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

Showing comments and forms 1 to 30 of 65

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 22

Received: 28/07/2017

Respondent: Colin Knipe

Representation:

Agree that building on the existing Core Strategy is the most efficient way of proceeding

Full text:

Agree that building on the existing Core Strategy is the most efficient way of proceeding

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 40

Received: 20/08/2017

Respondent: Lichfield & Hatherton Canals Restoration Trust

Representation:

No comments to add.

Full text:

No comments to add.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 66

Received: 11/08/2017

Respondent: Mr & Mrs John & Lynda Wilkins

Representation:

To keep changing policies (unless they are completely faulty) is counterproductive .

Full text:

To keep changing policies (unless they are completely faulty) is counterproductive .

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 85

Received: 24/08/2017

Respondent: Countryside Properties

Representation:

A partial review is appropriate

Full text:

A partial review is appropriate

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 103

Received: 27/08/2017

Respondent: Walsall Council

Representation:

review must adopt a health in all policies approach where a health impact assessment is addressed and seriously considered

Full text:

review must adopt a health in all policies approach where a health impact assessment is addressed and seriously considered

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 131

Received: 05/09/2017

Respondent: West Midlands Resource Technical Advisory Body (RTAB)

Representation:

In the context of the area's growing economy and the continuing significance of manufacturing, RTAB would urge the explicit recognition of and support for the concept of the circular economy and the associated improvements in resource efficiency, productivity and competitiveness that this could bring to the Black Country. Progress towards the circular economy will require support for more sustainable and innovative waste management provision, embracing new technologies and adapting to changes in waste recycling and energy recovery trends.

Full text:

In the context of the area's growing economy and the continuing significance of manufacturing, RTAB would urge the explicit recognition of and support for the concept of the circular economy and the associated improvements in resource efficiency, productivity and competitiveness that this could bring to the Black Country. Progress towards the circular economy will require support for more sustainable and innovative waste management provision, embracing new technologies and adapting to changes in waste recycling and energy recovery trends.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 136

Received: 05/09/2017

Respondent: National Trust

Representation:

This seems an appropriate means for ensuring that the plan remains up to date.

Full text:

This seems an appropriate means for ensuring that the plan remains up to date.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 140

Received: 05/09/2017

Respondent: CRASH

Representation:

Much of the strategy has yet to be implemented or see fruit.

Full text:

Much of the strategy has yet to be implemented or see fruit.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 176

Received: 07/09/2017

Respondent: Birmingham and the Black Country Wildlife Trust

Representation:

The Core Strategy includes robust environmental policies. We support a partial review and have provided advice to make policy ENV1 clearer and more robust and advice where other policy changes may affect decisions pertaining to the natural environment.
We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157.

Full text:

The Core Strategy includes robust environmental policies. We support a partial review and have provided advice to make policy ENV1 clearer and more robust and advice where other policy changes may affect decisions pertaining to the natural environment.
We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 241

Received: 07/09/2017

Respondent: Mr W Potter

Representation:

The review should be partial because it is based on the assumption that there has suddenly been a significant increase in the demand for employment sites since the recession. There is no evidence presented to show that the population has grown and the document assumes that the new transport links will boost employment which is pure speculation. It also assumes that the Black Country authority will totally fulfil its so called 'duty' to accommodate Birmingham's housing needs. The joint Core Strategy was introduced in 2011 and when all the facts are known the policy should be revisited.

Full text:

It should be a partial review because shortly there will need to be another. Why? Para 1.1 states that within the three years from 2008 to 2011 'the national economic situation has also changed'. Did it suddenly change in three years? No. The UK has still not recovered from the recession and this particular review is based on speculation. It is based on a number of assumptions. Firstly, that employment will continue to grow and that the brownfield sites formerly assigned for housing will not be available. Secondly, that the population will grow without giving any specific evidence in the document (Table 1 Page 18). Thirdly, that new transport links, HS2 and the Midland Metro, will have a 'significant impact on the Black Country within the timeframe of this plan'. HS2 is not even scheduled to be open by 2027 and only two extensions to the Metro have been planned, one just a mile across to Birmingham's Broad Street. My last point is that a 'housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodating'. What if the Black Country authority does not wish to accommodate this so-called housing need?

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 254

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation:

LCP believe that the Core Strategy should be a total review of all existing policies and proposals contained within the adopted Black Country Joint Core Strategy. There has been considerable change in planning policy since the adoption of the existing Joint Core Strategy and it is best that such changes in national planning policy are dealt with in a total review of the Joint Core Strategy.

Full text:

LCP believe that the Core Strategy should be a total review of all existing policies and proposals contained within the adopted Black Country Joint Core Strategy. There has been considerable change in planning policy since the adoption of the existing Joint Core Strategy and it is best that such changes in national planning policy are dealt with in a total review of the Joint Core Strategy.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 301

Received: 07/09/2017

Respondent: Barberry Developments Ltd

Agent: Harris Lamb

Representation:

disagree with a partial review and believe this should be a full review underpinned by an updated evidence base

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 347

Received: 07/09/2017

Respondent: Clowes Developments

Agent: Harris Lamb

Representation:

no we dont agree that a partial review is enough

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 394

Received: 07/09/2017

Respondent: Bloor Homes

Agent: Harris Lamb

Representation:

No, we consider that the review needs to go further than a partial review.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 441

Received: 07/09/2017

Respondent: Local Nature Partnership

Representation:

The Core Strategy includes robust environmental policies. We support a partial review and provide advice to make policy ENV1 more robust and where other policy changes may affect decisions pertaining to the natural environment.

We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA) and Local Nature Partnership (LNP). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157. The Town and Country Planning Regulations (Local Planning) 2012 as amended requires co-operation with Local Nature Partnerships for planning sustainable development in cross-boundary strategies.

Full text:

The Core Strategy includes robust environmental policies. We support a partial review and provide advice to make policy ENV1 more robust and where other policy changes may affect decisions pertaining to the natural environment.

We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA) and Local Nature Partnership (LNP). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157. The Town and Country Planning Regulations (Local Planning) 2012 as amended requires co-operation with Local Nature Partnerships for planning sustainable development in cross-boundary strategies.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 500

Received: 08/09/2017

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Representation:

it is our view that the proposed review does not go far enough and that it seeks to rely too heavily on the adopted strategy that was based on a very different set of circumstances. a comprehensive review of the plan is required and a range of different sites should be identified for development in a number of different locations in order to provide choice and competition in the market for land and to enable the significant housing and employment requirement to be met, whilst securing the various economic and social benefits these deliver.

Full text:

It is our view that a comprehensive review of the existing Black Country Core Strategy ("BCCS") is required. The reason for this is that there have been significant changes to almost all of the factors relevant to the consideration of the Core Strategy. Consequently, anything less than a full review would fail to properly consider the implications of these and would not allow for a comprehensive strategy to be developed to ensure the sustainable delivery of the development needs now identified. These changes are summarised below:

* The position with regard to national and regional planning policy and guidance has changed considerably. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy and the BCCS was produced prior to the adoption of the Framework.
* There has been a significant shift in the amount of housing and employment land that needs to be delivered, which has been informed by a new evidence base. The identified increase in need has resulted in the urban capacity being saturated and we are now in a position where a large amount of development will need to be delivered outside the existing urban area. This is a significant change and brings with it new challenges and considerations that will need proper consideration.
* The current economic climate has changed significantly since the production of adopted Core Strategy. This has resulted in:
o sites identified for housing actually having a new lease of life as employment sites and not as much surplus employment land suitable for housing as anticipated as explained in paragraph 2.5 of the Issues and Option Document.
o The value of employment land rising, reducing the incentive for owners of employment sites to sell. This is particularly pertinent given the level of occupied sites that need to be made available just to meet the allocated / committed sites.
o Combined both of these factor call into question the amount of housing and timing of delivery on these sites and will require significant discounts to be applied to this source of supply.
* The delivery approach outlined by the adopted BCCS has proven to be problematic, with delivery levels in the Regeneration Corridors significantly below that planned for. Housing delivery has been heavily supplemented by unexpected high levels of windfall sites, which has served to mask the problem. But this level of windfalls cannot be relied upon to occur again and the issue with delivery in the Regeneration Corridors confirms the unpredictability of relying on occupied employment site that are often in multi-ownerships. It also confirms the uncertainty and problematic nature of delivering brownfield sites in an established urban area that was not originally designed to meet modern day standards. Furthermore, even with the high levels of windfalls, the delivery of housing at the end of the 2015/16 year was still 3010 below the lower annualised housing target of 2625 dwellings per annum. Given the annualised OAN is now shown to be between 3432 - 3551, something clearly needs to change if these numbers are going to be met, rather than continuing to focus on a failing strategy.
* We understand from our contacts that funding, although available, has proven to be time consuming and difficult to access. Given the significant amount of external funding that is likely to be needed to make the 300 hectares of occupied employment land come forward for housing (paragraph 2.10 of the I&O document), this will impact on deliverability or whether a site can be considered developable, which are the tests set in Paragraph 47 of the Framework for housing allocations.

A new strategy is, therefore, required which will provide a range of sites on both brownfield and greenfield (including Green Belt) land which are capable of being delivered in the plan period and are attractive to the market and viable. There are inevitably limitations as to how many dwellings can be delivered on one large site, when lead in times and build out rates are taken into account. So whilst larger sites will need, it is, therefore, our view that the emerging plan should seek to direct development to sites that are deliverable within the plan period.

