1. Introduction

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Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 629

Received: 08/09/2017

Respondent: BOC

Agent: Savills

Representation:

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

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

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

Full text:

Black Country Core Strategy Issues and Options consultation

Summary

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

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

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

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

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



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

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

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

NPPF para 123 (our emphasis) states that:

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

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

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

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

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

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


Site specific considerations/representations

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

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


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

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

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

NPPF para 123 (our emphasis) states that:

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

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

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

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

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

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

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

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


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

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

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

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

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

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

NPPF para 123 (our emphasis) states that:

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

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

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

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

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

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

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

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


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

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

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

Policy EMP 3 states:

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


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

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

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

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

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1081

Received: 07/09/2017

Respondent: Inland Waterways Association Lichfield

Representation:

Timing and Purpose of Review

1.3 IWA does not agree that a review of the Core Strategy is necessary or desirable at this time. The present Strategy has 9 years to run to 2026 and allowing a generous 3 years for the process the review does not need to start until 2023. The suggestion that local plans require updating every 5 years is ridiculous. A local plan should be robust enough to last for 15 years and premature and frequent reviews serve only to undermine the credibility of the whole process and discourage democratic public participation, playing into the hands of developers who will always exploit any weaknesses in the system.

1.4 The specific reasons given are unconvincing; HS2 will not serve the Black Country and a possible Midland Metro extension whilst welcome would be hardly game changing. The national economic situation may have changed somewhat but it is likely to change even more after 2019 due to Brexit and any review now could be rapidly outdated before it is adopted.

Full text:

The Inland Waterways Association (IWA) is a national charity which campaigns for the conservation, use, maintenance, restoration and development of the inland waterways for public benefit.
The Lichfield Branch of IWA covers the canals to the east and northeast of Walsall town centre.
The rest of the Black Country is covered by our Birmingham, Black Country and Worcestershire Branch.
IWA has considered this consultation in relation to the environment of the canals and the interests of their users.


Policy ENV4 - Canals

Q100. Do you support the removal of the reference made to canal projects? - NO
Do you think that any other changes should be made to Policy ENV4? - YES
Please provide details.

IWA welcomed Policy ENV4 in 2010 and it remains relevant and necessary to protect and enhance the canal network in the Black Country and to safeguard the routes of canal restoration projects.

We and others did point out that the supplementary text, in supporting the restoration of the Hatherton Canal, should also refer to the other restoration schemes within or benefiting the Black Country canal network, including the Lichfield Canal and the Lapal Canal. Since that time all these projects have progressed and a project to restore the Bradley Canal has also been promoted and gained local support. Each of these restoration schemes would reinstate an important strategic link in the region's canal network which will greatly benefit the recreation facilities and visitor economy of the Black Country. Each project has had feasibility reports done which define their route, engineering requirements, costs and benefits, and significant physical restoration work has now been achieved on the first three.

Therefore, IWA considers that the Policy text should remain as it is, but that paragraph 6.19 should be updated and expanded as follows:

"Projects to restore several canals within or connecting with the Black Country are well established and are supported as important strategic additions to the region's canal network. The Hatherton Canal will link the Wyrley & Essington Canal in Pelsall with the Staffordshire & Worcestershire Canal west of Cannock. The Lichfield Canal will link the Wyrley & Essington Canal at Brownhills with the Coventry Canal east of Lichfield. The Lapal Canal will link the Dudley No.2 Canal at Halesowen with the Worcester & Birmingham Canal at Selly Oak. The Bradley Canal will link the Wednesbury Oak Loop at Bradley with the Walsall Canal at Moxley. Each of these projects will benefit the recreation facilities and visitor economy of the Black Country."

The reasons given in the Issues & Options Report at 6.1.55 for suggesting removal of references to canal projects, and specifically the Hatherton Canal, are wholly unconvincing. These are strategic projects, of significant length and with cross-boundary locations between Black Country boroughs and adjacent authorities, that require a strategic and co-operative approach to the safeguarding of their routes, as is recognised by the existing Policy. It is simply not credible to say they can just be considered at a local level. The local level plans can more clearly define the safeguarded alignment of their sections of the route and deal with any local issues, but for coherency and effectiveness the complete route also needs to be referenced and supported at a higher level through the Core Strategy.

The particular reasons cited for the Hatherton Canal; water availability and Habitats Regulations, are matters to be addressed by other authorities and there is no reason to suppose they cannot be satisfactorily answered. Water supply for the canal network is the responsibility of the Canal & River Trust, in conjunction with the Environment Agency and the canal restoration trusts. Safeguarding is not the same as a site allocation and does not in itself require an HRA. Such assessments, where relevant, will be considered at the appropriate time when pertinent to planning applications. Neither of these reasons are therefore any impediment to an expression of support for individually named projects or to the essential safeguarding of those routes from severance, as has been provided by the current Black Country Core Strategy since 2011.

