications are assessed and Council's should apply flexibility when discussing design solutions, including transportation solutions, with applicants.

Question 31 - Do you think that the right scale in the form of funding is available to support the delivery of the Core Strategy Review? Yes/No. If no, what alternative source of the funding or delivery mechanisms should be investigated?

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released.

Furthermore, it cannot be guaranteed that the funding which is provided now will continue to be available during the plan period.

In this context it is important to ensure that there is a balance portfolio of housing provided, some of which will be less dependent upon intervention funding. It is for this reason that we endorse a higher proportion of development on greenfield/Green Belt sites that is currently in the plan (see response to Question 3).


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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 .

Our response is that such matters will be better addressed at the development management stage when it will be possible to assess the specific impacts on individual schemes . The locational criteria to be applied to the inspection of sites should suffice for development plan purposes. Some of this will reflect matters such as proximity to local services.

Question 348 - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process? Yes/No.

We make no formal comment at this stage but we participate in the next stage of the plan when more details of this approach are given. We would stress, however, that given the likely constraints which will exist on many of the Black Country sites, care should be taken to ensure that overly restrictive policies are not introduced which could further reduce the attractiveness of sites for development.

Question 35 - Do you support the proposed approach to housing land supply? Yes/No.

We agree that HOU1 of the adopted Core Strategy needs to be reviewed. We agree that the proportion of housing to be built on previously developed land will need to be significant ly changed and we have indicated elsewhere that the plan should provide approximately 50% provision of the overall requirement on greenfield/Green Belt sites.

We do not favour the prioritisation of brownfield land over greenfield land. Given the considerable amount of housing required across the SCCS, it will be necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market and so it is important that a range of sites are made available for all sectors of the housing market at the same time. Furthermore, the current strategy has failed to deliver the required level of housing from former employment sites.

In terms of a discount rate we note that there have been problems in meeting the housing requirement in the plan period. This is of particular concern given that the housing trajecto ry for the adopted Core Strategy starts at a relatively low rate. The extent of the shortfall is already 3,000 units. Given the problems of bringing forward brownfield sites, acknowledged elsewhere in the Issues and Options document and including matters such as viability , ground conditions, failure to release employment sites, we believe that a discount rate of 25% should be applied. We consider that the proportion of a greenfield land as an element of the overall supply should be increased to provide more certainty about provision across the plan period and to ensure that the housing strategy accords with paragraph 47 of the Framework. It should be noted that the requirement to boost significantly the supply of housing land became national policy after the adoption of the SCCS.

We make no comment at this stage about proposals for high density allocations within strategic centres, particularly in Walsall, until more market research has been carried out to ensure that there is both demand and an appetite from the house building industry to provide this type of product.














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

The calculation of density standards is a difficult subject. It is always important to start first with an understanding of what the net developable area of a site may be irrespective of whether it is brownfield or greenfield. It will be necessary to have regard to site constraints, parking requirements , offset distances, green infrastructure requirements, drainage requirements etc. All these factors can significantly limit the net developable area on a site. It is importa nt not to overestimate densities which could be achieved when identifying sites to be released for development. Once schemes provide more than 40 dwellings per net developable acre the dens ity will usually require some element of flatted development.

The insistence on 35 dph as a minimum could well be problematic on greenfield sites, particularly if these are expected to accommodate significant areas of green infrastructure .

We would suggest that the policy should be targeted to provide densities of 30 to 40 dph depending upon site specific circumstances. High densities could be achieved in more centralised locations adjoining transport hubs, again subject to achieving acceptable design standards. We have explained elsewhere the importance of ensuring that development management expectations need to be married to strategic housing requirement delivery objectives.

Question 37A - Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No.

We would keep the threshold at 15 homes or more. This will help to assist smaller house builders to provide schemes on smaller sites which tend to have more exacting development management issues such as overlooking, relationship with existing uses etc and which can limit the ability to increase densities.

Question 38 - Do you think that the current accessibility and density standards are appropriate for Green Belt release locations? Yes/No.

In our response to Question 36, we identify the fact that greenfield sites may have more exacting requirements in terms of green infrastructure and that density standards may well have to be reduced. We suggest that density standards of 35 dph net developable should be considered.

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.

Generally speaking we believe that provision for the housing for the elderly will be demand driven. Occupiers will understand their markets and we would not welcome a restrictive policy regarding the location of either accommodation for the elderly or affordable housing.

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.

No. The SHLAA does not fully assesses affordable housing requirements as referred to above; as such it should not dictate an overall mix. House builders will provide housing to meet their










To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




assessment of the localised market. Setting general standards across such a large area can be difficult and can cause problems with housing delivery. Furthermore, it is important to understand the likelihood that new housing will also generate movements from existing stock to new stock thereby freeing up smaller properties for first time buyers and younger families.

Question 41A - Do you support the introduction of a policy approach towards self and custom built housing in the Core Strategy? Yes/No.

No, we do not support this approach . This is not a significant sector of the housing market. Given the need to encourage housing on a variety of sites, many of which will have problems in terms of delivery, we would not favour a policy which could create problems for delivery and viability which would arise if self and custom built housing were introduced into any housing requirement.

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.

We believe it would be prudent to keep the affordable homes target as originally set. Otherwise this will cause problems for delivery of brownfield sites.

Question 43A - Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No .

Yes, we believe that the site size threshold should be retained at 15 homes. Again this will assist in the delivery of smaller sites by smaller house builders . It will also be more attractive to the registered providers who do wait to manage a few plots on smaller schemes.

Question 44A - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on site? Yes/No.

Yes, we agree that the figure should be retained at 25%, subject to viability.

Question 45 - Should an increase in affordable housing requirement beset for Green Belt release sites, to reflect the likely financial viability of these sites? Yes/No.

The release of greenfield/Green Belt land also has significant costs associated with it. It is more likely to require new below ground infrastructure to be provided such as drains, power supply etc. Other physical and social infrastructure contributions will also be required such as educat ion, transport etc. Therefore, greenfield sites are not necessarily more able to contribute more significantly to affordable housing than brownfield sites. We believe, therefore , that a flat rate of 25% across the BCCS area should be adopted.

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

We should first comment that the provision of medical facilities relating to new developments should be funded through the clinical commissioning groups. In most cases this will involve new or extended doctor's surgeries. Doctor's surgeries can be provided through the private sector since the surgeries generate a rental income so that there is a development/investm ent market












To: Black Country Core Strategy - Dudley MBC Date: 81h September 2017




ready to provide the product. It does not need to be funded from contributions from residential development.

Education provision will need to be carefully researched so that a capacity in schools is identified in order to avoid unnecessary contributions being sought. The funding implications of the Education Funding Agency also need to be taken into account when assessing education requirements.

In terms of new community facilities, we agree that these need to be carefully assessed in order to ensure that they will in fact be used and also maintained by the local community. In some circumstances it may be better for contributions to be made to upgrade and expand existing facilities rather than create new ones which will simply put a drain on revenue resources.

Question 49A - Is there a need for the existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No.

We believe that the policy does need to be refined in order to ensure that land which is not necessary to be retained can be released quickly and easily without the need for extensive marketing. Also we see no reason for the policy to be applied where land has been allocated in an action area plan or similar alternative plan for alternative use.

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.

We believe that this should be included and that a net target should be set in order to allow for losses to alternative uses.

Question 55 - Do you agree with the proposed proposal to obtain Policy EMP5? Yes/No.

Generally we do not favour contributions which seek to restrict jobs to existing residents. This can cause problems for companies who have their own training and apprenticeship programmes. Whilst it is clearly desirable for Local Authorities to work alongside employers in trying to get local residents into work opportunities, this should be on a voluntary basis and there should not be a requirement to impose what is, in effect, a restrictive trade practice.

Question 94 - Do you support the proposed changes relating to environmental infrastructure and place making? Yes/No.

We appreciate that it will be necessary to review environmental infrastructure in the light of changing circumstances and updated guidance and standards. We will comment further on this issue at the next stage of the plan.

Question 95A - Do you think Garden City principles should be applied at the Black Country? Yes/No.

We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements. The Black Country has a different history and heritage as do the settlements which are geographically and functionally close to the Black Country. We do not consider that the vernacular of the existing urban area and adjoining settlements is appropriate for Garden City principles.










To: Black Country Core Strategy - Dudley MBC Date: Sth September 2017




Question 96 - Do you support the proposed changes relating to nature conversation? Yes/No.

It should be noted that the inclusion of new natural green space and new development will have implications for net developable areas and consequently, the amount of land which will need to be identified for development. It will also impact upon the viability of schemes and these factors need to be taken into account when assessing overall development requirements.

Question 98 - Do you support the proposed changes relating to design quality? Yes/No.

The introduction of National Space standa rd does have implications for viability since it introduces a significant additional cost to new house building without any necessary uplift in values. It can, therefore, have a significant impact upon the delivery of schemes.

Question 99C - Do you think that National Space standards for housing development should be introduced in the Black Country. Yes/No .

In the context of our response to Question 98, we do not agree that National Space standards should be introduced.

Question 99D - Do you think that the standards should be different for brownfield and greenfield sites? Yes/No.

Given that greenfield sites have their own viability concerns, we would not agree that the standards should vary between brownfield and greenfield sites. In any event we do not support the introduction of National Space standards.

Question 101A - Do you support the proposed changes relating to flood risk, sustainable drainage and urban heat island effects? Yes/No.

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications upon site layout and viability do need to be considered. A f lexible approach will be required from the Local Authorities when assessing individual schemes. In particular, a j oined up approach is needed by strategy undertakers to ensure that SuDS areas will be adopted if they are part of wider open space areas.

Question 103A - 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 .

We consider that the benefits of higher energy efficiency, as opposed to renewable energy should be considered in the planning balance, particularly when this has an implication for viability. Although this may not be capable of being a policy requirement there is no reason why it should not be capable of being taken into account. The residential sector has spent a considerable amount of money investing in improved materials which improve the energy efficiency of buildings and these factors need to be taken into account of both domestic and non­ domestic schemes .