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

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 534

Received: 08/09/2017

Respondent: IM Properties

Agent: Harris Lamb

Representation:

No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS).

Full text:

No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS). The consultation document confirms that the delivery approach outlined by the adopted BCCS is proving problematic with limited residential development being delivered in the Regional Corridors. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy. The BCCS was produced prior to the adoption of the Framework. The emerging BCCS is also being prepared in a significantly different economic climate to the adopted document. Furthermore, there have been a significant shift in the amount of housing and employment land informed by a new evidence base that is required that the revised BCCS needs to respond to. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted BCCS seeks to deliver development by focusing the majority of the housing and employment land requirement in the Growth Network and a series of Regeneration Corridors. It is, however, advised in the "Delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of residential in the Regional Corridors is "less than anticipated". Housing delivery in the Black Country has been boosted by the windfall sites.

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

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

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

A new strategy is required which will provide a range of sites on both brownfield and greenfield (including Green Belt) land which are capable of being delivered in the plan period and are attractive to the market and viable. These allocations should be made within the Housing Market Area generally, not just the Black Country, in order to provide a variety of housing sites in sustainable locations.

The Strategy should also be focused on identifying development sites that are deliverable within the plan period. It is, therefore, our view that the emerging plan should not place an overreliance on delivery from large scale urban extensions that have the potential not to be built out during the course of the plan period.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites should be "deliverable" and "available" in order to be allocated. The employment land led Regeneration approach of the emerging Core Strategy has failed this test at least to some degree. A more flexible and dispersed approach advocated by the Representator is a Framework compliant approach.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 539

Received: 08/09/2017

Respondent: SBP Property Ventures Ltd

Agent: Harris Lamb

Representation:

No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS).

Full text:

No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS). The consultation document confirms that the delivery approach outlined by the adopted BCCS is proving problematic with limited residential development being delivered in the Regional Corridors. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy. The BCCS was produced prior to the adoption of the Framework. The emerging BCCS is also being prepared in a significantly different economic climate to the adopted document. Furthermore, there have been a significant shift in the amount of housing and employment land informed by a new evidence base that is required that the revised BCCS needs to respond to. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted BCCS seeks to deliver development by focusing the majority of the housing and employment land requirement in the Growth Network and a series of Regeneration Corridors. It is, however, advised in the "Delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of residential in the Regional Corridors is "less than anticipated". Housing delivery in the Black Country has been boosted by the windfall sites.

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

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

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

A new strategy is required which will provide a range of sites on both brownfield and greenfield (including Green Belt) land which are capable of being delivered in the plan period and are attractive to the market and viable. These allocations should be made within the Housing Market Area generally, not just the Black Country, in order to provide a variety of housing sites in sustainable locations.

The Strategy should also be focused on identifying development sites that are deliverable within the plan period. It is, therefore, our view that the emerging plan should not place an overreliance on delivery from large scale urban extensions that have the potential not to be built out during the course of the plan period. Large scale urban extensions have extremely long lead in times and can take 10 years plus to be built out. It is, therefore, our view that the emerging plan should seek to direct development of sites that are deliverable within the plan period and there should not be an over reliance on large scale urban extensions.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites should be "deliverable" and "available" in order to be allocated. The employment land led Regeneration approach of the emerging Core Strategy has failed this test at least to some degree. A more flexible and dispersed approach advocated by the Representator is a Framework compliant approach.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 635

Received: 08/09/2017

Respondent: William Davis

Representation:

The adopted core strategy pre-dates the 2012 National Planning Policy Framework (NPPF.) There is a need to re-assess the soundness of the existing and emerging policies against this. Moreover, the acknowledged scale of the housing requirement within the area and the associated Green Belt release forces more than a partial review. The proposals within the Issue and Options paper are fundamental changes and require a full review and re-structure of the document.

Full text:

RE: BLACK COUNTRY CORSE STRATEGY ISSUES AND OPTIONS QUESTIONS


Please find below the responses from William Davis Ltd:
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies?
The adopted core strategy pre-dates the 2012 National Planning Policy Framework (NPPF.) There is a need to re-assess the soundness of the existing and emerging policies against this. Moreover, the acknowledged scale of the housing requirement within the area and the associated Green Belt release forces more than a partial review. The proposals within the Issue and Options paper are fundamental changes and require a full review and re-structure of the document.

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?
The proposed documents to form the evidence base for the Core Strategy are considered sufficient; however it is essential that the Green Belt review is undertaken comprehensively. The Green Belt review should acknowledge that the release of smaller parcels of land for residential use in some areas may be more appropriate. The review should not preclude this approach by only assessing larger sites.

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?
Whilst it is accepted that a Duty To Co-operate to meet Birmingham's unmet need is established within the Issues and Options document which is in-line with paragraphs 156 and 178 of the NPPF; it is considered that due to the proximity of the Black Country to Birmingham and the available infrastructure, employment, and land to accommodate growth, the proposed accommodation of 3,000 of the 38,000 shortfall is too low and should be revisited following the Green Belt review. This sentiment is echoed within the 2017 White Paper "Fixing our broken housing market" where it is discussed plans should incorporate an "honest assessment of the need for new homes." Moreover, the White Paper discusses the need for Local Authorities to "work with their neighbours so that difficult decisions are not ducked." It is considered this direction and strategy needs to be incorporated more closely with any emerging policy and associated housing target.

Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance?
The NPPF states in paragraph 22 that "policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose." This is acknowledged within the EDNA and therefore is supported. However, the long term goal of placing a residential focus on these sites is not. It is apparent from the Annual Monitoring Reports (AMRs) of Walsall and Dudley (both 2016) that this is failing and housing land should be re-allocated within the forthcoming Green Belt review. Walsall discusses "land being lost from employment to use uses is more gradual than anticipated in the BCCS targets" and within the AMR actually shows an increase from residential land to employment land of 1.47 hectares in 2015-2016. Dudley can only demonstrate 8 Hectares of land from employment to residential between 2011 and 2016 against a target of 57. It is apparent from this evidence that the current requirement is unattainable.

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review?
A Green Belt review is supported as it is considered the only feasible and sustainable way to accommodate the housing need within the area. However, a review of the Green Belt should accommodate all potential sites and not exclusively larger parcels of land suitable for SUEs. Ideally the scoping and approach of the Green Belt review should be open for consultation.

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?
The issues set out in Part 3 require some adjustment as they appear to underestimate the difficulties of retaining the existing strategy whilst acknowledging the need for the release of Green Belt land to sustainably meet residential need.

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate?
Paragraphs 17 and 111 of the NPPF states Local Authorities should "encourage the effective use of land by reusing land that has previously been developed." However, the BCCS sustainability principle states Brownfield land should be put first. This is not consistent with the NPPF and should be altered accordingly.

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate?
As previously discussed, the aim of using redundant employment land to accommodate new residential growth has proved unsuccessful and if past trends continue will leave a significant shortfall in the housing target. Therefore, this should be altered to accommodate a variety of sites within the Green Belt.

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network?
It is considered these policies are not in accordance with the requirement to release Green Belt land to accommodate the increased housing need. Therefore, they should be altered to be harmonious with this.

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?
Whilst it is not suggested an alteration of the regeneration corridors is required in order to support the emerging growth within the Black Country, there is a clearly a need to offer a broader focus on infrastructure, employment and housing ; as the geographical extent of the current corridors does not support the sustainable release of Green Belt land.

Question 11a - Do you support Strategic Option 1A?
1A is supported. This is because the previous Core Strategy's attempt to release employment land for housing need has proven to be ineffective and has fallen well short of target. Therefore, committing to extending this over a forthcoming plan period which features a far higher housing requirement would be destined to fail. Therefore Option 1B is unsustainable and unobtainable. 1A however, commits to a review of the existing strategy of Green Belt land which is essential to ensure that housing needs are successfully met by providing a broad portfolio of development opportunities.

Question 12a - Do you support Spatial Option H1?
Yes. Smaller sites should be used to contribute to the unmet need as SUEs often fall short of targets and are slow to deliver, whereas smaller strategic locations effectively and quickly contribute to housing figures by providing a broad portfolio of development opportunities. The use of smaller sites offers wider choice and balance throughout the housing market area contributing to social, economic and employment networks without overburdening infrastructure. Smaller scale Section 106 agreements can benefit communities in a sustainable manner further supported by CIL monies.

Question 12b - Do you think there are any potential locations that should be considered?
Yes-Land off Bromwich Lane, Pedmore. Land off Sutton Road, Walsall. Forms submitted through Call For Sites

Question 13a - Do you support Spatial Option H2
No. As previously mentioned, SUEs are not always the best solution as they can be slow to be delivered.. It is considered for a large area such as the Black Country where such a broad housing and social spectrum exists a mixed portfolio of small, medium and large scale residential commitments are more effective in terms of both delivery and sustainability.

Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA?
No. A successful Green Belt review, a Core Strategy that embraces a shift in the nature of development and Regeneration Corridor alteration will allow for the HMA to meet its own OAN.

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed?
Paragraph 47 of the NPPF states Local Authorities should "set out their own approach to housing density to reflect local circumstance." It is therefore considered there is a need for flexibility which takes into account individual sites in term of their siting, situation, surrounding area and access. Whilst it is acknowledged a broad density assumptions are required to achieve the housing need, a density set across the board is not in line with National requirements.