For comparison, the BCCS safeguards land needed for the implementation of priority transport projects and identifies those projects including new roads, railways and metro lines (Policy TRAN1). Each of these may be subject to resource provisions or Habitats Regulations Assessments, but that is not a reason for declining to name them in the Core Strategy and leaving it to local level site allocation documents or area action plans. The four canal restorations are not only recreation, tourism and wildlife corridors but are also major transport infrastructure projects.

Therefore, IWA advises that Question 100 and the justification for it is fundamentally misguided, that the present Policy ENV4 - Canals should be retained unaltered, but that the supporting text needs to be updated and expanded to refer to all the established canal restoration projects, including the Hatherton Canal, with new text as, or similar to, that suggested above.


Implications of the Core Strategy Review for the Existing Canal Network

The canals in the Black Country are historic waterways and valuable amenity and recreational corridors providing leisure boating, walking, angling, cycling and nature conservation benefits to the area. They are part of the national waterway system which attracts millions of visits each year from local people and holidaymakers from home and abroad, and a major component of the nation's tourism industry.

Whilst the surroundings of parts of the Black Country network are of interest for their historic industrial architecture, and others for their modern commercial or domestic buildings, it is generally the more rural parts of the network that are most attractive for visitors. Holidaymakers do not want to go boating past endless housing or industrial estates.

The rural parts of the canals play a vital role in encouraging continued recreational use of the whole canal system and thereby helping to fund its maintenance and improvement. The income from boating activities helps support local businesses and provides a major part of the funding necessary for the Canal & River Trust to maintain the canals for public use and enjoyment.

However, visually intrusive built development alongside the canals diminishes their tourism potential and economic benefits. The attractive countryside setting of parts of the canal system could be lost by the proposals for extensive Green Belt development which would diminish their value to the local community and the visitor economy.

There are areas of canalside Green Belt within Wolverhampton, Dudley and Sandwell which may be threatened but the greatest extent of Green Belt is in Walsall. To the north and east of Walsall the open countryside setting of the Wyrley & Essington Canal around Pelsall and Brownhills, the Daw End Branch around Walsall Wood, Rushall and Hay Head, and the Rushall Canal around Longwood and Shustoke are particularly valued.

IWA considers that these parts of the Green Belt in particular, with their additional canal amenity, recreation and tourism value, should be excluded from any Green Belt review.


The Core Strategy Review and Green Belt Issues

Timing and Purpose of Review

1.3 IWA does not agree that a review of the Core Strategy is necessary or desirable at this time. The present Strategy has 9 years to run to 2026 and allowing a generous 3 years for the process the review does not need to start until 2023. The suggestion that local plans require updating every 5 years is ridiculous. A local plan should be robust enough to last for 15 years and premature and frequent reviews serve only to undermine the credibility of the whole process and discourage democratic public participation, playing into the hands of developers who will always exploit any weaknesses in the system.

1.4 The specific reasons given are unconvincing; HS2 will not serve the Black Country and a possible Midland Metro extension whilst welcome would be hardly game changing. The national economic situation may have changed somewhat but it is likely to change even more after 2019 due to Brexit and any review now could be rapidly outdated before it is adopted.

Q.1 IWA does not agree that a review, partial or otherwise, is necessary at this time.

1.19 The present Core Strategy adopted in 2011 does not require building on the Green Belt and it is not accepted that circumstances have changed so much since then as to require the extensive Green Belt development now being suggested. The main purpose of the Green Belt for 70 years has been to restrict urban sprawl, preserve countryside and encourage urban regeneration. This remains Government policy despite extensive attempts to undermine it in the last few years. This consultation shamefully joins in the scramble to dismantle this essential element of post-war planning for the short term gain of developers at the expense of the long term public interest.

Local authorities are required to compile a Brownfield Land Register by the end of 2017 and it is wholly premature to claim that release of Green Belt will need to be considered before the results of that exercise are known. The absence of any reference to this statutorily required study is not acceptable.

1.25 The 'Call for Sites' should be restricted to Brownfield sites and non-Green Belt greenfield sites. Any Green Belt greenfield sites put forward should not be considered further unless Exceptional Circumstances can be clearly demonstrated.

2.9 Despite the recession and slower house building due to depressed demand, this confirms that the 2026 housing supply target can be met. Therefore, notwithstanding uncertainties about individual sites, there is no justification for a premature review.