The Lapal Canal Trust would like to formally provide information as part of the consultation process on the Black Country Core Strategy Document. We would have liked to do this on line, but our proposal affects a number of the consultation areas
In 1990 the Lapal Canal Trust was established to promote and ensure the eventual restoration of the Dudley No 2 Canal. Canals are recognised as an important benefit for both nature and health. It's a public amenity for boating , canoeing , walking, cycling and fishing. The restored Lapallink will create a popular green walkway from Selly Oak via Halesowen to Netherton. We would like to make sure that the route for restoration of the Dudley No 2 canal is protected , As you are aware some years ago Dudley Council worked on restoring a section of the Dudley No 2 Canal in the Leasowes. In 2007 Atkins was commissioned to prepare a Feasibility Proposal, The report is 9MB and copies are available if
requested. Atkins confirmed that the restoration is feasible but advised on a route via Woodgate Valley Park rather than reopening the tunnel. We are seeking to make sure that the route from the Park to the Leasowes is protected. I have attached a plan from the Atkins proposal, there was two alternative suggestions for crossing Manor Way.
The Lapal Canal Trust would like to confirm our support to retain this area as part
of the Green Belt, but whatever happens we are keen to make sure that the canal route is protected. More than happy to meet to discuss. As you might be aware Birmingham City Council insisted on Land Securities allocating £2.9m via a 106 agreement to protect the route through the new Sainsbury Store development in Selly Oak and has secured the route to California and the Woodgate Valley Park.

1.1 RPS Planning & Development (RPS) is instructed by Barratt Developments Plc (Barratt) to formally respond to the Black Country Core Strategy (BCCS) Review "Issues and Options Report" (July 2017) (IOR).

1.2 Barratt supports the decision of the four authorities to commence a review of the BCCS. As acknowledged in the IOR, the BCCS is now six years old and there is an urgent need for review to provide an up-to-date strategic development plan to identify and deliver growth requirements across the Black Country in the period to 2036. Barratt intend to take an active role in the BCCS Review process.

1.3 The representations are made in the context of Barratt's interest in land at Stencils Farm, Walsall. This land is promoted as a sustainable and deliverable site for residential development through the "Call for Sites" process, which has ran concurrently with the IOR consultation. Barratt's Call for Sites response has been submitted separately and comprises a covering letter, completed Questionnaire and a suite of supporting technical reports which includes a "Development Framework Plan" providing an indication of the site's development capacity; c.570 dwellings set within 18ha of green infrastructure.

1.4 Following the Council's consideration of these representations, Barratt would welcome the opportunity to meet with Officers of Walsall Council to present and discuss the emerging proposals for the land at Stencils Farm.

Statement Structure
1.5 This Statement is structured to provide a specific response to relevant Questions posed within the Council's IOR. Sections 2 to 15 respond to Questions 1-3, 5, 7-9, 11a, 12a, 12b, 13a, 13c, 13d and 15a.

Contact Details
1.6 Should any further information be required please contact:
Matthew Fox
Associate Director
T: 0121 213 5549
E: matt.fox@rpsgroup.com
 
2 QUESTION 1 - PARTIAL REVIEW
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?

2.1 Barratt supports the decision of the four authorities to commence a review of the BCCS. The BCCS is now six years old, pre-dating both the National Planning Policy Framework (NPPF) and National Planning Practice Guidance (NPPG), and sought to deliver growth targets based upon historic and outdated evidence, in particular the revoked West Midlands Regional Spatial Strategy (WMRSS) Phase Two Revision Panel Report. As acknowledged in the IOR, it is necessary to review the BCCS to provide an up-to-date strategic development plan to identify and deliver growth requirements across the Black Country in the period to 2036. Barratt intend to take an active role in the BCCS Review process.

2.2 Para. 1.6 of the IOR states that the BCCS "...will generally remain fit for purpose" and that it is "...proposed to carry out a partial review of the existing Core Strategy ... rather than carry out a wholescale review". Para. 3.61 states that a "selective" review is needed.

2.3 We recognise that many of the detailed "development management" type policies may be appropriate to carry forward as part of the BCCS Review. However, everything else in the adopted BCCS will need to be reviewed, particularly as strategic matters need to be revisited, namely; housing and employment need/requirements, spatial distribution strategy and land supply, with the latter inevitably requiring Green Belt releases based upon the scale of housing and employment need (IOR para. 3.17). The scale of the housing need is such that Green Belt releases will need to be delivered through strategic allocations within the BCCS Review rather than deferred to lower order development plan documents.

2.4 We highlight that the Inspectors appointed to review the BCCS were supportive of the "commitment to a full review" of the BCCS, rather than a partial review (emphasis added) (para. 236 of their Report, October 2010).

2.5 The scale of housing and employment growth identified in the IOR over the proposed plan period is significantly greater than that planned for in the BCCS and represents a step change on past rates of completion. The IOR acknowledges that the urban areas will not be capable of accommodating all of this growth. The spatial strategy in the BCCS review will therefore have to be fundamentally different to that within the adopted BCCS, so we consider it misleading to state that the existing spatial strategy will be "stretched". The growth requirements amount to an exceptional circumstance to justify the release of Green Belt land so this will have to form part of the new spatial strategy. Such releases were not necessary in the adopted BCCS, so it is important that the review acknowledges that the spatial strategy will be fundamentally different, rather than simply "stretched".

2.6 One could infer from the references to retaining and stretching the spatial strategy (para. 1.6), and "urban regeneration" (para. 1.19) remaining the focus, that the authorities have already agreed upon the spatial strategy. However, the spatial strategy forms part of the review and Questions 10 and 11 of the IOR seek views on strategic distribution options. It is therefore critical that the authorities do not commence the review process with a closed mind and predetermined spatial strategy. Rather, we urge the authorities to consider and assess all potential spatial options before settling upon a preferred option.

2.7 In summary, we consider references to a "partial" and "selective" review, and "stretching" the existing spatial strategy, to be wholly misleading. It should be acknowledged that an extensive review is required which will have to revisit the fundamental and strategic objectives/policies of the adopted BCCS.

2.8 The IOR does not include a question on the proposed plan period but we wish to record support for the 2014-36 timeframe (para. 1.17). 2014 aligns with the base date of the most up-to-date Household Projections and the end date provides a 15 year period from the envisaged date of adoption of the BCCS Review (2021).

2.9 We recognise that the preparation and examination of a joint development plan takes a considerable amount of work and agreement but we would urge the authorities to advance the review process as swiftly as possible. The authorities have acknowledged that the need for a review is urgent (para. 1.4 of the IOR) although adoption is not anticipated until Autumn 2021, with a five year review process when considering that it commenced in 2016. This would mean that the BCCS review will not be adopted until a decade after the BCCS, and will result in delays to the delivery of strategic allocations.

2.10 It is important that the identified development needs of the Black Country and wider Housing Market Area (HMA) are met as quickly as possible so we urge the authorities to progress the review as swiftly as possible, and to ensure that strategic allocations are delivered through the BCCS review rather than lower order development plan documents.

3 QUESTION 2 - EVIDENCE BASE

Q2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review?

3.1 Paragraph 159 of the NPPF advises that plan makers should have a clear understanding of housing needs in their area through the preparation of a Strategic Housing Market Assessment (SHMA). It requires a SHMA to identify the scale, mix and tenures of housing that the population is likely to need over the plan period. The Black Country and South Staffordshire SHMA (March 2017) has been prepared to address this national policy requirement, and provides a critical piece of evidence for the BCCS review.

3.2 RPS has considerable experience when considering objectively assessed housing need (OAN) having participated in numerous local plan examinations on this matter. We provide detailed comments on the SHMA in response to Question 3 but wish to highlight here that it is critical that the SHMA is refreshed at appropriate points during the review process (potentially to 2021) to ensure it remains valid. In particular, we wish to highlight that:
* New 2016-based Household Projections are programmed for release in summer 2018, and further releases are likely if the review programme extends to 2020/21; and
* The DCLG has pledged to revise the way in which housing need is calculated, as noted in the Housing White Paper (February 2017). Its standard methodology for calculating OAN is expected to be published for consultation during September 2017 and it is likely that the review will need to reflect this.

3.3 The 2017 SHMA must not therefore be viewed as a settled document but, rather, will need to be refreshed at appropriate points to reflect new and up-to-date policy, guidance and evidence.

3.4 As stated in our response to Question 5, we support the need for a Green Belt Review to be commissioned and completed during 2018. The scale of housing need and existing supply position provides an exceptional circumstance to justify Green Belt land release.

4 QUESTION 3 - HOUSING NEED AND SUPPLY

Q3 - 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?
Housing Need

4.1 The IOR states that the Objectively Assessed Need for Housing (OAN) for the Black Country Housing Market Assessment (HMA) is 78,190 dwellings across the period 2014-2036. To inform this calculation, the authorities have undertaken an updated Strategic Housing Market Assessment (SHMA) (March 2017). In addition to the four Black Country authorities, the SHMA also covers the future housing need for South Staffordshire.

4.2 RPS has reviewed the SHMA in detail and questions whether a fair or proportionate approach has been adopted in deriving this figure. We consider that further adjustments are necessary in order to present a sound OAN that is capable of withstanding scrutiny through the Examination.

4.3 It is also recognised that the Government is intent on reforming the current approach for calculating housing need and, as a consequence, a consultation methodology is likely to be published in September 2017. These representations are made without the benefit of viewing the consultation methodology although they do reflect on what may be included.

4.4 In summary, RPS considers that the OAN for the Black Country is insufficient and needs to be increased. RPS has taken into account more robust assumptions than relied upon in the 2017 SHMA, arriving at an OAN of 85,930, or 3,906dpa which is considered a more appropriate figure. This is 9.9% higher than the Councils' calculation and should be accounted for to ensure that the Councils are planning for the correct level of growth.

4.5 In addition to the Councils' own OAN, RPS considers that more needs to be done in order to establish the housing requirement for the plan period. Whilst the OAN informs what is necessary to meet the forecast housing need, the requirement can be higher to take account of policy factors such as economic growth aspirations and unmet need from across the wider HMA. A testing provision of an additional 3,000 dwellings is proposed within the IOR, as a contribution towards the unmet needs Birmingham.

4.6 The evidence supporting RPS' approach to OAN including a wider critique of the Councils approach is detailed under the various headings below.
Demographic Starting Point

4.7 Although the Planning Practice Guidance (PPG) recognises that there is no single approach to calculating OAN, it is recognised that the starting point should be the projections published by ONS which, presently, are updated biennially. The latest forecast published comprise the 2014-based Sub-national Population Projections (2014 SNPP) and the 2014-based Sub-national Household Projections (2014 SNHP). These projections will remain up-to-date until summer 2018, when ONS will publish the 2016-based projections.