Question 41c - Do you support a requirement for large housing sites to provide serviced plots? Yes/No; any further comments?
Any policy should simply encourage provision rather than impose a "requirement". The accommodation of serviced plots for self or custom build on larger sites presents operational difficulties due to Health and Safety legislation as plots will often be built outside of normal working hours. They also create uncertainty and amenity problems for adjoining areas which may inhibit sales. Not every house builder will therefore wish to commit to such provision

Question 42- Do you agree that annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment?
In line with NPPF policy, any affordable housing targets are required to be based on a robust assessment of need and viability

Question 43a- Do you think that the existing Policy HOU3 site size threshold should be kept and 15 homes or more?
The site size threshold should be justified by viability evidence

Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites?
The target should reflect need/viability evidence as discussed above but any policy should not seek to load greater provision on Green Belt sites as this will simply inhibit overall delivery in these areas.
Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?
It is apparent from AMR data that the release of employment land for housing is proving unsuccessful. The employment to residential land change progression is insufficient to meet the more demanding housing targets. Therefore it is considered a move toward Green Belt release is more sustainable and DEL2 requires a fundamental review.

Question 99a : Do you think that the national standards for housing developments on water consumption should be introduced in the Black Country?
The adoption of optional higher water efficiency standard should only be applied using the criteria set out in the NPPG (ID 56-013 to 56-017). The Black Country has not been identified as a water stress area in an up to date Water Cycle Study.

Question 99b : Do you think that the national access standards for housing development should be introduced in the Black Country?
No. National accessibility standards should only be introduced in accordance with the criteria set out in the NPPG.

Question 99c : Do you think that the national space standard for housing development should be introduced in the Black Country?
The nationally described space standard should only be introduced in accordance with the criteria set out in the NPPG (ID: 56-020).

Question 99d : Do you think the standards should be different for brownfield and greenfield sites?
No. It is not relevant to whether site is brown or green field.

Question 118: Do you agree with proposals to streamline and simplify the Core Strategy Monitoring framework?
The plan making process in the Black Country should be improved. The existing adopted Core Strategy is over-due for review and second tier Local Plans are still not yet in place six years after adoption of the Core Strategy. Any streamlining and simplification of the monitoring framework should incorporate more effective monitoring mechanisms such as key performance indicators. Currently the Councils are underperforming by 3,000 dwellings against adopted Core Strategy housing targets without triggering any positive policy response.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 663

Received: 08/09/2017

Respondent: IM Properties

Agent: Turley

Representation:

The Spatial Strategy therefore needs to be comprehensively reviewed and rethought. Others will make the case (including our subsidiary company IM Land) for a review of the Green Belt in order to accommodate a minimum of 14,270 dwellings which cannot be accommodated within the urban area, even allowing for an increase in urban capacity of 10,000 dwellings. This assumes the redevelopment of some existing industrial sites within the urban area for residential use.

Full text:

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

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 685

Received: 08/09/2017

Respondent: Highways England

Representation:

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

Full text:

Dear Helen

BLACK COUNTRY CORE STRATEGY ISSUES & OPTIONS CONSULTATION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Yours sincerely

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

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

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 741

Received: 05/10/2017

Respondent: Wyrley Estate

Agent: Fisher German

Representation:

These challenges suggest that the existing spatial strategy and policies require a comprehensive review.

Full text:

My client owns land to the south of Holly Lane, in the Landywood village area adjacent to Great Wyrley. The sites are located either side of the local railway line between Birmingham and Rugeley. The sites extend to approximately 25 hectares in total area, and a plan showing the site's boundaries is enclosed with these representations, along with completed pro-forma for the site's formal submission to the Call for Sites exercise.

CORE STRATEGY ISSUES AND OPTIONS REPORT: CONSULTATION RESPONSE

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
Paragraph 4 of the Issues and Options Report highlights the new challenges that have emerged since the Core Strategy was adopted in 2011. The economic situation has changed and there are future opportunities associated with HS2 and the Midland Metro. In governance, the Local Enterprise Partnership and West Midlands Combined Authority have emerged with their overarching visions and objectives.

Paragraph 008 Reference ID: 12-008-20140306 in Planning Practice Guidance states that local plans will mostly require updating in whole or in part at least every five years. Reviews should be proportionate to the issues in hand. Authorities should also consider whether plan making activity by other authorities has an impact on planning and the Local Plan in their area.

Changes to national policy including the introduction of the National Planning Policy Framework, and the housing shortfall in Birmingham mean that neighbouring authorities have a duty to consider accommodating the needs.
The Issues and Options Report in paragraph 1.6 considers the existing Core Strategy will generally remain fit for purpose. It is proposed to 'stretch' the existing spatial strategy and update existing policies in light of new evidence and national policy changes. However, in paragraph 1.19 it is acknowledged that in the new Core Strategy:

"...it will not be possible to accommodate all future development needs within the urban area. Therefore, an examination of the potential for additional development on land outside the existing urban area, all of which within the areas of the four authorities is currently green belt, will need to take place as part of the Core Strategy review."

Whilst it is in everyone's interest to have an up-to-date Core Strategy and framework on which to base more detailed planning proposals, the strategy must be fit for purpose and reflect the latest evidence. There is no doubt this has changed considerably since adoption in 2011. There are approximately only nine years remaining of the plan period, with 11 having passed (2006-2026). Given the issues identified with housing needs and delivery shortfall, to be expanded upon below in specific questions, and the governance changes both regionally and nationally, the authorities must be clear that the existing strategy remains fit for purpose. At this initial stage, the pre-NPPF status of the Core Strategy means it is failing to deliver full objectively assessed housing needs in the Housing Market Area including unmet needs of neighbouring authorities; it prioritises brownfield development and has less than ten years remaining for the plan period. These challenges suggest that the existing spatial strategy and policies require a comprehensive review.

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

The key evidence base documents and issues appear to have been covered on this list. It is vital that the Strategic Growth and Green belt issues are comprehensively covered, having regard to the need to accommodate additional housing arising from the Strategic Housing Market Assessment and Birmingham overspill needs. Associated with these issues is the national planning policy requirement for a Duty to Co-operate, the commitment of note only the four core authorities to work together but also having engaged with neighbouring authorities including South Staffordshire. The need to jointly and proactively plan for the next 15-year period is essential and should be a thread running through these evidence base documents, even summarised in a separate report as an 'issue' in itself for the evidence.

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

The Issues and Options Report in paragraph 3.13 states that the Strategic Housing Market assessment (SHMA) concludes the objectively assessed housing need (OAHN) for the Black Country is 78,190 dwellings over the period 2014-2036. 3.18 states that once completions, existing and estimated supply in the urban areas are all factored into the supply, there is a remaining need for land to accommodate 24,670 new homes.

At this early stage in the review process, it is difficult to conclude that the housing need identified is appropriate, when several issues are unresolved. One of the key issues is the overspill from the Birmingham Development Plan. The Black Country authorities form part of the Greater Birmingham HMA; collectively they have a role to play in the resolution of 37,500 dwellings of unmet housing needs arising from Birmingham city over the period 2011 - 2031.

The Duty to Co-operate (S110 of the Localism Act 2011 which introduced S33A into the 2004 Act) requires the Council to cooperate with other prescribed bodies to maximise the effectiveness of plan making by constructive, active and on-going engagement. In satisfactorily discharging the Duty it is important to consider the outcomes arising from the process of co-operation and the influence of these outcomes on the Local Plan. One of the required outcomes is the delivery of full OAHN for market and affordable housing in a HMA as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182)
Given the immediate and pressing need for delivery of housing in the Greater Birmingham and Solihull Local Enterprise Partnership (GBSLEP) area, confirmed during the examination of the Birmingham Development Plan, significant emphasis should be placed on meeting existing needs for the housing market area, and also ensuring sufficient allowance for longer-term needs.

Further concerns are raised with the assumptions applied for the OAHN. The increasing need for affordable housing as evidenced in the Issues and Options Report is likely to be further compounded by the change in Government funding for affordable housing. In the future, there is likely to be even greater emphasis placed on the use of Section 106 Agreements to deliver affordable housing through the planning system, as opposed to directly through grant funding. The Issues and Options Report cannot predicate the delivery of affordable housing need based on past rates which were achieved through grant-funding. The authorities should consider making an upward adjustment to the OAHN with the sole purpose of securing additional affordable housing.

Market signals are a very important component of assessing the housing requirement. Paragraph 158 of the NPPF states that:

"Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals."

The SHMA has only considered an adjustment to reflect market signals for South Staffordshire, whereas in the Black Country itself no adjustment has been deemed necessary. The increase for South Staffordshire is supported in principle; however, the market signals (affordability, supporting economic growth) suggest an adjustment should be applied across the Black Country. This is very important because the household projections are recognised as the starting point in determining the housing requirement and project forward the rate of housing delivery achieved in the period prior to the plan making process commencing. In so doing, they fail to support the significant boost to housing delivery which is required by the NPPF and will perpetuate past trends of under delivery with the risk of worsening affordability consequently.

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

The statement in paragraph 3.47 that the Black Country Green Belt Review will be carried out in conjunction with South Staffordshire Council, is welcome.
The new Core Strategy plan provides an opportunity to ensure that the most recent evidence on housing needs can be taken into account, with the Green Belt Review enabling the release of land to meet these needs now, whilst also identifying suitable parcels of land to be released from the Green Belt and safeguarded to meet longer term needs.