Q2. The key evidence must include the Brownfield Land Register that should be currently underway according to Government requirements.

Housing Need

3.10 The excessive overestimates of Birmingham's unmet housing need are not a reason for extensive Green Belt development in Birmingham, let alone in the Black Country. The purpose of Green Belt is to geographically constrain development and if need really can't be met within the conurbation, on Brownfield land and through increased development density, then it should be directed outside the Green Belt in planned new settlements in the same way that Telford and Milton Keynes for example were planned in more enlightened times.

3.11 The Housing Needs Study suggestion that the supply of brownfield land is insufficient cannot and should not be relied on before completion of the Brownfield Land Register required later this year.

3.13 The so-called "Objectively Assessed" Housing Need methodology produces notoriously overestimated figures based on the irrational assumption that Britain can accommodate and will tolerate continuing very high levels of immigration, and that this can be arbitrarily shared out across the country. In fact, immigrants tend to concentrate in already high immigrant areas and the Black Country, for all its past diversity, has more recently had a stable or falling population so the sudden increase in the projections and consequent housing need predictions is not credible.

3.17 The conclusion that a large number of new homes need to be built on the Green Belt is fundamentally wrong. Everything possible needs to be done to continue to accommodate modest native population growth within the existing urban areas, and certainly within the constraints of the Green Belt. Taking the 'easy option' of trashing the Green Belt without first exploring every other alternative is irresponsible and reprehensible.

Q3. IWA does not agree that the claimed housing need is appropriate.

Employment Land

3.24 Estimates of employment land need follow the same population forecasts driving the housing need estimates, and are subject to at least the same degree of overestimation, plus the move away from real manufacturing jobs to warehousing that is land hungry but employment poor, and not in the public interest.

Q4. IWA does not agree that the estimated employment land requirement is appropriate.

Green Belt Review

3.40 The legal requirement for 'exceptional circumstances' to justify Green Belt development still applies and the cavalier way in which this is proposed to be ignored is not acceptable. The prediction of future unmet housing need is speculative, based on dodgy statistics and predictions, and not a current reality. Should it transpire, after 2026, it will still not justify large scale Green Belt development, but rather increased efforts to maximise reuse of brownfield land, higher building densities, and ultimately overspill development beyond the Green Belt.

3.41 The Green Belt is meant to be permanent, other than very minor tidying-up of its boundaries. It is right that there has been no previous strategic Green Belt review in the Black Country and it should stay that way.

3.43 The 'cherry-picking' of Green Belt sites by assessing the 'contribution' of a series of land parcels, as recently conducted by some other local authorities, is fundamentally misguided. The purpose and value of the West Midlands Green Belt is as a unified whole, not as a series of separate sites. It should be defended and, if ever necessary, reviewed on a regional basis and not by individual local authorities or in this case a sub-set of them.

Q5. IWA does not agree that there needs to be a major review of Green Belt boundaries, and certainly not by the Black Country authorities in isolation.

Q6. Needless to say, in view of the above, IWA does not agree that these are the right key issues.

Q7. Agreed.

Q8. Agreed.

Other Questions

Q9 - Q99. In view of our fundamental disagreement with the timing and intentions of the review to justify extensive Green Belt development, IWA does not express any detailed opinions on the relative demerits of various ways of achieving this.

Q100. See separate comments above.

Q101 - Q119. No comment.


Conclusions

This Issues & Options Report is premature and unnecessary. It uses inflated estimates of housing and employment land need. It fails to acknowledge the importance of the current Brownfield Land Register work and makes unjustified and unacceptable proposals for extensive Green Belt development. It should be withdrawn and discontinued.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1114

Received: 08/09/2017

Respondent: Education & Skills Funding Agency

Representation:

The ESFA notes that significant growth in housing stock is expected within the Black Country Core Strategy area; the Issues and Options Core Strategy (2017) confirms an Objectively Assessed Housing Need for the Black Country of 78,190 homes (para 3.13) to the end of the plan period in 2036. This will place significant pressure on social infrastructure such as education facilities.

The ESFA welcomes reference within the plan to support the development of appropriate social and community infrastructure, as indicated within paragraphs 5.7 and 5.8 of the document, which recognise the additional pressures that will be created by new housing.

The ESFA supports the principle of the Black Country safeguarding land for the provision of new schools to meet government planning policy objectives as set out in paragraph 72 of the NPPF.

Full text:

Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1. Thank you for seeking the Education and Skills Funding Agency's (ESFA) views on the above document; we welcome the opportunity to contribute to the development of planning policy at the local level.