4.8 The 2017 SHMA has utilised the 2014-based projections to establish the demographic starting point, which is the correct approach to take. Framed against the proposed plan period 2014-2036, the 2014 SNPP indicate that there will be a growth of 73,572 dwellings across the HMA. These are the unadjusted figures which the Councils rely upon by the 2017 SHMA.

4.9 In order to convert these from households into dwellings, it is necessary to apply a conversion factor, which accounts for second homes and vacant homes that exist in the dwelling stock. This information is not clearly presented in the 2017 SHMA. However, RPS has calculated the conversion factor taken from the latest data available . As illustrated in Table 4.1, applying this factor presents a total dwelling growth of 80,066 dwellings for the five authorities.

Table 4.1: SNHP 2014 Baseline Growth Projections
Growth 2014-2036 Vacancy Rate Second Home Rate Conversion Factor Dwellings
Dudley 11,727 2.5% 0.2% 2.7% 12,044
Sandwell 29,088 2.5% 0.0% 2.5% 29,815
Walsall 17,544 2.2% 0.2% 2.4% 17,962
Wolverhampton 15,213 2.9% 0.3% 3.2% 15,695
South Staffordshire 4,437 2.3% 0.3% 2.6% 4,550
Total 78,009 80,066

4.10 The 2017 SHMA includes a baseline dwelling increase of 80,055 across the five planning authorities. This is only 11 dwellings different from the figures in Table 4.1, so provides a good sense check against the baseline projections.

4.11 Although not currently modelled by RPS, it is recommended that the demographic forecasts are updated to reflect subsequent Mid-Year Population Estimates (MYEs) provided by ONS, which may differ from the baseline projections. In terms of the current data available, the 2015 and 2016 MYEs have been published and should be factored into the assessment of OAN as part of future iterations of the SHMA.
 
Demographic Adjustments

4.12 The PPG recognises that the population and household projections prepared by ONS are trend based, resulting from past changes in local demography. The PPG advises that the household projections may need to be adjusted to reflect factors not captured in past trends. This can be explored through the consideration of the components of the population projections, in relation to longer term trends and an assessment of household formation rates, which may have been constrained by a shortage of housing supply. The 2017 SHMA's approach to both of these issues is set out below.
Household Formation Rates

4.13 The 2017 SHMA takes a cursory view of Household Formation Rates (HFRs), presenting the latest 2014-based projections in relation to how these are expected to change over the plan period. The 2017 SHMA indicates (paragraph 4.33/4.34 refers) that the evidence does not suggest rates have been suppressed by a lack of supply, pointing instead to a lack of viability in the market to build new homes which young adults can access. RPS questions whether this is a robust assumption, and the assertion in the 2017 SHMA (paragraph 4.49) that HFRs in younger age cohorts are performing well. No evidence has been provided to consider past formation rates as part of the assessment, which is not consistent with the aims of the PPG.

4.14 Turning to the previous treatment of HFRs, RPS has considered these against the younger age cohorts in particular, to consider whether there has been any departures from trend. Figure 4.2 considers the formation rates for the 25-34 age cohort across the HMA. This indicates that across the board for this age group, the formation rates have significantly decreased from around the year 2000, and the projections have embedded this reduction into the forecasting years ahead.
Figure 4.2: 2014-based Household Formation Rates for Black Country and South Staffordshire

4.15 RPS considers that adjustments to HFRs for this age cohort are necessary and have been overlooked by the 2017 SHMA. In response to this, we propose that the 2017 SHMA should be amended to uplift the HFRs in the 25-34 age cohort to robustly capture any shortcomings of the household projections.

4.16 This departure from trend is consistent with the research of McDonald and Williams, who noted this in their 2014 report on behalf of the RTPI when they drew on evidence indicating that a major change to formation rates since 2001 has been the trend for young adults living in either the parental home or in shared accommodation, led in part to issues linked to housing shortage and affordability during the economic downturn.

4.17 We consider that there is compelling evidence to uplift the HFRs. Although this has not been modelled by RPS, this adjustment should be made as part of a future SHMA and for the purposes of this assessment, the OAN is presented as a minimum figure as it is expected that the actual OAN will be higher once this factor is accounted for.
Accounting for Past Delivery

4.18 The 2017 SHMA recognises the need for consistency throughout the wider HMA, recognising that the BCCS review sits in the context of the wider Greater Birmingham HMA.

4.19 The 2017 SHMA draws on the Strategic Housing Needs Study (SHNS) which identified the housing need in the wider HMA from 2011 onwards. The 2017 SHMA has taken the view that completions from 2011 up to the start of the Plan period (2014) should be considered against the projections in the SHNS to consider whether there have been any shortfalls in delivery. In total, a gap of 2,689 dwellings is identified (table 4.6 of the 2017 SHMA refers) across this three year period. This is added to the Councils' demographic starting point. This is considered a reasonable action to take, which is presented in Table 4.3:
Table 4.3: Accounting for Shortfalls in Delivery 2011-2014
Demographic Starting Point SHNS Shortfall Total
Dudley 12,044 125 12,169
Sandwell 29,815 2,047 31,862
Walsall 17,962 516 18,478
Wolverhampton 15,695 -85 15,610
South Staffordshire 4,550 86 4,636
Total 80,066 2,689 82,755

Market Signals

4.20 Section 5 of the 2017 SHMA reviews information associated with market signals in the Black Country, taking the view that the housing market in the HMA is relatively stable and other than South Staffordshire, there is no need for further adjustment to the OAN (paragraph 5.69 refers). RPS questions this conclusion and considers that the relationship of affordability pressures in the District warrant the need for further uplifts.

4.21 One approach to consider market signals across the HMA would be to apply the methodology recommended by the Local Plans Expert Group (LPEG) report to Government. The LPEG recommendations propose a methodology for the consideration of market signals, based on two indicators; median quartile housing affordability and lower quartile rental affordability. The LPEG recommendations indicates four brackets of potential market signals uplift ranging from 0% to 25% depending on the severity of affordability issues, which are replicated below:
* House Price Ratio less than 5.3 and Rental Affordability less than 25% = No uplift
* House Price Ratio at 5.3 - 6.9 and/or Rental Affordability between 25% - 29% = 10% uplift
* House Price Ratio at 7.0 - 8.6 and/or Rental Affordability between 30% - 34% = 20% uplift
* House Price Ratio at 8.7+ and/or Rental Affordability is +35%= 25% uplift

4.22 In terms of the median quartile House Price Ratio (HPR), the latest data published for 2016 has been published by ONS. ONS has provided two data sets for median affordability, based on "workplace" and "residence" based earnings. The residence based dataset is considered a more appropriate dataset to use, which aligns with the historical projections provided by DCLG. In terms of rental prices, this can be calculated using lower quartile wages taken from ONS data, aligned with monthly rental data from the Valuation Office Agency (VOA), which provides a Rental Affordability Ratio (RAR). This information for the Black Country Authorities is captured below:

Table 4.4: Market Signals Uplifts in Black Country and South Staffordshire
HPR RAR Uplift
South Staffordshire 7.67 31% 20%
Dudley 5.35 24% 10%
Sandwell 7.56 26% 10%
Walsall 5.39 25% 10%
Wolverhampton 5.31 24% 10%

4.23 Using the LPEG methodology, this suggests that 10% increases to the demographic baseline are necessary (and an uplift of 20% should be attributed to South Staffordshire where the market signal pressures are more acute). The figures suggest that Sandwell could also be qualified as a 20% market signals authority, though a conservative approach has been adopted at this stage of assessment.

4.24 Relating this data to the LPEG methodology, it is clear that market signals cannot simply be discounted for the Black Country and there is a need to ensure that there are appropriate increases to the OAN to reflect the balance between the supply and demand for housing. It is therefore proposed to apply the LPEG methodology to capture affordability related market signals in the Black Country area.

Table 4.5: Market Signals Uplift
Demographic OAN + Shortfall Uplift Market Signals Adjusted OAN
Dudley 12,169 10% 13,385
Sandwell 31,862 10% 35,048
Walsall 18,478 10% 20,325
Wolverhampton 15,610 10% 17,171
South Staffordshire 4,636 20% 5,563
Total 82,755 91,494

Accounting for Employment Growth

4.25 The SHMA has only taken a cursory review of employment data, relying on a single post-brexit forecast as part of the assessment to whether the future population balances the forecast growth in jobs. Additionally, we consider that the SHMA needs to give greater consideration to what can realistically be expected in terms of future economic activity rates, as this will impact on the translation of workplace job forecasts when considering the future availability of working age population. RPS would expect that this matter is more fully developed as part of a subsequent update.

Summary of OAN for Black Country and South Staffordshire

4.26 Taking into account the above steps, RPS' initial review of the OAN in the Black Country is presented in Table 4.6:
 
Table 4.6: Summary of Necessary Steps to Identify OAN for Black Country and South Staffordshire
Household Change 2014-2036 Dwelling Change 2014-2036 Unmet Need from SHNS Household Formation Rate Adjustment Market Signals Uplift
Dudley 11,727 12,044 12,169 TBC 13,385
Sandwell 29,088 29,815 31,862 TBC 35,048
Walsall 17,544 17,962 18,478 TBC 20,325
Wolverhampton 15,213 15,695 15,610 TBC 17,171
South Staffordshire 4,437 4,550 4,636 TBC 5,563
Total 78,009 80,066 82,755 TBC 91,494

4.27 Not accounting for growth in South Staffordshire, the above table indicates that the minimum OAN for the Black Country is 85,930 dwellings. This figure is 7,740 dwellings higher than the Council's proposed figure of 78,190, and has yet to account for the necessary uplifts to account for HFR suppression.

4.28 The RPS figure of "policy off" OAN is significantly higher than that presented in the 2017 SHMA. The adjustments made to reach the figure of 85,930 are not unreasonable and grounded in a robust set of assumptions. RPS therefore recommends that Black Country authorities consider the implications of these findings from an early stage, to ensure that the strategy for identifying sites is clear from the outset and delivers the level of growth that is required.

Housing Requirement

"Policy on" Employment Growth

4.29 The NPPF requires that authorities plan to meet their OAN in full, accounting for both market and affordable housing. In addition, the NPPF requires authorities to work together to work collaboratively to deliver sustainable economic growth, delivered through Local Enterprise Partnerships (LEPs).