Such an approach would comply with the requirements of the NPPF, which states that local planning authorities should ensure that local plans are based on an adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. When seeking to alter existing Green Belt Boundaries, it is therefore clear that a review of all potential sites to be released should be undertaken, based on a clear, objective methodology.


It is noted that South Staffordshire Council undertook a Partial Green Belt Review in 2016; however, it is clear that a wider assessment is needed given the SHMA findings and cross-boundary issues, including the Duty to Cooperate.
Given the challenging circumstances faced by the Black Country authorities - including South Staffordshire, it is vital that further land is released from the Green Belt to meet the development needs now and in the future. The NPPF is clear that Green Belt reviews should ensure that boundaries can endure beyond the plan period, so the identification of safeguarded land must also be considered at this stage.

The identification of a Strategic Growth Study is also welcome and should run alongside the Green Belt review to ensure consistency and a comprehensive approach.

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

The key issues have been broadly identified in paragraph 3.61 of the Issues and Options Report. Nevertheless, the emerging evidence on the OAHN is queried and the key issues should reflect the need for a comprehensive review of the spatial strategy. It is important that housing is planned for strategically and delivered on the scale envisaged through coordinated planning across boundaries. Such an approach which looks beyond each administrative boundary can help contribute towards sustainable patterns of development in the right places, thereby enhancing social wellbeing and tackling the issues associated with unsustainable development patterns.

The key issues summary should also acknowledge that the unmet housing needs for Birmingham need addressing across the wider housing market areas and that South Staffordshire should accommodate some of the Core Strategy's additional housing needs.

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

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

It is noted that one of the sustainability principles refers to putting brownfield land first. Furthermore, one of the ten spatial objectives are model sustainable communities on redundant employment land in Regeneration Corridors.
Whilst this approach was adopted for the pre-NPPF Core Strategy, given the challenges identified in preceding sections of this response, the review should consider all reasonable alternatives in strategy. The new Core Strategy should be encouraging the most efficient use of brownfield land in accordance with the NPPF rather than prioritising.

We have no objection to the principle of re-using previously developed land. There does, however, need to be a full acknowledgement of the challenges associated in bringing forward previously developed sites. These include development viability, the type of housing provided on typically smaller and denser sites, together with the need to ensure that all the new environments being created are attractive and of high quality. Such reasons are acknowledged in the Issues and Options Report as reasons why housing supply has not met the Core Strategy requirement; paragraph 2.10 of the Report states that a large pipeline of major housing sites, including occupied employment land which has been allocated for residential development, which have multiple constraints and financial assistance will be required which places added risk on their timely delivery.

It is therefore essential that, in preparing the Core Strategy review and housing supply delivery assumptions, the authorities adopt a cautious approach to brownfield development and do not overestimate the potential contribution that such land can make in meeting future development needs across the region. Greenfield sites, including those within the Green Belt and cross-boundary locations, are an essential component of the future supply and should be accommodated through the thorough review.

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?

Both options include the release of Green Belt land outside the Growth Network. It is vital that the options allow for Green Belt release in South Staffordshire Council, particularly in locations which adjoin the Black Country area.

Caution should be exercised with Strategic Option 1B which risks over reliance on releasing employment land for housing based on the assumption that past Local plan allocation trends continue. As acknowledged in the Issues and Options Report, this option is extremely challenging in terms of delivery and viability. Its robustness is questioned given that it is still to be tested. It will be necessary to test this on very clear and robust evidence of land availability, achievability, suitability and, very importantly, viability. Furthermore, a very cautious approach should be taken in relation to land supply from this source to reflect the risks often inherent in delivering housing on previously developed land.

Finally, there should be recognition that in general previously developed sites are likely to be less capable of providing affordable housing due to a number of viability considerations. Careful consideration is therefore needed of the potential affordable housing yield from this source of supply.

Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.

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

To meet the housing needs for the Black Country and South Staffordshire, the Core Strategy will require a combination of site allocations on different sources of sites. The right type and location of sites must be identified and this should have a bearing on the choice of allocated sites proposed through the Core Strategy review.

Housing delivery will be faster where there are the strongest housing markets with high demand from purchasers. Strong markets with high demand increase sales rates and provide developers with the greatest certainty regarding the timescales for completion of a site or phase of development. The Issues and Options report together with the SHMA evidence indicates a strong market in South Staffordshire; this has led to the proposed housing uplift to take account of market signals as per NPPF (and Planning Practice Guidance) policy. There are generally strong market conditions in good locations in South Staffordshire, including the area which adjoins the Black Country boundary. There is logic to provide housing where it is best placed to meet this demand; this includes South Staffordshire.

A greater range of sites than a select few Sustainable Urban Extensions (SUEs) under Spatial Option H2 would provide flexibility and choice in the market.
Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?

The export of housing to neighbouring authorities including South Staffordshire is strongly supported. Both the Black Country and South Staffordshire have challenging housing targets to deliver and, in accordance with the NPPF, the Core Strategy review must ensure that it is capable of delivering the housing needs identified. However, local planning policy as a whole must reflect the most recent evidence base and ensure that there is sufficient flexibility to demonstrate a five-year supply of deliverable housing land, ensuring competition and choice in the market for this land.

Concern is raised with the proposed approach in so far as it deals with Green Belt release from neighbouring authorities. Paragraph 4.33 acknowledges that some sites in neighbouring authorities could be more sustainable and deliverable than sites within the Black Country's Green Belt. Given that South Staffordshire Council falls within the same HMA and the Duty to Cooperate is being exercised, meeting the Black Country housing needs through land located in South Staffordshire Council is a plausible option. The release of Green Belt land should not necessarily be the last resort, as suggested in paragraph 4.31 of the Issues and Options Report - Paragraph 84 of the NPPF is clear that changes to the Green Belt "should take account of the need to promote sustainable patterns of development" and provides a very clear steer as to the evidence needed to make this judgement.

Question 15b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.
As stated, land at the southern extent of South Staffordshire Council should be considered for development through the Strategic Growth and Green Belt evidence base. Specifically, land south of Holly Lane, Landywood, Great Wyrley is in a highly suitable and appropriate location to meet the future open market and affordable housing needs. It is well-located relative to the boundary for the Black Country, being approximately 1.85km north of the urban edge for Bloxwich (Walsall). It is accessible to the M6 and Toll Road as well as local rail facilities.
The site comprises land either side of the Birmingham to Rugeley railway line, north of Landywood Farm. Both parcels represent deliverable options for housing at Cheslyn Hay and Great Wyrley. Detailed justification for the site has been set out in representations to the South Staffordshire Local Plan Site Allocations Document Publication Plan (2017), a copy of the representations is enclosed.
The site has development adjacent to at least two of its existing boundaries, is flat in nature and has clear field boundaries which are reinforced by existing hedgerow. The land north of Landywood Farm is enclosed on all sides by development and a defined boundary - the railway line.

The site is located to the south of Landywood and does not extend further south beyond the village's existing extent of development. It would in effect be enclosed by development and well-defined hedgerow/field boundaries. There would be no risk of merging with Landywood through the two sites identified and the extent of their boundaries, either practically or perceptually.

The site is very close to a range of services and facilities including the primary school, public house, employment sites and several bus stops along Strawberry Lane and Streets Lane. It is also within 1 km walk of Landywood railway station, which provides an hourly service between Birmingham and Rugeley on weekdays. Also within approximately 1km are services in the centre of Landywood including a community centre, church and shops.

This land is currently located within the Green Belt. However, having regard to the five functions of the Green Belt as set out in paragraph 80 of the NPPF, it is considered that this land could be released from the Green Belt without any harm to its wider functions.

The release of this land will enable the housing market area's needs to be met. However, even if it considered that this site is not required to meet needs within the current plan period, it should nevertheless be released to assist in meeting longer-term needs, and be subject to an appropriate safeguarding policy. This approach is in accordance with the Framework's requirement for Green Belt boundaries to be enduring and, following review, not require amending at the end of the current plan period.

Further details of the site's suitability is provided in the enclosed call for sites form, together with a location plan.

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

A housing market area is a geographical area defined by household demand and preferences for all types of housing, reflecting the key functional linkages between places where people live and work. It might be the case that housing market areas overlap.

The extent of the housing market areas identified will vary, and many will in practice cut across various local planning authority administrative boundaries. Local planning authorities should work with all the other constituent authorities under the duty to cooperate.

CONCLUSION

It is requested that the comments detailed above are taken into consideration in progressing the Core Strategy review and further evidence base gathering, particularly on Strategic Growth and Green Belt. Having regard to the Black Country authorities' emerging evidence and key issues in its Issues and Options Report, additional sites, such as the land south of Holly Lane in Landywood, needs to be released from the Green Belt through the Duty to Cooperate which applies to the Black Country authorities and South Staffordshire Council.

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 751

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation:

It is considered that a "partial" review of the BCCS should be followed with a considerable degree of caution, if at all. The existing Core Strategy was focused on urban regeneration and accommodating development needs entirely within the urban area, whereas the Review will necessarily adopt a balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core Strategy was adopted in very different circumstances following the financial crisis at the end of the last decade. It catered for different needs, with no requirement to accommodate overspill growth from Birmingham, no certainty as to how employment land requirements would evolve in subsequent years, and different expectations in terms of Midland Metro and HS2.