2. The Education and Skills Funding Agency (ESFA), launched on 1st April 2017, brings together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA), to create a single funding agency accountable for funding education and training for children, young people and adults. The ESFA are accountable for £61 billion of funding a year for the education and training sector, including support for all state-provided education for 8 million children aged 3 to 16, and 1.6 million young people aged 16 to 19.

3. The ESFA aims to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. As such, we would like to offer the following comments in response to the proposals outlined in the above consultation document.

General Comments on the Black Country Core Strategy Issues and Options Approach to New Schools

4. The ESFA notes that significant growth in housing stock is expected within the Black Country Core Strategy area; the Issues and Options Core Strategy (2017) confirms an Objectively Assessed Housing Need for the Black Country of 78,190 homes (para 3.13) to the end of the plan period in 2036. This will place significant pressure on social infrastructure such as education facilities.

5. The ESFA welcomes reference within the plan to support the development of appropriate social and community infrastructure, as indicated within paragraphs 5.7 and 5.8 of the document, which recognise the additional pressures that will be created by new housing. You will have no doubt taken account of key national policies relating to the provision of new school places but it would be helpful if they were explicitly referenced within the document. In particular:

- The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 72).

- The ESFA supports the principle of the Black Country safeguarding land for the provision of new schools to meet government planning policy objectives as set out in paragraph 72 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary.- The Black Country should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on 'Planning for Schools Development'1 (2011) which sets out the Government's commitment to support the development of state-funded schools and their delivery through the planning system.

6. In light of the above, the ESFA encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. We note that the four local authorities covered by the Black Country Core Strategy have published statements of community involvement. In line with the Duty to Cooperate, please add the ESFA to your list of relevant organisations with which you engage in preparation of the plan.

7. In this respect, the ESFA commends, for example, the approach taken by the London Borough of Ealing in producing a Planning for Schools Development Plan Document (DPD)2. The DPD provides policy direction and establishes the Council's approach to providing primary and secondary school places and helps to identify sites which may be suitable for providing them (including, where necessary and justified, on Green Belt/MOL), whether by extension to existing schools or on new sites. The DPD includes site allocations as well as policies to safeguard the sites and assist implementation and was adopted in May 2016 as part of the Local Plan. The DPD may provide useful guidance with respect to securing site allocations for schools in the emerging Black Country Core Strategy as well as providing example policies to aid delivery through Development Management policies. You may also be interested in Barnsley's Education Sites Development Plan Document, produced by Barnsley Metropolitan Borough Council, which seeks to provide a framework for the development of education sites within the borough. These DPDs may provide useful guidance with respect to securing site allocations for schools in the emerging Black Country Local Plan as well as providing example policies to aid delivery through Development Management policies.

8. Ensuring there is an adequate supply of sites for schools is essential and will ensure that the Black Country can swiftly and flexibly respond to the existing and future need for school places to meet the needs of the local planning authorities over the plan period.

9. While it is important to provide clarity and certainty to developers, retaining a degree of flexibility about site-specific requirements for schools is also necessary
1 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6316/1966097.pdf
2 https://www.ealing.gov.uk/info/201164/local_plans/1961/planning_for_schools_dpd

given that the need for school places can vary over time due to the many variables affecting it. The EFSA therefore recommend the Council consider highlighting in the next version of the Local Plan that:

- specific requirements for developer contributions to enlargements to existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that
- requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use.

10. The ESFA would like to be included as early as possible in discussions on potential site allocations, as there are pipeline school projects in the Black Country that may be appropriate for specific designation. We would welcome the opportunity to meet with the council in the near future to discuss these projects.
Forward Funding

11. In light of the chapter Funding for Site Development and Infrastructure (page 54), emerging ESFA proposals for forward funding schools as part of large residential developments may be of interest to the Council. We would be happy to meet to discuss this opportunity at an appropriate time.

Core Strategy Issues and Options

12. The ESFA note that paragraph 5.6 of the Local Plan (Issues and Options) is considering the scope available for releasing land for Sustainable Urban Extensions (SEUs). We would request that as part of this exercise, work be undertaken to identify sites that can be safeguarded for the provision of new schools/school extensions where the proposed SEUs are likely to generate significant additional demand.