4.30 Beyond the OAN, the Black Country authorities should give consideration to how the BCCS Review can be used to support economic growth and the aims of the Black Country LEP (BCLEP) and West Midlands Combined Authority (WMCA) Strategic Economic Plan (SEP).

4.31 As part of Appendix B to the 2017 SHMA, a "Policy On" approach has been tested which seeks to translate the aspirations of the LEP to increase the number of jobs in the WMCA by 600,000 by 2030. The 2017 SHMA has translated this into the Black Country through the consideration of 80,000 jobs across the plan period.

4.32 RPS highlights that the Draft Black Country Strategic Economic Plan (SEP), which was published in May 2017, identifies a job growth of 103,000 additional jobs in the Black Country up to 2030. In terms of testing a "Policy On" scenario, future iterations of the SHMA should consider the implications of this more recently published figure which is specific to the Black Country.
Unmet Need from Outside the HMA

4.33 The Duty to Cooperate (DtC) places a legal mandate on local authorities to work together to address strategic cross-boundary issues through the local plan process. There is a clear and significant unmet need arising from the Birmingham Development Plan, which against a target of 89,000 dwellings, has a shortfall of 38,000 dwellings.

4.34 The GBSLEP has coordinated a number of Joint Strategic Housing Needs Studies (JSHNS) to consider where shortfalls arising from Birmingham could be met, taking into account the functional relationship to the City and the ability to accommodate further housing need. Presently three studies have been prepared, the latest dated August 2015 and a further "Stage 4" study has been commissioned (entitled "Greater Birmingham and Black Country HMA Strategic Growth/Locations Study") which is expected to be published during autumn 2017.

4.35 As a response to the shortfalls arising from Birmingham, the IOR indicates that it will test whether 3,000 dwellings can be accommodated within the Black Country up to 2031 (following the Birmingham Local Plan timeframes) to contribute towards the shortfall in the wider HMA. RPS welcomes the authorities proactive stance towards accommodating cross-boundary needs particularly given that the Black Country shares clear functional relationships with Birmingham in terms of migration and commuting. It is, however, unclear how the 3,000 contribution has been arrived at and we request that the rationale behind this level of provision be explained.

Housing Supply

4.36 The Housing Supply Background Report (HSBP) (July 2017) summarises potential sources of housing supply across the Black Country. Completions since 2014 amount to 5,678 dwellings (2,839 per annum). Potential supply for the period 2016-36 from commitments and windfall sites included within the adopted/emerging development plan documents and four SHLAAs amounts to 45,416 dwellings. Finally, potential additional supply from both small and large windfall sites and from increased densities amounts to 5,426 dwellings. The total potential supply is therefore stated as 56,520 dwellings.

4.37 It is apparent that windfalls make up a significant portion of the identified supply; it is not possible to confirm the figure using the HSBP although the IOR states that the figure is 8,335 (Figure 6) equating to 15% of the identified supply. Relying on such a large windfall allowance attracts significant risks in relation to housing delivery because it relies upon a considerable number of unidentified sites coming forward, despite the fact that the SHLAAs will have already investigated the potential for large windfall sites. It is considered that the SHLAAs will have to be refreshed as part of the BCCS Review to provide a more definitive position on potential housing supply within the urban areas. Updates to the HSBP should also provide a clear breakdown of the supply categories for each authority for transparency; this will be critical in assessing the deliverable/developable housing supply.

4.38 Even when allowing for such a huge windfall allowance, the overall supply position is stark in the context of the emerging housing need; there is a shortfall of almost 22,000 dwellings against the 2017 SHMA OAN, which means that 28% of the Black Country's housing need to 2036 is currently unaccounted for. This shortfall would be even more pronounced against the OAN figure presented by RPS; 29,410 dwellings (34% of the need). Furthermore, this shortfall disregards the 3,000 dwellings which the authorities have committed to test as a contribution to Birmingham's unmet needs.

4.39 To put these shortfall figures into context, they equate to a need for 629 - 840ha of net developable housing land over and above all of the currently identified supply (assuming a net density of 35 dwellings per hectare as applied in the HSBP). Obviously, the gross land requirement would be even greater. It is therefore clear that significant Green Belt releases will be required.

Employment Land Release

4.40 Para. 3.16 of the IOR alludes to the potential release of additional surplus employment land for housing during the final decade of the proposed plan period (2026-36). A "maximum" figure of 10,400 dwellings is stated from this potential source, and whilst this has not been included within Figure 6 of the IOR as a potential source of supply, we urge caution in making assumptions around such additional employment land releases for the following reasons:
* The figure of 10,400 is crudely calculated on the basis of projecting forward the 300ha of employment land planned to be released between 2016 and 2026 and then applying a residential density of 35dph. This is a simplistic method of calculation which is not founded upon a robust evidence base on the need for employment land and the potential quantum of surplus employment land which is potentially suitable for residential development;
* The Economic Development Needs Assessment (May 2017) (EDNA) recommends that the review plans for the provision of up to 800ha of additional employment land to meet needs, with a "gap" of upto 300ha (IOR para. 3.27). This is obviously a huge requirement and appears to be in direct conflict with the suggestion that up to 600ha of existing surplus employment land will be released over the plan period; and
* The potential supply figures in Figure 6 of the IOR already provide a considerable windfall allowance which will inevitably include redevelopment of surplus employment sites, so seeking to add in a further employment land supply runs the risk of double-counting.

4.41 In summary, any potential for further release of surplus employment land beyond 2026 must be quantified based upon a robust evidence base which has regard to the need for employment land over the plan period. Such evidence must be aligned to the SHLAAs to ensure that each provides a thorough assessment of the supply from potentially surplus employment sites identified through the EDNA. The EDNA suggests that there will be a significant need for additional employment land to be allocated which flies in the face of the suggestion at para 3.16 of the IOR that further employment land could help to "close the gap" in the housing supply.
Conclusions on Overall Housing Supply

4.42 To conclude, the authorities are facing a considerable challenge in meeting their own housing needs, let alone any contribution towards the unmet needs of Birmingham. The authorities have identified potential supply within the urban areas which demonstrates a significant shortfall. The scale of the shortfall is huge - equating to approximately a third of the need - even when allowing for a large unidentified and speculative supply in the form of windfall sites. The authorities must therefore acknowledge that a fundamentally different spatial strategy is required compared to that enshrined in the BCCS.

4.43 With respect to para. 1.39 of the Housing White Paper (February 2017), it is evident that the authorities have fully examined all other reasonable options for meeting their identified housing requirements and, as such, the shortfall must be acknowledged as an "exceptional circumstance" (NPPF para. 83). This justifies the alteration of the Black Country's Green Belt boundaries to allow land to be released (through a Green Belt Review) to accommodate sustainable housing development beyond the urban areas. Such releases and allocations must be delivered through the strategic plan rather than deferred to lower order development plan documents. We explore these issues in greater detail in response to Questions 5, 7, 8, 9, 11, 12 and 13.

4.44 Once the housing supply has been identified, the authorities ought to consider a contingency allowance (circa 20% uplift) to provide sufficient flexibility in responding to changing circumstances and in recognition that the housing requirement is a minimum, rather than maximum, figure.
Position relative to individual authority areas

4.45 The HSBP indicates that only Dudley has a supply which is capable of meeting its own needs (an excess of c.3,400 dwellings). This overprovision could therefore help to address shortfalls across the three other authorities, or Birmingham.

4.46 The most pronounced shortfall is within Sandwell; 13,500 dwellings. This Borough is almost entirely built-up with minimal opportunities to accommodate the shortfall through Green Belt releases. It is therefore likely that its unmet needs will need to be delivered in adjoining authority areas.

4.47 Wolverhampton is projected to have a current shortfall of c.3,300 dwellings. There are areas of Green Belt land around the peripheries of the City which could potentially accommodate this shortfall.

4.48 Finally, Walsall has an OAN of c.18,500 but an identified supply of only c.10,200 dwellings, resulting in a shortfall of c.8,200. This represents the second highest shortfall of the four authorities (if RPS' OAN figure (above) were to be applied this shortfall would increase to 10,000 dwellings). Walsall is unique in the Black Country context insofar as it encompasses an extensive area of Green Belt which lies in-between Walsall, Birmingham, Aldridge and Brownhills. It is understood that this amounts to c.70% of the Green Belt within the Black Country as a whole. Whilst not all of this will be suitable for release and development it should be recognised that Walsall has a significant area of undeveloped Green Belt land which provides an opportunity to accommodate its own shortfall (and potentially others) through selected Green Belt releases to permit sustainable urban extensions within the heart of the West Midlands conurbation, and in close proximity to Birmingham (which has the largest shortfall of all the authorities).

5 QUESTION 5 - GREEN BELT REVIEW

Q5 - Do you agree with the proposed approach to the Black Country Green Belt Review?

5.1 As explained in our response to Question 3, there can be no question of the need for a Green Belt Review across the Black Country given the identified scale of growth and current shortfalls in land supply within the urban areas (for both housing and employment). The housing shortfall from Birmingham only reinforces this need. Similar Green Belt reviews are/have taken place across the West Midlands including Bromsgrove, Solihull and Lichfield (releases are currently proposed in the latter two).

5.2 The scale of the potential shortfall is a matter of regional significance and the Green Belt Review must be addressed through the BCCS review, in order to formulate an appropriate spatial strategy to accommodate sustainable growth and identify the most appropriate sites for release from the Green Belt. We therefore welcome the recognition in the IOR at para. 3.42 of the need to identify sites on land outside of the urban area and that "nearly all such land is currently Green Belt". However, the IOR does not explicitly acknowledge that "exceptional circumstances" exist. We urge the authorities to accept this position and move forward proactively with a Green Belt Review as swiftly as possible and in a manner which provides a comprehensive and consistent assessment of the potential for sustainable land releases across the Black Country (and beyond), and which allows appropriate releases to be delivered through the BCCS review (as opposed to lower order development plan documents).

5.3 We recognise that the Greater Birmingham Strategic Growth/Locations ("Stage 4") Study includes a strategic Green Belt Review and this will inform the BCCS Green Belt Review. We understand that this will be strategic in scope and will not be subject to consultation, nor formally endorsed by each of the councils within the HMA. As such, we request that the Black Country Green Belt Review be subjected to consultation, prior to its finalisation/adoption and prior to the Preferred Option stage.