Full text:

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

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 962

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation:

We consider that the emerging Core Strategy should be the subject of a full review. The adopted Core Strategy predates the National Planning Policy Framework (NPPF) and the updated Core Strategy should be fully updated to take account of a change in circumstances. It covers four Local Authorities and is therefore crucial that the spatial strategy is fully reviewed so that all of the policies are relevant and up to date. Also the scale of the proposed changes to the existing strategy warrants a full and comprehensive Review. It is also essential that the Review takes account of the Birmingham Housing Market Area (HMA) shortfall.

Full text:

Dear Sir / Madam

Black Country Core Strategy Review - Issues and Options Consultation Response
Introduction We are writing to provide our response to the Black Country Core Strategy Issues and Options consultation on behalf of our clients who own land to the north of Hardwick, in the District of Walsall. As well as submitting a response to the questions set out in the Issues and Options document, we have also submitted our client's land to be considered through the Call for Sites process.
This letter includes our response to the following questions:
* Question 1 * Question 2 * Question 3
* Question 5 * Question 6 * Question 7
* Question 8 * Question 9 * Question 11
* Question 12 * Question 13 * Question 14
* Question 15 * Question 21 * Question 35
* Question 36 * Question 37 * Question 38
* Question 39 * Question 40 * Question 42
* Question 43 * Question 44 * Question 45
* Question 49 * Question 95

Site Context

Our clients' land is located adjacent to Chester Road to the north of Hardwick. Their land is approximately 23.6 hectares in size and is currently used for agricultural purposes. We consider that this land could be developed for residential or retail purposes and would form a logical extension to the existing settlement with a defensible boundary. We have attached a Call for Sites form and a location plan for your reference.

Issues and Options Response

Question 1

We consider that the emerging Core Strategy should be the subject of a full review. The adopted Core Strategy predates the National Planning Policy Framework (NPPF) and the updated Core Strategy should be fully updated to take account of a change in circumstances. It covers four Local Authorities and is therefore crucial that the spatial strategy is fully reviewed so that all of the policies are relevant and up to date. Also the scale of the proposed changes to the existing strategy warrants a full and comprehensive Review. It is also essential that the Review takes account of the Birmingham Housing Market Area (HMA) shortfall.

Question 2

No - Wolverhampton City Council is the only Black Country Local Authority which has updated it's Strategic Housing Land Availability Assessment (SHLAA) in 2017. Walsall's SHLAA is from 2016 and both Dudley and Sandwell's SHLAAs cover the period of 2015/2016. We consider that all of the SHLAAs must be updated to
represent the current availability of housing land.

Question 3

The figures in the Housing Supply Background Report (July 2017) are based on the adopted Core Strategy requirement from the 2006-based household projections that were published in 2008. We consider that these figures are outdated and the figures in the Housing Supply Background Report should be based on up to date housing requirement figures as set out in the Strategic Housing Market Assessment (SHMA) 2017.

There is also an inconsistency with the housing requirement within the Issues and Options document. The Core Strategy states that the housing requirement is 78,190 dwellings. However, table 7.1 of the SHMA states that the total Black Country housing requirement totals 78,105 dwellings. This point should be rectified.

We do not agree that 3,000 dwellings is an appropriately evidenced contribution towards the 38,000 dwelling Birmingham HMA housing shortfall. Although it is positive that the Black Country Local Authorities have included a figure to contribute to towards the HMA shortfall, there is no evidence to support the 3,000
dwelling figure and we consider that the Black Country will be expected (and potentially capable) to contribute more than this once distribution figures/locations have been finalised.

Question 5

We agree. NPPF paragraph 83 states that "Green Belt boundaries should only be altered in exceptional circumstances". The proposed 21,670 (+3,000 BHMA addition) housing shortfall and limited availability of alternative sites should count as exceptional circumstances. Birmingham did not have enough brownfield
land or other suitable alternatives to meet its housing need, and therefore 6,000 dwellings have been allocated within former Green Belt land at Langley, Sutton Coldfield. The Black Country's spatial connection and proximity to Birmingham means that areas of Green Belt land within the Black Country will be amongst
the most sustainable options to locate new residential development to help meet the HMA shortfall.

Question 6

We agree.

Question 7

We object to the adopted Core Strategy Sustainability Principle 4 'Brownfield First' as it is contrary to paragraph 17 of the NPPF which states that the principles of planning should 'encourage the effective use of land by reusing land that has been previously developed (brownfield land), it does not refer to prioritising
brownfield land before Green Belt land. Sustainable Principle 4 should be amended to be in accordance with the NPPF. This principle is potentially irrelevant where there is insufficient brownfield land to meet the housing requirement and all sites identified are required to meet the housing need.

Question 8

Strategic Objectives should be reviewed to include new housing developments which is a key focus at present due to the housing shortfall within the HMA. There is a significant shortfall of housing land currently available within the Black Country and the HMA. Therefore we consider that finding land for 21,670 (+3,000
BHMA addition) dwellings should be a key spatial objective within the Core Strategy.

Question 9

We do not consider that the policies should be retained. Policy CSP1 and CSP2 are old policies which predate the NPPF. The Black Country requires a new strategy for housing growth to deal with the significant Black Country and Birmingham HMA housing shortfall and therefore the policies should be updated
accordingly.

Question 11a

We support Strategic Option 1A "continue to strengthen the Growth Network with some corridors being housing led and others employment led. Remaining housing and employment land growth to be accommodated in the green belt". We consider that there would be a significant loss of potential employment land if Option 1B is selected which is required in order to meet the Core Strategy Vision of 'Economic Prosperity'. Issues of viability are a potential major challenge for this Option which may result in some housing/employment needs not being met if sites don't come forward during the plan period. We consider that a range of sites will need to be allocated which promote a balanced housing portfolio.

Question 12a

The theoretical capacity of our client's site is approximately 495 dwellings at 35dph using 60% capacity. Suitable sites should be adjacent to existing settlements and have a defensible boundary, such as roads or railway lines. The site we have identified could be reduced to provide a smaller housing opportunity north of Hardwick.

Question 12b

We consider that land to the north of Hardwick east and west Chester Road provides a potential location for sustainable growth and the railway line acts as a defensible boundary. The scale of opportunity to meet spatial option H1 could be considered through a detailed review with the Council's policy team.

Question 13a

Yes we also support spatial option H2 because we recognise that the Council will have a range of housing sites to consider. We propose that the land north of Hardwick could also be considered for a larger SUE opportunity at circa 600+ dwellings . This opportunity could include land to the south west of our client's site.

Question 13b

This will very much depend on the assessment of existing infrastructure and will need to be reviewed on a site by site basis.

Question 13c

We consider that land north of Hardwick should be considered as a potential SUE opportunity. This may require improved highways, education and community infrastructure.

Question 13d

The core strategy could set out high level strategic infrastructure expectations and capture cross boundary requirements. However more detailed site specific requirements should be left to local policies.

Question 14

We consider that a range of small / medium scale infill and SUE opportunities together with any re-use of brownfield sites could provide a range of sites suitable for meeting the Objectively Assessed Housing Need (OAHN).

Question 15a

We support the export of housing growth across the HMA area. The HMA area represents the most sustainable approach to solving the overall housing requirements in both the Black Country HMA and other neighbouring authority areas.

Question 15b

The consideration to other areas meeting the Black Country's housing requirement should only be given where evidence shows that the land within the Black Country cannot accommodate all of this need.

Question 15c

If housing has to be exported beyond the Black Country then first consideration should be given to areas close to the Black Country boundaries or via public transport corridors that serve the Black Country.

Question 21

We do not consider that Policy DEL1 should seek to assess infrastructure on the basis of whether the site is in the existing urban area or with the Green Belt. There is no evidence that Green Belt sites have any greater ability to pay more towards infrastructure (for example roads, utilities etc) than brownfield sites. Green Belt sites often have high infrastructure start up costs which need to be properly taken into account. Therefore we consider that the policy should be updated and based on a site by site considerations.

Question 35

We do not consider that Policy HOU1 is clear enough to reach an informed conclusion. Paragraph 6.20 states that the SHLAAs are up to date for the four Authorities. We do not agree with this statement as only Wolverhampton's SHLAA is from 2017, the rest of the SHLAAs are from 2015/2016. All of the SHLAA's should be updated to show the current supply of housing land.

Appendix B of the 'Black Country Housing Trajectory' sets out that the Authorities have not met their cumulative Core Strategy Target between 2006/07 - 2015/16 - cumulative target between 2016/17 to 2025/26 is even more aspirational. The Councils need to identify more sites in order to deliver this target.

The total completions figure for Walsall within Appendix C of the 'Black Country Housing Trajectory' is inconsistent with the figure in Table 1 of the Housing Supply Background Report (HSBR) July 2017. The BCCS refers to 6,137 dwellings whilst the HSBR refers to 6,165 dwellings. This inconsistency should be rectified.

Once the SHLAA evidence for the BCCS area is consistent and up to date the position on supply of deliverable housing sites should be made available to enable an informed review of whether the OAN housing supply is appropriate for the identified OAN.

Question 36

Before a review of Policy HOU2 and Table 8 is pursued, further evidence should be provided on whether the accessibility and density standards have been successful. We consider that to apply blanket policies on density do not always lead to the most appropriate forms of development.