13. In terms of the Spatial Options (pages 42-43) proposed within the document, the ESFA does not favour a particular option, however, the preferred option will need to be supported by sufficient social infrastructure, in particular primary and secondary schools, to meet the demand generated by the new homes.
14. In respect of proposed Policy HOU5 Education and Health Care Facilities, the ESFA would welcome the proposed expansion of this policy to include standards aimed at ensuring new communities are well served by education facilities.
Developer Contributions and CIL

15. There is a need to ensure that education contributions made by developers are sufficient to cover the increase in demand for school places that are likely to be generated by major developments. The ESFA note that Dudley and Sandwell Councils have adopted CIL Charging Schedules, but that Wolverhampton and Walsall councils are yet to implement CIL. The ESFA support the Dudley and Sanwell's approach to ensuring developer contributions address the impacts arising from growth.
16. The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements, which will inform any CIL review and/or amendments to the Regulation 123 list. As such, please add the ESFA to the database for future CIL consultations.

Conclusion

17. Finally, I hope the above comments are helpful in shaping the Black Country Core Strategy, with particular regard to the provision of land for new schools. Please advise the ESFA of any proposed changes to the emerging Local Plan policies, supporting text, site allocations and/or evidence base arising from these comments.

18. Please do not hesitate to contact me if you have any queries regarding this response. The ESFA looks forward to continuing to work with the local authorities of the Black Country to aid in the preparation of a sound Local Plan.

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1271

Received: 07/09/2017

Respondent: Transport for West Midlands

Representation:

We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies.

Full text:

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1279

Received: 07/09/2017

Respondent: Transport for West Midlands

Representation:

TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.

Full text:

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1684

Received: 25/08/2017

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

Representation:

We act for the Chief Constable of West Midlands Police (CCWMP) and are instructed to make representations on local development documents in respect of securing policy reference in such documents to matters including:
* Recognising the community need for securing safe environments with crime reduction made a priority;

* Requiring developers to demonstrate how proposals address community safety and crime prevention in Design & Access Statements, or other relevant planning application documents;

* Promoting a safe and secure entertainment, leisure and evening economy;

* Ensuring the timely and effective engagement of the police and other emergency services to ensure effective delivery of infrastructure projects required as a result of development growth with the recognition that the police are a social infrastructure delivery agency;

* In appropriate cases, seeking financial contributions towards the additional expenditure burden placed on West Midlands Police as a consequence of development proposals and growth;

* Ensuring the timely and effective engagement of the police and other emergency services in the planning processes in relation to matters likely to affect crime and fear of crime; and

* Ensuring the timely and effective engagement of the police and other emergency
services in relation to Counter-Terrorism matters. For example, Counter Terrorism Security Advisors can give appropriate advice concerning Vehicle- Borne Devices (VBD) mitigation and the Crowded Place agenda (particularly in relation to shopping areas and the night-time economy).
Section 17 of the Crime and Disorder Act 1998 states, 'Without prejudice to any other obligation imposed on it, it shall be the duty of each authority to which this section applies to exercise its various functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent, crime and disorder in its area'. The CCWMP clearly has a statutory duty to secure the maintenance of an efficient and effective police force for its area and, of course, the Council is also statutorily required to consider crime and disorder and community safety in the exercise of its duties with the aim of achieving a reduction in crime. The CCWMP is grateful for the opportunity to comment on the Black Country Core Strategy Issues and Options Report.

Full text:

Black Country Core Strategy Issues and Options Report: Formal Representations on behalf of the Chief Constable of West Midlands Police.

We act for the Chief Constable of West Midlands Police (CCWMP) and are instructed to make representations on local development documents in respect of securing policy reference in such documents to matters including:
* Recognising the community need for securing safe environments with crime reduction made a priority;

* Requiring developers to demonstrate how proposals address community safety and crime prevention in Design & Access Statements, or other relevant planning application documents;

* Promoting a safe and secure entertainment, leisure and evening economy;

* Ensuring the timely and effective engagement of the police and other emergency services to ensure effective delivery of infrastructure projects required as a result of development growth with the recognition that the police are a social infrastructure delivery agency;

* In appropriate cases, seeking financial contributions towards the additional expenditure burden placed on West Midlands Police as a consequence of development proposals and growth;

* Ensuring the timely and effective engagement of the police and other emergency services in the planning processes in relation to matters likely to affect crime and fear of crime; and

* Ensuring the timely and effective engagement of the police and other emergency
services in relation to Counter-Terrorism matters. For example, Counter Terrorism Security Advisors can give appropriate advice concerning Vehicle- Borne Devices (VBD) mitigation and the Crowded Place agenda (particularly in relation to shopping areas and the night-time economy).
Section 17 of the Crime and Disorder Act 1998 states, 'Without prejudice to any other obligation imposed on it, it shall be the duty of each authority to which this section applies to exercise its various functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent, crime and disorder in its area'. The CCWMP clearly has a statutory duty to secure the maintenance of an efficient and effective police force for its area and, of course, the Council is also statutorily required to consider crime and disorder and community safety in the exercise of its duties with the aim of achieving a reduction in crime. The CCWMP is grateful for the opportunity to comment on the Black Country Core Strategy Issues and Options Report. Comments are set out below:

Infrastructure
1. The Issues and Options Report at paragraph 5.4 states that, '...The growth in development required across the Black Country up to 2036 will place pressure on existing physical, social and green infrastructure, and measures need to be in place to ensure that new growth is supported by appropriate and timely infrastructure provision so that vibrant and sustainable communities can be created and maintained. This will also create opportunities to provide infrastructure solutions to ease and remedy existing issues.' At paragraph 5.6 the Report accepts that '...infrastructure which requires significant up-front investment, such as new roads, or on-going service provision, such as schools, public transport and community services, may be more challenging to provide.'

2. The CCWMP welcomes the recognition in the Report that the scale of growth proposed will inevitably put pressure on existing infrastructure provision with a requirement to invest in additional infrastructure to serve the increased population. It is vital to ensure the necessary infrastructure is in place to deliver the growth objectives, including 'emergency services' infrastructure, as recognised in the Introduction and Scope of the Report.

3. The CCWMP formally requests that they be involved in the plan making process on an on-going basis to establish potential infrastructure pressure points and future infrastructure needs as more detailed information on preferred locations and the scale of growth likely in each location emerges.

Designing Out Crime
4. The CCWMP welcomes the recognition in Policy Area A - Health and Wellbeing section of the document, Theme 3 - 'Designing for Safety and Wellbeing' paragraph 6.12 that, '...Social exclusion can be reduced by effective design solutions which integrate well maintained public spaces, community facilities, shops and parks into the surrounding development. Well-designed places can also help to reduce the circumstances and opportunity for crime and increase public confidence and security...'

5. The CCWMP formally request that policies continue to be included in the Black Country Core Strategy review which require developments to meet Secured by Design Standards, as currently set out in adopted Policy ENV3 'Design Quality' and supporting text paragraph 6.15 which identifies crime reduction as a key objective. It is important that appropriate policies are included in the Review document which seek to increase security, reduce crime and reduce the fear of crime.

6. Given the recognised importance of prioritising safety and security within national, local and emerging planning policies, the CCWMP considers it essential that the Black Country Core Strategy Review should include reference to the intention to work in partnership with the Police to promote safe and secure environments and communities to deliver the Plan's objectives.

7. The local police Senior Leadership Team and Neighbourhood Policing Unit are likely to have detailed knowledge about site specific issues in respect of crime and safety and any needs arising from the proposed additional residential and employment land allocations in specific areas. Additionally, the centrally-based Design Out Crime Team (DOCT) have extensive knowledge of security measures and 'Designing Out Crime'. The CCWMP requests that the Senior Leadership Team, Local Policing Unit and Design Out Crime Officers are engaged in policy implementation and delivery once the Black Country Core Strategy Review is adopted.


The CCWMP and his representatives would be pleased to meet with you to discuss the matters raised in this letter of representation.

We should be grateful if you would acknowledge receipt of this letter of representation.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 1788

Received: 06/09/2017

Respondent: Lichfield District Council

Representation:

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

Full text:

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

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

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

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

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

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

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1849

Received: 31/08/2017

Respondent: Mr I R Carroll

Representation:

-The respondents do not consider that the consultation process has been conducted in an appropriate manner.
-Core Strategy is a big document and is not easy to be read and understood by majority of the people.
-The authors of the document seems to be biased towards unsustainable expansion of urban environments and building even on contaminated land which is unsuitable for development.
-Planners seem to believe that it is acceptable to live in overpopulated densities.
-"The need" for housing in the Black Country is simply based on a lie relating to rising population.
-Has the Core Startegy review looked at the implications of Brexit on population decrease.
-The strategy is questionable on the theme of "need" for more homes.
-The demand for more housing on unsustainable locations is artificially created.
-The nature feels threatened by increasing population around its centre.

Full text:

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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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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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.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2286

Received: 18/08/2017

Respondent: Peter Brown

Representation:

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.

Full text:

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 ?

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 2287

Received: 18/08/2017

Respondent: Peter Brown

Representation:

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.

Full text:

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 ?

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2290

Received: 18/08/2017

Respondent: Peter Brown

Representation:

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.

Full text:

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 ?

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2520

Received: 14/09/2017

Respondent: Gallagher Estates

Agent: Pegasus Group

Representation:

Technical Compendium for Conclusions for Home Farm, Sandhills.