5.4 As stated in response to Question 3, Walsall is unique in the Black Country context insofar as it encompasses an extensive area of Green Belt which lies in-between Walsall, Birmingham, Aldridge and Brownhills. It is understood that this amounts to c.70% of the Green Belt within the Black Country as a whole. Whilst not all of this will be suitable for release the Green Belt Review must recognise that Walsall has a significant area of undeveloped Green Belt land which provides an opportunity to accommodate the authority's own shortfall and, potentially, that of others through selected releases to permit sustainable urban extensions within the heart of the West Midlands conurbation, and in close proximity to Birmingham (which has the largest shortfall of all the authorities). Walsall should therefore be a key focus of the Green Belt Review.

5.5 We attach as Appendix 1 an assessment of the strategic Green Belt sites in Walsall which have been promoted through previous rounds of development plan consultation for residential development. This has been completed by FPCR on behalf of Barratt and provides an evidence base which should be taken into account as part of the Green Belt Review.

6 QUESTION 7 - VISION AND SUSTAINABILITY PRINCIPLES

Q7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate?

6.1 The Vision reflects the three dimensions of sustainable development within the NPPF and is therefore considered to be broadly appropriate. However, we would suggest that the first "major direction of change" - Sustainable Communities - should include reference to the delivery of sustainable urban extensions in the Green Belt, as it is currently focused upon "regeneration" (which we recognise will continue to be important).

6.2 Turning to the Sustainability Principles, these need to be amended to:
* Reflect the need for sustainable Green Belt releases. Number 4 includes a "brownfield first" principle which is inconsistent with national planning policy. It is recognised that national policy requires Councils to re-use previously developed land (PDL) but the BCCS Review should not be prioritising brownfield first. Furthermore, there needs to be recognition that significant Green Belt releases are necessary to meet the growth requirements. The scale of housing need is such that greenfield land will have to be delivered alongside brownfield land;
* Principle 5 proposes a comprehensive approach which remains appropriate but the references to Site Allocation Documents and AAPs documents as the "preferred mechanism" for "areas of large-scale change" needs to be updated to reflect the need for strategic Green Belt releases and allocations to be delivered through the BCCS Review, rather than deferred and delayed to other development plan documents; and
* Update the text at para. 2.4 as growth is unlikely to be concentrated within Strategic Centres and approximately a third of the housing requirement will need to be delivered on greenfield sites within the Green Belt.

7 QUESTION 8 - SPATIAL OBJECTIVES

Q8 - Do you think that the Core Strategy spatial objectives remain appropriate?

7.1 We agree with IOR para. 4.7; the Spatial Objectives provide a "sound basis" for the BCCS Review but some will inevitably need to be amended to reflect the new evidence base. In particular, the housing shortfall amounts to an "exceptional circumstance" to justify the release of land from the Green Belt and, based upon the Councils' own data, approximately a third of the housing requirement may need to be delivered from such releases, so this must be reflected in the Spatial Objectives.

7.2 The IOR (para. 3.18) states that the authorities have committed to "test" the accommodation of 3,000 homes to help address the shortfall from across the wider HMA. Any such provision will need to be reflected in the Spatial Objectives.
 
8 QUESTION 9 - STRATEGIC POLICIES

Q9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network?

8.1 Policies CSP1 and CSP2 will need to be comprehensively rewritten to reflect the significant change in circumstances, principally the major shortfall in housing and employment land in the urban areas and the resultant need to introduce a fundamentally different spatial strategy which provides for a significant portion of new development to be delivered through Green Belt releases.

8.2 As outlined in our response to Question 8, based upon the Councils' own data, approximately a third of the housing requirement may need to be delivered through Green Belt releases, so this will need to be reflected in the strategic policies. Indeed, it is likely that there will need to be a specific strategic policy addressing the release of Green Belt land.
 
9 QUESTION 11A - SPATIAL STRATEGY

Q11a - Do you support Strategic Option 1A or 1B?

9.1 Para. 4.14 of the IOR states that the main variable between Options 1A and 1B is the availability of employment land within the Growth Network. The authorities are proposing to retain the Growth Network as the focus in meeting the "majority" of the development needs (para. 4.11).

9.2 Our response to Question 3 explains that any potential for further release of surplus employment land beyond 2026 must be quantified based upon a robust evidence base which has regard to the need for employment land over the plan period. Such evidence must be aligned to the SHLAAs to ensure that each provides a thorough assessment of the supply from potentially surplus employment sites identified through the EDNA. Significantly, the EDNA suggests that there will be a significant need for additional employment land to be allocated which flies in the face of the suggestion at para 3.16 of the IOR that further employment land could help to "close the gap" in the housing supply. In relation to the figure of 10,400 dwellings being released from additional employment land releases between 2026 and 2036 (Figure 9), please refer to our response to
Question 3 which identifies significant concerns with the assumptions underpinning this figure.

9.3 Having regard to the above, we consider that Option 1A will need to form the basis of "Stage 1" unless a robust evidence base can be produced, which differs from the existing EDNA and SHLAAs, to demonstrate that there is additional surplus employment land within the urban areas which is deliverable/developable for housing.

9.4 Either way, it is inevitable that significant Green Belt land release will be required to meet the housing shortfall, rather than "some" as stated in IOR para. 4.14.

9.5 The IOR asserts that Option 1B "...may allow more housing need to be met within the Black Country" (para. 4.18 and reiterated in the table on page 40). No explanation is provided for this statement and it is unclear why releasing additional employment land will have the effect of increasing housing supply compared to Option 1A. As acknowledged in the IOR, further Green Belt releases would be needed to offset the loss of existing employment land (para. 4.19) but under 1A this could be developed for housing instead. Figure 9 is deceptive in this regard as it does not explain that Green Belt land would need to be released to reprovide employment land.

9.6 Finally, there are deliverability issues associated with 1B with the need to redevelop existing employment land. Such redevelopment attracts significant costs in relation to demolition, site clearance and land remediation, often requiring assistance from public subsidy (and often at the expense of affordable housing delivery). This approach is therefore likely to cause significant delays to the delivery of housing land which will be contrary to the need to "boost significantly" housing land supply (NPPF para. 47).
 
10 QUESTION 12A - SPATIAL OPTION H1

Q12a - Do you support Strategic Option H1? What criteria should be used to select suitable sites?

10.1 Barratt considers that the identification of housing allocations beyond the Growth Network should be informed by the SHLAAs, Sustainability Assessment and the Green Belt Review. These will enable the identification of sites having regard to sustainability/accessibility, deliverability/developability ("suitability", "availability" and "achievability" tests (NPPF and PPG)) and Green Belt criteria (assessment against the five purposes of Green Belt in NPF para. 80).

10.2 The two Spatial Options are presented as mutually exclusive in the IOR which is unclear and considered to be a flawed assumption. Given the scale of the shortfall, it is likely that both small-medium (H1) and strategic Sustainable Urban Extensions (SUE) (H2) will need to be identified in order to meet the housing shortfall and it is necessary to provide a diverse range of housing allocations to ensure that all sectors of the housebuilding market are engaged in delivering housing simultaneously to meet needs as swiftly as possible.

10.3 To put the housing shortfall into context, 22,000 dwellings is the figure stated throughout the IOR purely to meet the Black Country's needs and will equate to 629ha of net developable housing land (over and above all of the currently identified supply) when assuming a net density of 35 dwellings per hectare (as applied in the HSBP). This requirement would obviously increase if the Black Country agrees to meet the unmet needs of the wider HMA, and RPS has presented a higher OAN figure in response to Question 3 which would also increase the land requirement significantly. The shortfall will need to be met primarily through Green Belt release and the scale of requirement means that strategic releases in the form of SUEs will have to be delivered through the BCCS review process, in addition to small-medium Green Belt releases (the scale of which is not defined in the IOR).

10.4 Strategic residential allocations are generally defined in Local Plans as developments of at least 500 dwellings, although SUEs can be smaller in scale. We suggest a minimum size of 250 units and such larger sites should be allocated through the BCCS Review.

10.5 We concur with the statements in para. 4.28 of the IOR which acknowledges that SUEs are better placed to comprehensively deliver, or contribute towards, supporting physical and social infrastructure.

11 QUESTION 12B - POTENTIAL LOCATIONS

Q12b - Do you think there are any potential locations that should be considered?

11.1 Barratt has submitted a Call for Sites submission for land at Stencils Farm, Walsall, comprising a covering letter, completed Questionnaire and a suite of supporting technical reports which includes a "Development Framework Plan" providing an indication of the site's development capacity; c.570 dwellings set within 18ha of green infrastructure.

11.2 The land at Stencils Farm provides a highly sustainable option to assist in delivering Walsall's emerging housing need through the BCCS Review. Of the eight strategic residential Green Belt sites in the Borough previously promoted for residential development, Stencils Farm provides a limited contribution to the five national purposes of Green Belt (second to only one other site) (refer to Appendix 1). It lies close to Walsall town centre with good public transport and walking/cycling links to local facilities, and is well contained providing a valuable opportunity to create a robust settlement edge and Green Belt boundary with a soft transition to the countryside. This transition would comprise a strategic area of green infrastructure adjoining the canal, providing a linkage between two "Wildlife Corridors".

11.3 The site is deliverable and we respectfully request that it be considered as an allocation through the BCCS Review.

11.4 The potential scale of development on the land at Stencils Farm means that it would qualify as a Sustainable Urban Extension but it is presented in response to this question given that the scale of SUEs has yet to be determined.

11.5 Barratt intend to fully engage with Walsall Council and the local community over forthcoming months to discuss the site and proposed development in greater detail.
 
12 QUESTION 13A - SPATIAL OPTION H2

Q13a - Do you support Spatial Option H2? What should the characteristics of SUEs be? What criteria should be used to select suitable sites?

12.1 Barratt considers that the identification of housing allocations beyond the Growth Network should be informed by the SHLAAs, Sustainability Assessment and the Green Belt Review. These will enable the identification of sites having regard to sustainability/accessibility, deliverability/developability (suitability, availability and achievability test (NPPF and PPG)) and Green Belt criteria (assessment against the five purposes of Green Belt in NPF para. 80).