Question 37a and 37b

Further evidence should be provided to confirm what proportion of housing delivery across the Black Country has been on sites of 15 dwellings or more. Where for example, a significant number of schemes are being built comprising between 10-15 dwellings, then a review of the threshold may warrant being undertaken.

Question 38

Not necessarily - the density of any new development should be appropriate to the density of the existing surrounding area, not necessarily being a lower density just because its a Green Belt release or higher density because it is a brownfield site. Should be done on a site by site basis.

Question 39

Yes potentially. Where car ownership / access to public transport can be shown to be greater for different types of housing then separate accessibility standards should be applied.

Question 40

Yes as long as they are in line with up to date evidence. The most up to date evidence should be applied.

Question 42

Prior to any change being proposed to the affordable homes target, detailed evidence should be undertaken to review a range of matters including viability and past deliver across the BCCS area.

Question 43a and 43b

Where evidence demonstrates the reducing the threshold to 11 homes or more will be achievable and viable then yes. However, there is a need for an achievable up to date affordable housing viability assessment in
order to assess whether this threshold is viable.

Question 44a and 44b

As per our responses to Q's 42 and 43a, the decision as to whether the affordable housing requirement should be changed requires further detailed evidence (viability and past delivery) to demonstrate that any changes are supported with up to date evidence.

Question 45

This question makes a sweeping assumption that all Green Belt sites have a greater financial viability than brownfield sites. This may not always be the case where significant investment is required in new infrastructure and S106 obligations are overloaded without due regard to site viability. Unless viability
appraisals are undertaken as part of a comprehensive approach including a review of infrastructure requirements, the basic assumptions should be properly supported by appropriate evidence.

Question 49a and 49b

Where evidence can be provided which clearly demonstrates that employment sites are no longer required for their current use then use for residential development may be appropriate. Of all of the BCCS Authorities, Walsall has the largest areas of Green Belt land and therefore, parcels adjacent to settlements within Walsall should be seriously considered for release to meet the housing requirement within the Black Country.

Question 95a

Where appropriate sites of sufficient scale can be identified to provide opportunities that meet the Garden City / Village principles then they should be considered.

Question 95b

Whether greenfield or brownfield sites are considered, there will need to be careful consideration of site details and context, including viability. These details will determine how the Garden City or Village principles could be applied.

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 1003

Received: 23/10/2017

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

Representation:

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

Full text:

Introduction.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

A few points are relevant here:-

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

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

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

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

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

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

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

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

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

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

Key issue 5 - Protecting and enhancing the environment.

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

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

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

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

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

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

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

The key issues outlined in paragraph 3.1 are as follows:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Questions 22-28, Social and Physical Infrastructure.

We have no further comments on these aspects.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Call for Sites - potential options.

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

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

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

Yours sincerely

John Acres

ACRES LAND & PLANNING LTD

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1080

Received: 07/09/2017

Respondent: Inland Waterways Association Lichfield

Representation:

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.

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:

Support

Black Country Core Strategy Issue and Option Report

Representation ID: 1124

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation:

Yes. Paragraph 153 of the National Planning Policy Framework (NPPF) states that each local planning authority should produce a Local Plan for its area and that this can be reviewed in whole or in part to respond flexibly to changing circumstances. Furthermore, the Planning Practice Guidance (PPG) identifies that for plans to remain effective, they need to be kept upto-date. The PPG highlights that policies will age at different rates depending upon local circumstances and that most local plans are likely to require updating in whole or in part at least every five years.

Overall Gallagher Estates support the partial review of the existing Core Strategy, subject to the above being achieved.

Full text:

See attachments

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1175

Received: 06/09/2017

Respondent: South Staffordshire Council, Planning and Strategic Services

Representation:

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

It is acknowledged that the existing spatial strategy of focusing urban regeneration at the Growth Network has been successful. This strategy aimed to deliver regeneration in the Black Country and prevents the outward movement of people and investment from the MUA. The South Staffordshire Core Strategy was developed as a counterpoint to this and looked to limit development to meeting locally identified needs. Recent developments in the Black Country have shown this to be an effective strategy and therefore it seems sensible to explore if there is scope to stretch the existing spatial strategy in the first instance.

This acknowledged, it is clear that the challenges now faced are very different from those faced when the current Black Country South Staffordshire Core Strategies were developed. Principally, it is clear that the Black Country housing and employment shortfall (25,000 dwellings and 300ha of employment land) cannot be wholly met within the urban area and that some Green Belt release is inevitable. The NPPF (Paragraph 83) is clear that Green Belt boundaries should only be altered in exceptional circumstances, and as such, all reasonable non-Green Belt options should be fully explored. The Government's recent Housing White Paper makes it clear that demonstrating exceptional circumstances for Green Belt release is a high bar, and Green Belt boundaries should only be amended where authorities can demonstrate they have examined all other reasonable options, including effective use of suitable brownfield sites and estate regeneration. Therefore brownfield sites should be maximised as far as possible - both within and outside the existing Growth Network. Similarly, whilst recognising that estate regeneration is very challenging, if this option is not going to be pursued then the plan should set out the reasons why this is not considered a viable and deliverable option.

Full text:

South Staffordshire Council response to the Black Country Core Strategy Issues and Options consultation

Purpose and scope of the review.

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

It is acknowledged that the existing spatial strategy of focusing urban regeneration at the Growth Network has been successful. This strategy aimed to deliver regeneration in the Black Country and prevents the outward movement of people and investment from the MUA. The South Staffordshire Core Strategy was developed as a counterpoint to this and looked to limit development to meeting locally identified needs. Recent developments in the Black Country have shown this to be an effective strategy and therefore it seems sensible to explore if there is scope to stretch the existing spatial strategy in the first instance.

This acknowledged, it is clear that the challenges now faced are very different from those faced when the current Black Country South Staffordshire Core Strategies were developed. Principally, it is clear that the Black Country housing and employment shortfall (25,000 dwellings and 300ha of employment land) cannot be wholly met within the urban area and that some Green Belt release is inevitable. The NPPF (Paragraph 83) is clear that Green Belt boundaries should only be altered in exceptional circumstances, and as such, all reasonable non-Green Belt options should be fully explored. The Government's recent Housing White Paper makes it clear that demonstrating exceptional circumstances for Green Belt release is a high bar, and Green Belt boundaries should only be amended where authorities can demonstrate they have examined all other reasonable options, including effective use of suitable brownfield sites and estate regeneration. Therefore brownfield sites should be maximised as far as possible - both within and outside the existing Growth Network. Similarly, whilst recognising that estate regeneration is very challenging, if this option is not going to be pursued then the plan should set out the reasons why this is not considered a viable and deliverable option.

Key Issue 1 - Updating the evidence base

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.

The Council agrees that all the key evidence based studies identified with Table 1 are necessary. However, which evidence based documents are required may depend on which options for growth are progressed. It is acknowledged that a Landscape Character Assessment will form part of the HMA Strategic Growth Study however a Landscape Sensitivity Study considering the relative sensitivity of land cover parcels will also be required. The Issues and Options confirms that the Core Strategy will allocate strategic sites, and therefore dependent on which options for growth are pursued, it may be appropriate to undertake an assessment of the impact on heritage assets and their setting. Historic England should be able to offer advice on this matter.

Key Issue 2 - Meeting the housing needs of a growing population

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

The housing need for the Black Country for the period 2014-2036 as identified in the SHMA is considered robust and the anticipated supply seems appropriate in line with national guidance; therefore the initial housing requirement of 24,670 is supported. The Council also supports the ongoing work to consider if there are options for surplus employment land to be allocated for housing, as well as considering the potential to increase the density of housing allocations and the limited release of surplus open space. Clearly, the Black Country authorities will need to demonstrate that the potential sources of supply within the urban area have been fully considered in order for Green Belt release to be justified.

Key Issue 3 - Supporting a resurgent economy

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

The recommendation that the Black Country should plan for 800ha of employment land (B1 (b), B1(c), B2 and B8 uses) as suggested within the Economic Development Needs Assessment (EDNA) appears robust and in line with national guidance. The Issues and Options paper goes on to confirm that 394ha of employment land is available or is likely to come forward in the Black Country over the plan period, including opportunities to intensify existing employment areas. It is then apparent that the Black Country authorities are seeking to rely on some 100ha of employment land in South Staffordshire when concluding that there is a residual need to identify some 300ha of employment land through the Core Strategy review.

As you are aware, South Staffordshire Council is progressing its Site Allocations Document that seeks to allocate 62ha of additional employment land at proposed extensions to i54 and ROF Featherstone to meet a proportion of the Black County's employment needs. Remaining employment land at our strategic sites is relied upon in the District's employment land supply to meet South Staffordshire needs and therefore any additional supply that South Staffordshire Council can contribute above the 62ha (including a proportion of land at West Midland Interchange should it be consented) would need to be agreed through Duty to Co-operate discussions and a Memorandum of Understanding. We will be undertaking our own EDNA next year which will consider our own need for additional employment land and will provide a clearer picture of how much additional employment land South Staffordshire could contribute towards the Black Country supply, if any. Until this work has been done and agreements have been reached about the amount of existing supply that can contribute to the Black Country need, it is not possible to say if the stated residual requirement for 300ha of employment land is appropriate. The Council would welcome further Duty to Co-operate discussions with the Black Country authorities to establish if any unmet employment land need from the Black Country can be met within the District.