Full text:


10. Conclusions


10.1 Conclusion


10.1.1 This Technical Compendium relates to the site known as 'Home Farm, Sandhills, Walsall'. This document has been produced in response to the 'Issues and Options' consultation of the Black Country Core Strategy Review. Previous versions of this document have been prepared in response to other consultations in relation to the emerging Walsall Local Plan, and alterations have been made where applicable in light of any changes in contextual information.

10.1.2 Land at Home Farm, Sandhills is a highly sustainable and deliverable site and it is proposed that it should be allocated for residential development as part of the Black Country Core Strategy Review. The site provides an opportunity to deliver a significant amount of housing (circa 1,280) with associated infrastructure and open space, which will assist to meet the development requirements of Walsall and the wider Black Country and meet the housing needs of local people in a successful manner.

Suitable
10.1.3 The site comprises of Green Belt land on the edge of Brownhills. As demonstrated in Section 2, the site is a suitable candidate for release from the Green Belt from a landscape perspective. Brownhills is identified in the current Development Plan as a 'regeneration corridor' with a wider range of services and facilities in the nearby town centre, therefore the site is well placed to meet the future development needs of the area.

10.1.4 The town is also located in close proximity to the towns of Walsall , Sutton Coldfield and city of Lichfield.

10.1.5 As such, the site is considered to be a sustainable location for residential development and will contribute towards meeting the housing needs of Walsall and the wider Black Country.

Available
10.1.6 The land is under the control of Gallagher Estates, a Master Developer who is committed to putting the land to market as soon as planning permission has been obtained and relevant site wide conditions discharged. This model allows the potential for multiple house builders to deliver the site efficiently and effectively. Gallagher Estates is committed to obtaining planning permission for the land at the earliest opportunity following an appropriate allocation as part of the adopted Local Plan.

10.1.7 There are no legal ownership matters which would prevent the land from being delivered for residential use.


Achievable
10.1.8 The site is greenfield and as demonstrated throughout the technical chapters, there are no constraints to development that would pose the site to be unviable to deliver. Gallagher Estates has reviewed the economic viabi lity of the site and proposals, including considering land values , market attractiveness and demand , sales rates and development costs and can confirm the development is economically viable to deliver.

10.1.9 In terms of the delivery programme, it is possible that if the site were to be allocated, completions could commence on site within 2 to 3 years of adoption - this would be subject to planning permission. It is anticipated that two to three developers would build at a rate that would see the site complete within 10 years or well within the plan period.

10.2 Summary


10.2.1 To summarise, the site will deliver a significant quantity of much needed housing in the medium to long term in a sustainable location. The proposed development is viab le and can be delivered in a timely manner. The site is therefore achievable.

10.2.2 Gallagher Estates are committed to engaging and working with Walsall Council and the local community to design a high quality residential development.

10.2.3 The development will consider site specific constraints and opportun ities, and will ensure that development proposals respect the existing character of the area.

10.2.4 In light of the information prepared, it is considered the site is suitable, available and achievable for development to meet emerging requirements for dwelling provision in both Walsall and indeed the needs of the wider Black Country.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2545

Received: 14/09/2017

Respondent: Gallagher Estates

Agent: Pegasus Group

Representation:

Tehnical Compendium information for Home Farm ,Sandhills

Full text:

Gallagher Estates
Black Country Core Strat egy ssues & Options





APPENDIX C


LAND AT HOME FARM, SANDHILLS TECHNICAL COMPENDIUM










































SEPTEMBER 2017 I HS I BIR.4327

BIR.4327 SEPTEMBER 20 17
::7




LAND AT HOME FARM, SANDHILLS, WALSALL


TECHNICAL COMPENDI UM
ON BEHALF OF GALLAGHER ESTATES







017
SE ;


WWW.PEGASU SPG.CO.UK

PROJECT DIRECTORY
for the Technical Compendium:-


Gallagher Estates Gallagher House Gallagher Way
Gallagher Business Park I
Heathcote Warwickshire CV34 6AF

Contact: Spencer Claye










The following consultants were involved
in the preparation of this Technical Compendium :-

Pegasus Planning Group Ltd
5 The Priory
Old London Road Canwell
Sutton Coldfield 875 5SH

Contribution: Introduction
Ground Conditions Conclusion
Contact: Hanna Staton




Contribution: Masterplanning and Design Concept Contact: Jeremy Peachey/Angela Wood