12.2 Barratt supports the identification of Strategic Urban Extensions (SUEs) under Spatial Option H2. However, the two Spatial Options are presented as mutually exclusive in the IOR which is unclear and considered to be a flawed assumption. Given the scale of the shortfall both small-medium (H1) and SUE (H2) will need to be identified in order to meet the housing shortfall and it is necessary to provide a diverse range of housing allocations to ensure that all sectors of the housebuilding market are engaged in delivering housing simultaneously to meet needs as swiftly as possible.

12.3 To put the housing shortfall into context, 22,000 dwellings is the figure stated throughout the IOR purely to meet the Black Country's needs and will equate to 629ha of net developable housing land (over and above all of the currently identified supply) when assuming a net density of 35 dwellings per hectare (as applied in the HSBP). This requirement would obviously increase if the Black Country agrees to meet the unmet needs of the wider HMA, and RPS has presented a higher OAN figure in response to Question 3 which would also increase the land requirement significantly. The shortfall will need to be met primarily through Green Belt release and the scale of requirement means that strategic releases in the form of SUEs will have to be delivered through the BCCS review process, in addition to small-medium Green Belt releases (the scale of which is not defined in the IOR).

12.4 Strategic residential allocations are generally defined in Local Plans as developments of at least 500 dwellings, although SUEs can be smaller in scale. We suggest a minimum size of 250 units and such larger sites should be allocated through the BCCS Review.

12.5 We concur with the statements in para. 4.28 of the IOR which acknowledges that SUEs are better placed to comprehensively deliver, or contribute towards, supporting physical and social infrastructure.

13 QUESTION 13C - POTENTIAL LOCATIONS

Q13c - Are there any potential locations that should be considered for SUEs and what infrastructure would be required to support these?

13.1 Barratt has submitted a Call for Sites submission for land at Stencils Farm, Walsall, comprising a covering letter, completed Questionnaire and a suite of supporting technical reports which includes a "Development Framework Plan" providing an indication of the site's development capacity; c.570 dwellings set within 18ha of green infrastructure.

13.2 The land at Stencils Farm provides a highly sustainable option to assist in delivering Walsall's emerging housing need through the BCCS Review. Of the eight strategic residential Green Belt sites in the Borough previously promoted for residential development, Stencils Farm provides a limited contribution to the five national purposes of Green Belt (second to only one other site) (refer to Appendix 1). It lies close to Walsall town centre with good public transport and walking/cycling links to local facilities, and is well contained providing a valuable opportunity to create a robust settlement edge and Green Belt boundary with a soft transition to the countryside. This transition would comprise a strategic area of green infrastructure adjoining the canal, providing a linkage between two "Wildlife Corridors".

13.3 The site's location to the east of Walsall adjoining the Aldridge Road (A454) means that minimal new infrastructure would be required - the site already benefits from a roundabout which can provide a primary point of access from the Aldridge Road, and this road is served by regular bus services linking both Walsall and Aldridge.

13.4 The site is deliverable and we respectfully request that it be considered as an allocation through the BCCS Review.

13.5 Barratt intend to fully engage with Walsall Council and the local community over forthcoming months to discuss the site and proposed development in greater detail.

14 QUESTION 13D - DETAILED SUE GUIDANCE

Q13d - Do you think that the Core Strategy should set out detailed guidance for the development of SUEs, rather than details being determined at a local level in light of local policies?

14.1 It is important that the identified development needs of the Black Country and wider Housing Market Area (HMA) are met as quickly as possible so we urge the authorities to progress the review as swiftly as possible, and to ensure that strategic allocations and SUEs are delivered through the BCCS review, rather than lower order development plan documents. It is essential that the strategic sites/SUEs are allocated through the BCCS review process as this is the strategic development plan and sites will be identified through the Green Belt Review which will cover the whole of the Black Country. Indeed, some of these sites may be cross-boundary allocations i.e. meeting the needs of one authority in another, so it is critical that the strategic development plan provides a clear policy framework for them.

14.2 We draw reference to the South Worcestershire Development Plan and Gloucester, Tewkesbury and Cheltenham Joint Core Strategy, both of which allocate strategic sites.

14.3 Deferring such allocations and/or detailed development guidance will only serve to delay the delivery of the developments which will fail to ensure that development needs are met as they arise.

15 QUESTION 15A - EXPORTING HOUSING NEEDS

Q15a - 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?

15.1 The NPPF requires that authorities plan to meet their objectively assessed housing need (OAN) (para. 14, 17, 47 and 182). As such, there needs to be a rigorous approach to the identification of potential housing sites with a view to providing all of the Black Country's needs within the Black Country. To date, the SHLAAs have focused upon the urban area to accord with the adopted BCCS spatial strategy but the BCCS Review must now undertake an assessment of capacity within the Green Belt.

15.2 The results of the Greater Birmingham HMA Strategic Growth/Locations Study are yet to be published and the Black Country Green Belt Review will not be completed until mid-2018. However, it is essential that the authorities now undertake a proactive and thorough approach to the assessment of potential Green Belt release because the only potential capacity within adjoining authorities to assist in meeting any shortfalls in the Black Country would be through Green Belt releases in those authorities.

15.3 Walsall is unique in the Black Country context insofar as it encompasses an extensive area of Green Belt which lies in-between Walsall, Birmingham, Aldridge and Brownhills. It is understood that this amounts to c.70% of the Green Belt within the Black Country as a whole. Whilst not all of this will be suitable for release and development the Green Belt Review must recognise that Walsall has a significant area of undeveloped Green Belt land which provides an opportunity to accommodate its own shortfall (and potentially others) through selected Green Belt releases to permit sustainable urban extensions within the heart of the West Midlands conurbation, and in close proximity to Birmingham (which has the largest shortfall of all the authorities).

Dear Sirs,

In connection to the above, please find attached representation to the Black Country Core Strategy Review 'Have your Say' Issues and Options consultation.
Should you require any further information regarding the above please do not hesitate to contact me. In the meantime, I would be grateful if you could please confirm receipt of the attached at your earliest convenience.

Yours faithfully

Chapter / Page / Question / Paragraph
Paragraphs 2.5 - 4.34
Do you agree or disagree with the approach set out in the relevant section and / or question?
Please see comments below
Comments (continue on a separate sheet if necessary)
It has clearly been indicated within the Issues and Options Report that there is a need for additional land to support the development needs both residential and commercial of the Black Country in the coming years. It has been demonstrated that there is insufficient land within the urban area to meet the needs of the four Black Country authorities.
It has been shown in paragraph 2.5 that there has been an under delivery of sites within the growth network. Paragraph 2.9 identifies that the Black Country is currently 3,000 homes behind the Core Strategy target trajectory. Paragraph 2.10 states, "There is a large pipeline of major housing sites concentrated within the Growth Network, which have been successfully allocated through the Local Plans. However, many of these sites have multiple constraints and financial assistance will be needed to bring them forward".
Figure 4 Housing delivery 2011-17 shows there has been a significant number of pipeline homes and/or homes completed/commenced outside of the housing and employment led corridors which would be understandable due to the reasons mentioned above.
The Black Country authorities and the illustrative plans confirming an under delivery of housing indicate the current strategy has not been as successful as hoped for.
The housing need (OAN) for the Black Country over the period 2014-2036 is identified as 78,190 homes.
With the inclusion of SHLAA sites it is identified that there is still a deficit in land supply of approximately 21,670 homes (paragraph 3.15).
At the time of preparing the Core Strategy some years ago, the Country were feeling the effects of the global recession and there had been many employment sites becoming vacant providing the opportunity for redevelopment for residential uses. However, the economy has greatly improved since that time with employment sites in demand and there is the requirement for an additional 300ha of employment land to meet future needs. We therefore do not consider that the approach of redeveloping employment sites for residential development is the most appropriate strategy for consideration in the Core Strategy Review.
Paragraph 3.17 states in bold that there will be the requirement for a, "large number of new homes and supporting services will need to be accommodated outside the existing urban area of the Black Country. All such land in the Black Country is currently Green Belt".
We support this strategy of allocating land outside of the urban area for residential development.
We support the proposals for a Green Belt review in order to allocate sites to meet future residential development.
The needs of the Black Country are significant. Due to the nature of the four Black Country authorities there is limited opportunities for additional land to be identified within the Boroughs of Sandwell and Dudley due to their dense urban character, Wolverhampton is also lacking in areas of undeveloped land (including the limited land within the Green Belt) to meet the Black Country's needs. Therefore the need to find land will result in the cross boundary cooperation with neighbouring authorities such as South Staffordshire (which borders Wolverhampton, Dudley and Walsall and Cannock Chase and Lichfield (both of which border Walsall) and Bromsgrove (which borders Dudley to the south).
It has been demonstrated that there is a strong link between the Black Country and South Staffordshire and therefore we consider it would understandable to look to South Staffordshire to determine the capabilities of supporting residential development to assist the Black Country and their land supply deficit, in addition to the other neighbouring authorities.
With the current issues facing the Black Country, this needs to be considered in conjunction to the well-publicised housing land supply shortage currently affecting Birmingham, where there is the requirement for approximately 38,000 dwellings to be accommodated outside of the Birmingham administrative boundary.
The Black Country's predicament reduces their ability to assist Birmingham to any great extent and therefore the pressures to identify land within the Green Belt surrounding the West Midlands urban conurbation becomes ever more essential.
We therefore consider the Black Country Authorities should undertake a Green Belt review to identify sites on the edges of the Black Country and enter into robust discussions under the Duty to Co-operate with neighbouring authorities to identify land within their administrative boundaries to identify sustainable sites which are in close proximity to the Black Country authorities for residential development. Due to the current land supply issue and the constraints of the Black Country Authorities it is inevitable that some of the housing needs will have to be met through changes to the Green Belt in the Black Country and sustainable extensions into the adjoining Shires.
Table 2 approach to accommodating growth identifies a number of options for the allocation of land for residential development. We consider options 2A-Housing development outside the Growth Network options H1 - Rounding off the Green Belt and meeting housing needs through a large number of smaller sites and H2- identification of a limited number of large sustainable urban extensions in the Green Belt should be considered going forward as potentially the most appropriate strategy to identifying residential development land as this is the only way to ensure linked infrastructure facilities and services.

Question 3 : Do you agree that the housing need identified in the Black Country over the period 2014 - 2036 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?