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

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

South Staffordshire Council is working closely with the Black Country authorities and others authorities within the HMA as the commissioning authorities for the Strategic Growth Study. In addition to this, the Council supports the Black Country authorities' approach of producing a more detailed Green Belt review to inform the Preferred Spatial Options Report. Currently officers are working with counterparts from the Black Country in ensuring that the more detailed Black Country Green Belt review uses a consistent methodology with the South Staffordshire Green Belt review that will be commissioned to support our Local Plan review at an appropriate stage.

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?

In the context of a partial review of the Core Strategy, the key issues as presented in Part 3 of the Issues and Options Report are considered appropriate.

Vision, Principles, Spatial Objectives and Strategic Policies

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

In the context of a partial review of the Core Strategy, the Core Strategy vision and sustainability principles remain appropriate.

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

It is considered that most of these objectives remain valid. However, as it is acknowledged that some Green Belt release will be necessary, additional objectives around delivering sustainable urban extensions, or other smaller Green Belt releases (the 'rounding off' option) may be necessary dependent on which growth option is progressed.

Considering the pressure for housing and employment land it may be that a further objective around maximising brownfield opportunities - both within the Growth Network and outside it - is required.

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

The focus of the existing Core Strategy was to focus the majority of growth at the strategic centres and regeneration corridors, known collectively as the Growth Network and set out in Policy CSP1, and to see more limited growth outside the Growth Network and reflected in Policy CSP2. It is therefore agreed that such overarching policies should be retained and updated to reflect new evidence.

Considering the requirements for new housing and employment land, it is welcomed that the Issues and Options Report acknowledges that Policy CSP2 will be amended and subject to significant change in order to accommodate housing and employment land and to reflect proposed changes to the Black Country Green Belt. As stated in response to Question 1, all reasonable options should be considered and therefore fully exploring development options outside the existing Growth network, both Green Belt and non -Green Belt, is essential.

Reviewing the Spatial Strategy

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

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

The Council supports the Black Country authorities in re-examining the boundaries of the regeneration corridors to explore whether this could result in additional sites for housing and/or employment land.

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?

Whilst there may be scope for the release of some occupied employment land for housing in certain locations in the Growth Network (Strategic Option 1B), the loss of employment land would need to be offset in the Green Belt and therefore this option is unlikely to reduce the loss of Green Belt overall. It is also acknowledged that there are likely to be delivery and viability issues around Option 1B. On this basis, the bulk of the remaining housing and employment needs are likely to need to be met outside the Growth Network (Strategic Option 1A). However, before this is concluded, the authorities will need to demonstrate that there are no other deliverable sources of supply (e.g. estate regeneration) within the Growth Network.

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

No comment.

Stage 2: Strategic Options 2A and 2B - Housing and Employment outside the urban area

Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.

It is noted that both options outside the Growth Network (Strategic Option 2A and 2B) would involve Green Belt release. As stated in response to questions 1 and 16, all reasonable non-Green Belt options should be explored, and therefore the authorities will need to demonstrate that there are no other deliverable sources of supply (e.g. estate regeneration and increasing development density) within the urban area outside of the identified Growth Network. Once this has been demonstrated, it is considered that exploring a combination of Spatial Options H1 and H2 will need to be explored.

As Spatial Option H1 would see the 'rounding off' the edge of the Green Belt, including internal Green Belt wedges, it is envisaged that this will see the release of a number of small to medium sized sites. Considering the upfront infrastructure delivery for Sustainable Urban Extensions (SUEs) (Option H2) it is considered that from a delivery perspective, a number of these smaller 'rounding off' sites will need to come forward to ensure housing is being delivered over the short term (0-5 year period). The Issues and Options report confirms that this 'rounding off' option may not yield sufficient capacity to accommodate all the growth needs, and if this is the case, then a combination of 'rounding off' sites, as well as SUEs, are likely to be required to meet the growth requirements.

In terms of what criteria should be used to select such sites, this must be evidence led. Of particular importance will be the outcomes of the Strategic Growth Study and Black County Green Belt Review in terms of the contribution that these site play to the Green Belt. A Landscape Sensitivity Study will also be a key piece of evidence for determining the degree of landscape sensitivity, to ensure that areas of very high sensitivity remain undeveloped where possible. Access to services and facilities will need to be considered, however these sites by their nature will adjoin the urban area, and therefore in most cases there is likely to be adequate access to amenities. It is not considered that a size threshold should be imposed on these 'rounding off' sites; however sites should follow defensible boundaries, such as existing roads, watercourses and hedgerows where possible.

An important consideration when considering options for growth will also be the Cannock Chase SAC. The Council welcomes the continued involvement of the relevant Black Country authorities in the Cannock Chase SAC Partnership through the Core Strategy Review process. Any development proposals in the Core Strategy Review need to come forward in accordance with the most up to date evidence to ensure that development does not have an adverse impacts on European protected sites.

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

To reiterate, it is important that site selection is evidence led, and therefore crucially, it is essential that all sites/areas with 'rounding off' potential are considered. This includes areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken. Where necessary, land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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

As set out in response to Question 12a, there is likely to be a requirement to allocate SUEs to meet the identified growth requirements in addition to smaller 'rounding off' sites. However, it is unclear if this option includes options for new standalone settlements in the Green Belt, or will just focus on SUEs that adjoin the urban area. It is suggested that, considering the scale of the housing and employment requirements, new standalone settlements could be considered at this early stage of plan preparation under this option.

It is considered that any SUE would need to provide a mix of house sizes and specialist housing (for example for the elderly) where there is evidence of need, and an appropriate level of affordable housing. The Council also believes there are options for new employment land to be allocated within SUEs. In particular there may be scope for modern industrial units aimed at SME businesses offering supply chain opportunities to serve established businesses in the area. Clearly sustainable development principles should be followed with good access to amenities, public transport, employment opportunities, sport and recreation and other green infrastructure.

An important consideration when considering options for growth will also be the Cannock Chase SAC. The Council welcomes the continued involvement of the relevant Black Country authorities in the Cannock Chase SAC Partnership through the Core Strategy Review process. Any development proposals in the Core Strategy Review need to come forward in accordance with the most up to date evidence to ensure that development does not have an adverse impacts on European protected sites.

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

It is suggested that SUEs would typically need to be in excess of 750 houses to facilitate a primary school and it is likely that developments would need to be larger than this (in excess of 1000) to provide a local centre. A self-contained development is likely to be in excess of 2000 -2500 homes; with 5000 homes the typical threshold to facilitate a new high school.

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

It is important that site selection is evidence led, and therefore it is essential that all sites/areas with potential to accommodate an SUE are considered. This includes areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken; for example the Strategic Growth Study, any further fine grain Green Belt assessment, Landscape Sensitivity Study and market capacity evidence. Where necessary, land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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

The Council supports the Core Strategy setting out detailed guidance and broad parameters for design and layout of SUEs, including the type of tenure of housing, employment land requirements, infrastructure and service provision and open space requirements etc. It may be that these requirements are set out in a proforma for each proposed SUE, which then hooks to the relevant SUE allocation policy.

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

As set out in previous responses, if Green Belt release is proposed then the authorities will need to demonstrate that all reasonable non-Green Belt alternatives have been considered. This should include exploring funding opportunities to deliver constrained brownfield sites, increasing site densities within the urban area and exploring any opportunities for estate regeneration.

As set out in response to Question 13a, at this early stage of plan preparation, Spatial Option 2a should consider options for new standalone settlement as well as SUEs that adjoin the urban area.

Meeting housing needs outside the Black Country

Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?

If it is clearly demonstrated that housing need cannot be met within the Black Country by carrying out a robust and transparent assessment of all non-Green Belt and Green Belt options, then it is acknowledged that some of this housing growth will need to be exported to other authorities within the Greater Birmingham HMA. This could potentially be to neighbouring HMAs should it be robustly demonstrated that the shortfall cannot be met within the Greater Birmingham HMA. The Strategic Growth Study will provide an indication of where opportunities may exist outside the Black Country and these opportunities could then be explored further by the relevant authority through local evidence gathering.

It is clear that there are significant pressures for new housing, employment and Gypsy & Traveller provision and these key cross boundary issues will need to be addressed through our respective local plans. It is the Council's firm view that this is a two-way negotiation and the role that South Staffordshire might play in this regard needs to be very carefully explored. An equitable and fair approach, which recognises the environmental, physical and infrastructure constraints, as well as the availability of sites to meet specific needs, should be robustly evidenced when addressing these issues under the Duty to Cooperate.


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

Potential locations outside the Black Country, similar to considering options for 'rounding off/SUEs within the Black Country, should be evidence led. Therefore, this could include areas that haven't been put forward through the 'call for sites' but perform well in planning terms based on the evidence undertaken; for example the Strategic Growth Study, any further fine grain Green Belt assessment, Landscape Sensitivity Study and market capacity evidence. Where necessary land searches/land assembly should be undertaken to ascertain if these sites are available and deliverable.

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

Whether development is delivered within the Black Country or is exported elsewhere it will need to comprise sustainable development that meets the needs of the people who live there. If housing is exported, it will be for the LPA(s) in question to allocate sites through their Local Plan alongside appropriate infrastructure having undertaken a Sustainability Appraisal to ensure that sustainable development is being achieved.