Contribution: Landscape & Visual Issues Contact: Jeremy Peachey/Katie Machin





Contribution: Archaeology and Cultural Heritage Contact: Laura Garcia












Pegasus
J
Pegasus
Pla88 *
PeUrgbaansursy Pegasus
Landscap







Pegasus
:7






Mode
45 Newhall Street Birmingham
B3 3QR



transport planning


Contribution: Transportation Contact: David Frisby




Aspect Ecology West Court Noral Way Banbury Oxfordshire OX16 2AF

asr:ect
Ecology


Contribution : Ecology Contact: Alistair Baxter




THDA Limited Consulting Engineers 1O Hylton Street Birmingham
B18 6HN

TH****DA


Contribution: Flooding and Drainage Contact: Paul Tinley



Kernon Countryside Consultants Ltd Greenacres Barn
Stoke Common Lane Purton Stoke Swindon
Wiltshire SN5 4LL

Contribut ion: Agricultural Land

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills


Contents


Executive Summary

1. Introduction

2. Landscape and Visua l Context

3. Indicative Development Framework

4. Transportation

5. Ecology

6. Archaeology and Cultural Heritage

7. Drainage

8. Ground Conditions

9. Agricultural Land

10. Conclusion

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills



Executive Summary


This Technical Compendium has been prepared on behalf of Gallagher Estates and demonstrates that land at Home Farm, Sandhills provides an ideal opportunity to create a sustainable, residential development adjoining the town of Brownhills. The site is being promoted for residential development through the Black Country Core Strategy Review.

In summary:


* The Black Country Core Strategy (2011) identifies Brownhills as a 'Regeneration Corridor'. It has a population of c. 12,500 and is connected to other suburban areas such as Pelsall, Shelfield, Aldridge,with Walsall, Sutton Coldfield and Lichfield beyond, and as such is a sustainab le location for development.

* The development requirements within the adopted Black Country Core Strategy are significant ly out of date. A recent Strategic Housing Market Assessment for the Black Country and South Staffordshire has identified a need for 78,190 homes for the Black Country between 2014 and 2036. Work undertaken to date suggests that of the 78,190 homes requirement, the existing urban areas only has the capacity to deliver approximately 56,520 homes, leaving a local shortfall in housing land to deliver 21,670 homes. This shortfall constitutes exceptional circumstances to justify for Green Belt release.

* The release of the site from the Green Belt would not compromise the five purposes of the Green Belt.

* The site would deliver on the three aspects of sustainable development , including providing an economic role (through construction jobs and materials, expenditure in the local economy from future residents and additional Council Tax contributions); a social role (through the provision of a range of types and mix of homes and through the delivery of a quality development that will enhance the quality of life for existing and future residents); and an environmental role (through enhanced environmental features, including new landscaping and green space).

* The site is not affected by any overriding physical, environmental or technical constraints.


*The Indicative Development Framework Plan demonstrates that the site could deliver circa 1,280 dwellings, complete with open space including landscape buffers and attenuation features (16 ha) and the potential for a mixed use centre and Primary School.

* The proposed development is highly sustainable and deliverable.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

* Gallagher Estates is committed to working with Walsall Council, the local community and stakeholders to design a high quality development, which compliments and enhances the wider community of Brownhills.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2707

Received: 08/09/2017

Respondent: Iceni Projects

Representation:

The Issues and Options consultation is the first stage of the review of the Black Country Core Strategy. The Core Strategy is a key part of the Local Plan for the Black Country Local Authorities which covers
4
the areas of Dudley Metropolitan Borough Council (MBC), Sandwell MBC, Walsall Council and the City of Wolverhampton Council.
The existing Core Strategy was adopted in 2011, covering the period up to 2026. Upon adoption, in accordance with national planning guidance, it was agreed that the Core Strategy would be reviewed in whole or in part at least every five years.
Since adoption there has been a number of changes to national policy, furthermore a housing shortfall has been identified in Birmingham which neighbouring authorities, notably the Black Country, have a duty to consider accommodating.
The Council state that although the Core Strategy is considered generally fit for purpose, this consultation stage will identify emerging issues and set out how the sustainable growth of the Black Country can be achieved.
The documents which make up the current evidence base for this consultation exercise, and are of key relevance to these representations, are set out as follows:
 Black Country and South Staffs Strategic Market Housing Assessment - March 2017; and
 Greater Birmingham and Solihull LEP Black Country Local Authorities Strategic Housing Needs Study - August 2015
Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services, such as open space, shops, schools and healthcare, are provided.

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

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2935

Received: 08/09/2017

Respondent: Wendy Morton MP

Representation:

Since the publication of the Black Country Core Strategy in 2011 , the local economy has been transformed in many ways and therefore future plans and strategic documents should reflect these changes. An update to the plans for the regeneration corridors and the inclusion of plans for our smaller communities would be too good an opportunity to miss but, the review of the plan should not simply grant licence to destroy our much-loved and needed green belt.

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see attachment