As referenced above the means by which OAN is calculated is likely to change in the near future, such changes will need to be factored into the OAN requirement as the plan develops. Gladman do support the Councils in their intention to ensure that all of the housing needs of the Black Country are met, and to look to contribute towards the unmet housing needs of Birmingham. It will be essential moving forward that any calculation of OAN is not undertaken in isolation and that the full needs of the sub-region are met moving forward, this may require further joint working and the consideration of even wider strategic plan making.

Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review?

Yes. Given the scale of need for housing and employment land it is inevitable that the Councils will have to undertake Green Belt review to attempt to meet needs. The consultation document confirms in paragraph 3.41 that the Green Belt in the Black Country has not been reviewed, strategically, since it was designated in the 1970s. Whilst Gladman therefore note what the NPPF and Housing White Paper say about the Green Belt it is clear that in this area the time for strategic review is well overdue.

Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate?

As referenced in response to question 1, the Core Strategy was prepared pre the adoption of the NPPF. Whilst therefore a number of the principles may remain appropriate others will require reconsideration. For example putting brownfield first may need to be reconsidered in light of the NPPF. Clearly the redevelopment of brownfield sites is important, but the concept of brownfield first is on no longer enshrined in national policy.

Question 8: Do you think that the Core Strategy spatial objectives remain appropriate?

No. Gladman consider that the spatial objectives will need to be reconsidered in light of the significant development requirements to which the plan will need to meet. The objectives at present do not place significant enough emphasis on the need to deliver new housing to meet needs, as expressed in both the NPPF
and the Housing White Paper.

Question 10: In continuing to promote growth within the Growth Network is there a need to amend the boundaries of the Growth Corridors in the existing Core Strategy?

The question will be best be answered when the plan knows firmly what its development targets are. It seems inevitable that the boundaries of the Growth Corridors, alongside Green Belt release, will be required in order to ensure housing and employment land needs are met.

Question 11A: Do you support Strategic Option 1A? Do you support Strategic option 1B?

It is highly likely that Option 1A will give the Councils the best chance of delivering their housing and employment needs. In reality what is needed is as broad a range of sites, in as broad a range of locations as possible to ensure that all areas of the house building industry can be actively engaged in delivering housing
needs. Strategic Option 1A would give a better chance of this being achieved without relying on the potentially challenging need to redevelop existing employment land for housing, which could be challenging in viability
terms.

Question 12A: Do you support Strategic Option H1?
Question 13A: Do you support Strategic Option H2?

As highlighted above Gladman consider that the Council will need to consider a mix of the options outlined in H1 and H2. Meeting development targets of the scale proposed will require the largest possible range of sites, attractive to the largest possible range of developers. Concentrating on either small/medium sites or large
SUEs in isolation would not allow this to happen.

Question 15: 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. The Housing White Paper placed great increased emphasis on the need for HMAs and adjacent HMAs to work constructively and collaboratively to ensure that unmet housing needs are met. It is clear that there are likely capacity issues in the Black Country and pressures from Birmingham with additional unmet housing need.

Constructive and effective discussions through the Duty to Cooperate across the West Midlands region will be vital to ensuring housing need it met.

Question 35: Do you support the approach to HLS?

The inclusion of a windfall rate of 505 dwellings per annum is noted, the figure does seem to be high. Any further draft of the plan will need to be accompanied by evidence to justify such a figure in line with the requirements of the NPPF and the PPG. Similarly whilst Gladman note the densification of development in
certain areas this will again need to be clearly evidenced and accompanied by market data which allows comfort to be taken that development at the density proposed will be deliverable.

Question 42: Do you agree that the annual affordable housing target should be increased to reflect the 2017 SHMA?

Yes. The Local Authorities should be planning to meet their full OAN for market and affordable housing.

Question 44A: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site?

The affordable percentage of homes on sites should be reflective of the viability of the sites in question. The appropriate percentage can only be derived on the back of a consideration of the overall plan viability which factors in such things as build costs, land values, infrastructure costs and any other associated CIL costs. It may
well be that 25% is the correct figure but this will need to be fully evidenced.

Question 111: Do you agree with the proposed change to 'prior extraction' requirements, to maintain a size threshold in urban areas and increase the threshold for green belt sites to 3 ha? If, no what evidence do you
have to justify an alternative approach?

No. The Council needs to provide a robust evidence base to justify such an approach which could have a negative or detrimental impact on site delivery. In the first instance policies which require prior extraction need to carefully consider what mineral they are protecting, what quantities of that mineral are already banked and have consent to extract and what level of minerals are required for the future. Whilst the need to consider mineral protection is acknowledged it must be properly weighed against the need for new development, particularly housing and employment land.

Gladman would recommend that should the Council wish to consider a prior extraction approach it should be working actively with land promoters, land owner and land agents throughout the development of the plan in order that any sites which may be allocated on mineral protection areas can have the issues resolved through the plan making process to avoid unnecessary delay. The Council will also need to set out a detailed methodology to allow sites that are not allocated within the plan to be able to provide the necessary information required to consider prior extraction.

Dear Sir/Madam

Re Proposed mass construction of dwellings and industrial facilities beyond southerly perimeter of A456

I wish to register my objection to this proposal.

General comment on Green Belt
The green belt provides a constraint to urban sprawl; helps to retain the identity of settlements and encourages community, provides a physiological and psychological lung to the adjacent population, people who visit the locality and those who need to travel between settlements; and offers an accessible experience of the ex-urban world that is physically accessible from the inner city.

Below are some points to support the case against the proposed construction beyond the southerly perimeter of the A456

1. The scale of the proposal must now be questioned. It predates more recent demographics which show post-referendum changes that will inform adjustment to government requirements of certain local authorities.
2. The negative dynamics of urban sprawl are now well appreciated. In consequence regeneration is preferred to new generation because 'grow the edge - kill the middle'
- Excess urban sprawl creates economic disparity (relocation of the more affluent to the periphery reduces the desirability of the centre, has a detrimental effect on attraction of new investment and results in the opposite of the original intention)
- Excess urban sprawl generates increased numbers of commuters with more noise pollution and deterioration of air quality. Commuting induces individual, societal and infrastructural stress, which have concomitant intangible costs as well as direct and indirect costs to the local and national economy.
- Excess urban sprawl detracts from environmental aesthetics, can create adverse economic metrics and reduce quality of life.
3. This green belt is so close to Birmingham city centre, as well as Black Country conurbations, that it offers a rapid 'escape to the country' - a resource to be treasured - not destroyed.
This green belt offers a clear boundary between neighbouring counties which supports the individual identity of the Black Country Region both locally and nationally.
Use of green belt, especially heritage sites and productive agricultural land is contrary to the national strategy for sustainability.

Specific concerns for the Black Country

4. Not consistent with government, regional and local directives
- the government and Black Country Local Enterprise Partnership has focussed priority on the regeneration of Dudley and Wolverhampton in key ways, notably local light rail development, educational and business expansion in Dudley, development of Wolverhampton City College, regeneration of Walsall Waterfront, deliver additional housing within Sandwell and Dudley,
- ignores the pressing need to regenerate the many vacant and eye-sore brown field sites, especially within the Sandwell and Wolverhampton areas.
- why has consideration not been given to mixed-use developments? Eg commercial premises with residential property above/below; creation of a 'cafe culture'; planning rules which permit/encourage home-based employment (cut commuting, invigorate localities 9am-5pm). Keeping areas active day and evening offers an economic use of resources and is supportive to the human and built environment
5. Lack of infrastructure
- the A456 corridor is already beyond efficient capacity for access to/from central Birmingham and motorway complex (itself under strain)
- the proposal does not take account of growth and transport demands currently incurred by and planned for in locations beyond the western boundaries of the Birmingham and Black Country conurbation
6. Loss of heritage site
- Loss or partial loss of the grounds of Halesowen Abbey and associated medieval water control features of the sloping grounds which comprise a scheduled ancient monument and archaeological area
7. Unnecessary loss of green belt
- this contravenes national and local priorities: diversion of funds in this way may compromise support to the region for national priority developments which would deter commercial support

Yours faithfully

Dear Sir or Madam
I have just tried to answer your Core Strategy Forum . Maybe I am too late to answer it but it keeps
Telling me my e mail address doesn't exist. As you have sent me the email in the first place my
Email does exist .
However my point I would like to make is; please keep OFF Green Belt land it is a very precious
Resource that we could well use if the EU negotiations go much further downhill.
We may well need to grow our own food again.
Looking through Rightmove on a regular basis I do see an awful lot of empty homes.
Surely it would be a good idea to look at getting these back into use rather than let them lie
Empty and causing you to use up our valuable green spaces.
Also we do have a tremendous amount of supermarkets everywhere could this land that
Has been propose for yet another supermarket be for home building or industrial purposes?
I really do feel very strongly that the Green Belt really must be maintained .
PLEASE DO NOT invade it further.
Thank you for reading my conclusions.
Yours sincerely

The people of the Black Country were not asked if they wanted a Police Commissioner, an elected Mayor or a joint Strategy with Birmingham and the rest of the surrounding LAs. Lack of support for such matters was reflected by the extremely poor turnout when the elections actually took place for the above 2 positions.

Again we have not been consulted whether or not we want a "Black Country Core Strategy", it has just been foisted upon us !

You are admittedly allowing people to have their say, but will you really take any notice of what we say. Surely you will just plough ahead as usual.
After all Public opinion is seen as an obstacle to remove, not a reason to change direction.

Your brief multiple choice questionnaire is simply a dumbing down of the situation, you haven't provided enough space for anybody to actually express a considered opinion, hence this letter.

The big issue as far as I am concerned is your plan to identify land in the Green Belt and presumably on agricultural land as well, to build on in the future. Bearing in mind only 12.4% of land in all England is designated Green Belt.

Why therefore is this core strategy being projected 19 years ahead, instead of the present strategy that was only for 6 years ?

LAs only need to identify within their local Plan a programme for building in the next 5 years to comply with the National Planning Policy Framework, although it is worrying that only 41% of LAs have such a plan.

Doing the maths from your own projections, NOT EVIDENCE, you have sufficient sites in the urban area including homes being built, homes that are already planned and new high density sites for 56,000 homes. At around 4,000 houses per year that is 16 years supply.

If you reduce your future strategy to say 6 or even 10 years there will be no need to identify Green Belt or other Agricultural land to build on at all.

The danger of identifying any land in the Green Belt and/or on Agricultural land now, means developers will want to build on this first, because its cheaper and unfortunately you will let them, in order to meet your commitments.

Already Developers, Builders and Land Barons are themselves identifying land of this sort where LAs have no local plan in place and are likely to say yes to planning applications to meet their central government commitments.

In 2011-12 35%of houses built in rural areas were affordable, the proportion has effectively halved to a mere 16% in 2015-16 as house builders have been able to renege on affordability commitments using the viability assessments set out in Government policy. Faced with the prospect of an appeal or a failure to meet targets LAs have waved through developments with greatly reduced affordable housing proportions.

Before retiring I worked in the construction industry as both a builder and developer for some of the biggest names still operating. I therefore can assure you that I know what I am talking about. Profit is King, there is no question of these companies being public spirited, they can only be reined in by legislation !

None of your projections can be hard and fast in 2 years, let alone 19 - the demographic will have changed, Brexit will alter the way we do business, more industrial land (Brownfield sites) will become available. On line shopping will inevitably change our town centres for ever and drone deliveries will change things even further. More people will work from home and electric cars are coming. Its a very brave man indeed that thinks he can predict what will be happening under the headings you are quoting in 19 years time or even before !

Instead of reviewing the Green Belt a Moratorium of at least 10 years should be placed upon it.

Your comments on protecting the environment are unnecessary, all the matters you refer to should be dealt with via the planning process for new build.

Over the last 10 - 20 years in order to save money more and more local hospitals and care facilities have been closed in the area and playing fields built on or left to run wild so they cannot be used properly. So what with the legacy of hospitals built using PFI, where is the money going to come from to provide for the items listed in your rather pathetic questionnaire under 6, 7 and 8 ?

I have lived in Halesowen all my life, my father, grandfather and great grand father were born here and lived here all their lives. I am shocked that consideration is being given to development on any of the green belt surrounding Halesowen.

We are on the edge of the Black Country and as such our borders to open countryside should be protected at all costs. These beautiful areas are the lungs of the Black Country. Our community thrives on the ability to access such wonderful green areas, you only have to take a stroll locally and there are dog-walkers, runners, children, families all enjoying healthy time out. I regularly see great wildlife including 3 types of deer in the fields surrounding the Clent Hills.

Unlike other areas of the Dudley Borough, Halesowen does not have a park, we need easy access to local countryside, do not begin the destruction of our green belt.

These representations are made on behalf of Heyford Homes Ltd which has various land interests in the West Midlands and beyond. The representations do not address in any detail the scale or nature of the need for new housing in the Black Country though the right to do so at later stages of the BCJCS Review process is reserved.

However the published evidence & other material which informs the Issues & Options consultation demonstrates that there is a clear need to allocate a substantial amount of additional land for new housing; and that this need cannot be met without releasing for development a significant amount of land that is currently within the Green Belt.

The BCJCS Review's approach to addressing this challenge needs to consider all options available and the potential of releasing land in the Green Belt which is of little functional value or strategic landscape importance should be seriously explored, especially where land is visually enclosed and so where development would have little or no impact on the charactor or openness of the wider landscape and so where development would not prejudice the purposes for which Green Belt is designated.

It should also recognise that new housing in such areas can help sustain currently less than sustainable patterns of development, for example by extending in an organic way existing enclaves of development to enhance their security & conviviality and by making public transport serving the existing network of settlements more viable.

Further, the Review should note that development which meets the above criteria can also contribute to meeting the immediate need to address the shortfall in the supply of new, high quality housing essential to attracting & retaining high skilled workers, as acknowledged by BCJCS Policy HOU 2 (esp para 3.2) and Policy
PL3 Housing of the Black Country Strategic Economic Plan. Such development at a relatively modest scale would not detract from the thrust of whatever overarching spatial strategy is pursued and should be supported as making a positive contribution to achieving wider policy objectives as well as meeting local and
Black Country wide housing needs.

The BCJCS Review process is urged to give positive consideration to taking such an approach in its review of the Green Belt; and also to giving positive consideration to facilitating the grant of planning permissions now where such development can meet immediate needs.

I am writing to implore you to NOT build on the Green Belt Land, this land is vital to our health and well being.

We have suffered from flooding in recent year and concreting on more green land would cause more as the water will have not where to go.

I do not understand why derelict area are left untouched, why can the not be used.

Please do not 'give away' our very special countryside around Halesowen. We need green spaces to enrich our lives and to help us cope in this ever-busy world. Children need green spaces to run and also learn how to care for plants/trees/insects/animals. They are the adults of the future and need to learn how to care for the environment they live in.

It is so very important to all of us and if you allow it to be developed and built upon it will be gone FOREVER !!!!!

I wish to record my opposition to the proposal to build on the Green Belt surrounding the Black Country.

The Green Belt is an important asset that improves the quality of life for people and wildlife. It is an area of recreation where people can communicate with nature. Studies have shown that this reduces stress and improves mental health. Mental illness is at an all time high and the Government has committed to a substantial increase in NHS funding in order to combat it. Loss of the Green Belt will only exacerbate this problem.

Priority must be given to developing brown field sites within the Black Country These areas are ideal for industrial sites and there are plenty of them.

Furthermore with land at a premium we should build up. We need 22,000 homes not 22,000 houses. The redevelopment of the old Austin works at Longbridge is an example of what should be done.

I write regarding the proposed Review of the Black Country Core Strategy 2017 as I strongly object to to Housing and Industrial Development in the Green Belt.

I oppose all development on designated Green Belt land, but my experience, and intimate knowledge, relates primarily to the Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'.

You do not ask for a detailed representation, but I list some pertinent issues:

1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.

2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.

3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.

4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.

6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.

7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.

8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

We have been residents of Halesowen for years and own a local business employing 5 staff. The main reason we chose our home location was the proximity to beautiful countryside in the area alongside the A 456 Halesowen Bypass with access and views of Clent and Romsley.
This countryside is sacred, historic and a valuable amenity. If it were developed then we would certainly leave the area as there is little else to be said in its favour. Halesowen has deteriorated over the years we have lived there.
Development should surely first take place in the many brown-field areas that are currently dilapidated. There are also many areas of undeveloped land.

Re: Proposed mass construction of dwellings and industrial facilities beyond southerly perimeter of A456
Here is a case against this proposal.
General concerns
1. The scale of the proposal must now be questioned as it predates more recent demographics which show post-referendum changes that will inform adjustment to government requirements of certain local authorities.
2. The negative dynamics of urban sprawl are now well appreciated. In consequence regeneration is preferred to new generation because 'grow the edge - kill the middle'
- Excess urban sprawl creates economic disparity (relocation of the more affluent to the periphery reduces the desirability of the centre, has a detrimental effect on attraction of new investment and results in the opposite of the original intention)
- Excess urban sprawl detracts from environmental aesthetics, can create adverse economic metrics and reduce quality of life.
3. Use of green belt, especially heritage sites and productive agricultural land is contrary to the national strategy for sustainability

Specific concerns for the Black Country

4. Not consistent with government, regional and local directives
- the government and Black Country Local Enterprise Partnership has focussed priority on the regeneration of Dudley and Wolverhampton In key ways, notably local light rail development, educational and business expansion in Dudley, development of Wolverhampton City College, regeneration of Walsall Waterfront, deliver additional housing within Sandwell and Dudley,
- ignores the pressing need to regenerate the many vacant and eye-sore brown field sites, especially within the Sandwell and Wolverhampton areas.
5. Lack of infrastructure
- the A456 corridor is already beyond efficient capacity for access to/from central Birmingham and motorway complex (itself under strain)
- the proposal does not take account of growth and transport demands currently incurred by and planned for in locations beyond the western boundaries of the Birmingham and Black Country conurbation
6. Loss of heritage site
- Loss or partial loss of the grounds of Halesowen Abbey and associated medieval water control features of the sloping grounds which comprise a scheduled ancient monument and archaeological area
7. Unnecessary loss of green belt
- this contravenes national and local priorities: diversion of funds in this way may compromise support to the region for national priority developments which would deter commercial support

Well, here we go again less than two years after last attempt to build on our precious green belt countryside. I objected strongly then as I do now. There are enough brown sites in this Borough to be developed so please use them. Do any councillors actually walk in the countryside surrounding Halesowen to see how many folk walk, cycle, etc in our beautiful countryside? I understand that people need work and accommodation but look at the proposed plans for Halesowen town centre to rejuvenate the centre by utilising old buildings there and conversion into apartments.

The road infrastructure around the town is pretty overstretched as it is so you don't have to think too hard to imagine the impact and devastation on the existing road system. The A456 has been de-trucked and look how busy and congested that already is.

We will just become one sprawling conurbation of Birmingham it it is allowed to happen. Learn lessons from other cities please. Johannesburg in South Africa has now consumed small towns like the former Boksburg which was around twenty miles away. It is now just a suburb of the city.

For this proposed planning to come so soon after the last attempt makes citizens suspicious about the motives perhaps of some councillors who may have a vested interest in such planning going ahead?

Please listen to the comments of your citizens. I have yet to meet one person who is in agreement with the proposals!

Review of the Black Country Core Strategy 2017
Objection to Housing and Industrial Development in the Green Belt
I oppose Green Belt development, but my experience, and intimate knowledge, relates primarily to all that Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'. You do not ask for a detailed representation, but I list some pertinent issues:
1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.
2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.
3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.
4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.
6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.
7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.
8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

The ' Halesowen green belt ' is an historic and beautiful area of countryside which is to be protected.
The impact of building on these areas would be devastating ..... residents would suffer from crippled traffic networks , & community services would be devastated.
Any development should be contained within existing urban areas.

I am writing to object to the proposals to build on Halesowen's greenbelt land and I fully support the above campaign.

The road infrastructure around Halesowen is currently wholly inadequate. During the rush hour I take longer to get into and out of Halesowen town centre than travelling to North Birmingham. The traffic jams surrounding Mucklow Hill, Manor Way are unacceptable. The efforts to create a better flow of traffic at the island at the Manor way, Grange Road interchange have dramatically failed after several attempts and the thought of creating more traffic to access new housing estates in this area is well beyond reason.

The social housing which is needed will not work on the greenbelt land as this area will command a premium value that first time buyers will be unable to afford.

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

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

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

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

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

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

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

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

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

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

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

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

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

Social Infrastructure (Questions 22-25)

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

Physical Infrastructure (Questions 26-28)

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

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

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