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

Question 16 - Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E1 of extending the Black Country's existing employment sites on the edge of the urban area into Green Belt land where it is demonstrated that there is insufficient options for employment land within the urban area. It is considered that there is a need for a mix of employment sites, both in terms of use class, size and quality. Overall, it is likely that the authorities will need to provide a range of employment land from sites aimed at large advanced manufacturing companies, through to small scale modern fit for purpose industrial units aimed at existing SMEs and start-up businesses.

In most instances, good access to the strategic road network is a key criterion, particularly for logistics companies, however for more local quality manufacturing this may be less of a factor. Access to labour markets, including accessibility to employment via public transport is also seen as key site selection criteria.

Question 17 - Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E2 of providing new freestanding employment sites in sustainable locations in the Black Country's Green Belt where it is demonstrated that there is insufficient options for employment land within the Black Country urban area. New freestanding employment sites are more likely to be aimed at larger advanced manufacturing and/or distribution companies and therefore good access to the strategic road network is seen as key. Again, access to labour markets, including accessibility to employment via public transport is also seen as key site selection criteria.

Question 18 - Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).

The Council supports Spatial Option E3 of providing new employment land within Sustainable Urban Extensions (SUEs) in the Green Belt where it is demonstrated that there is insufficient options for employment land within the urban area. In particular, there may be opportunities within SUEs to provide modern industrial units on new business parks as part of a sustainable mixed use development. These are more likely to be aimed at existing SMEs and start-up businesses.

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

The Council acknowledges that alongside the other three spatial options, there may be a requirement to export employment growth to neighbouring areas. It is acknowledged that South Staffordshire has strong economic links with the Black Country as demonstrated by the fact that our emerging Site Allocations will provide an additional 62ha of employment land to meet Black Country needs.

The Black Country EDNA concludes that South Staffordshire and Birmingham are the areas with the strongest economic links to the Black Country, but acknowledges that there are also links with other adjoining areas e.g. Lichfield, Cannock and Bromsgrove. Clearly, the employment land requirements for the Black Country are significant, reflecting the growth aspirations of the Black Country and wider West Midlands Combined Authority. Considering the scale of the need, if it is demonstrated that Spatial Option E4 is an appropriate option, then options to export to all neighbouring authorities with an economic relationship to the Black Country should be considered under this option.

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

It is agreed that good access to the strategic road network with good sustainable public transport links are important factors if the export option was to provide large scale freestanding employment site(s). Further, consideration should also be given to which communities in the Black Country the sites will serve. Clearly, sites on the northern edge of the Black Country are less likely to serve residents in Dudley and Sandwell and vice versa. Therefore, if employment sites are provided outside the Black Country then this should be done in a way that avoids the overconcentration of sites in one area.

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

No other options are suggested at this stage. It may be the case that a combination of all options is needed to meet the Black Country employment requirements. As set out above, assuming that the export option is required, all neighbouring authorities with an economic relationship to the Black Country should be considered under Spatial Option E4.

Delivering Growth - Infrastructure and Viability
Introduction and scope

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

It is agreed that the policy may need to be reconsidered. Where Green Belt release for SUEs/employment land is proposed then it may be that there is a hook in the policy to link to site specific proformas/development briefs for these sites. These could clearly set out what infrastructure is required to be delivered, both on and off site.

Social Infrastructure

Question 22 - Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

We have no evidence with regard to social infrastructure needs in the Black Country.

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

We have no evidence with regard to surplus social infrastructure provision in the Black Country.

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

We have no evidence with regard to social infrastructure needs in the Black Country. However, it is acknowledged that new housing will put pressure on social infrastructure both within the Black Country, and the surrounding local areas and therefore the authorities will need to engage carefully with cross boundary social infrastructure providers to ensure that they understand the 'tipping point' at which new development will facilitate the need for additional social infrastructure provision.

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

See response to Question 24.

Physical Infrastructure

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

We have no evidence at this stage with regard to physical infrastructure needs in the Black Country.

Question 27 - Do you have evidence of pressure being placed on the capacity of current physical infrastructure which could be exacerbated by new developments? Yes/No; If yes, please provide details.
We have no evidence with regard to physical infrastructure needs in the Black Country. However, it is acknowledged that large scale new development (for example SUEs) are likely to require substantial upfront infrastructure provision.

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

See response to Question 27.

Delivery and Viability

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

Clearly infrastructure provision through Section 106 and 278 agreements and CIL will be essential. No other tools or interventions are suggested.

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

It is considered that in order to maintain the urban regeneration strategy, a brownfield first approach should be explored to its fullest extent. Therefore, all funding options should be explored to try and deliver as many problematic brownfield sites as possible.

Funding for Site Development and Infrastructure

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?

Both private and public sector investment will be needed to deliver the Core Strategy. The availability of funding sources will impact on viability, and therefore robust viability, delivery and infrastructure studies will be needed when determining if the proposed Core Strategy policies are feasible.

Review of Existing Core Strategy Policies and Proposals

Policy Area A - Health and Wellbeing

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

It is agreed that spatial planning and place making does have a key role in improving the health and wellbeing of residents and therefore incorporating a health and wellbeing into the Core Strategy is fully supported.

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?

A number of policy areas, e.g. open space and sports provision, affordable housing delivery tie in with the health and wellbeing agenda and these will be picked up in other Core Strategy policies. There may however be a role for overarching health and wellbeing policy that ties these together to ensure it is clear on how development will be expected to contribute towards healthier communities.

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

Undertaking a Health Impact Assessment for large developments in addition to considering their impact through the Sustainability Appraisal (SA) is supported.

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?

Applying good practice design principles, including provision of on site open space and links to existing green infrastructure will be essential. It is also important that larger schemes to include facilities for children's play and youth development.

Policy Area B - Creating Sustainable Communities in the Black Country

Policy HOU1 - Housing Land Supply

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

The proposed approach to housing land supply is supported.

Policy HOU2 - Housing Density, Type and Accessibility

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

The Council supports the proposal to increase the minimum net density of 35 dwellings per hectare to maximise brownfield housing delivery. Densities should be reconsidered through the emerging viability and delivery evidence and efficient use of land be promoted.

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

The authorities should consider lowering or removing the threshold for applying density standards as in many instances high densities may also be appropriate for small sites of less than 15 dwellings.

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

The site size threshold could be reduced to less than 11 if there is evidence to suggest that this will not impact on deliverability.

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

It is important that efficient use of land is encouraged so as to limit Green Belt release as far as possible, particularly given the Housing White Paper's requirement to limit the need for Green Belt release by optimising the proposed density of development. Therefore, where Green Belt release has been shown to be necessary, the minimum net density of any Green Belt release should not be set below the standards for the adjacent urban area.

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

As locations for residential development will principally focus on sites within the urban area or Green Belt locations on the edge of the urban fringe, it is considered that none of these locations will be isolated with fundamental accessibility concerns. Therefore, separate accessibility standards for different types of development are not considered necessary. With regard to affordable housing, this should be provided on site where possible.

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

Yes.

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

Yes.

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

Considering the low numbers on the register currently (nine for the entire Black Country), It may be most appropriate to set a target for each authority, rather than a percentage requirement for each large development coming forward. One potential approach could be to extrapolate need evidenced from the base periods to date, in order to determine how many plots each authority should be providing over the plan period.

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

See response to Question 41b.

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

See response to Question 41b.

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

No comment.

Policy HOU3 - Affordable Housing

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

It is agreed that the annual affordable housing target should be directly informed by the 2017 SHMA.

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

It is agreed that the threshold requiring sites to provide a proportion of affordable housing set out in Policy HOU3 should be lowered to 11 homes or more in line with Government guidance.

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

See response to question 43a.

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

A requirement for 25% affordable housing seems reasonable considering the viability constraints that may be associated with some sites. This is also in line with the requirement identified in the SHMA.

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

It may not be necessary to increase the affordable housing percentage requirement in order to increase the provision of affordable home ownership now that the Housing White paper appears to have removed the specific requirement to deliver starter homes (20%) on all sites over a certain threshold. The 10% requirement for affordable home ownership products can be met within the proposed 25% affordable housing policy. The split within this between shared ownership, starter homes and other types of affordable home ownership could then be dealt with by negotiation, considering the comments in 6.37 which note that most starter homes in the Black Country would not necessarily be genuinely affordable in all areas. This would also still leave a 15% requirement for rented products, which is only marginally below the 16.6% recommended in the SHMA.

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

The SHMA confirms that the Black Country authorities should aim for 28.6% (23.3% if starter homes are excluded) of new housing to be affordable housing; therefore on this basis there may be limited scope to go above 25% on greenfield sites. However, considering that these could be large sites that would need substantial onsite infrastructure provision then a cautious approach should be taken to going above 25%. Setting an appropriate percentage should be directly informed by a high level viability study.

Policy HOU4 - Accommodation for Gypsies, Travellers and Travelling Showpeople

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

The targets set out in Tables 4 and 5 are taken from the Black Country and South Staffordshire GTAA 2017 and therefore are deemed appropriate for identifying the Black Country's pitch/plot requirements. However, as you are aware the 2017 GTAA identified a pitch requirement of 87 residential pitches for South Staffordshire for the period 2016-2036, considerably above the pitch requirements for the four Black Country authorities combined. Historically, pitch provision in South Staffordshire has been in the Green Belt as no non-Green Belt options have ever been promoted. Therefore, assuming that this remains the case, there will be a requirement through our Local Plan review to demonstrate that we have explored other reasonable options to amending Green Belt boundaries including exploring whether other authorities can help to meet some of the identified development requirement, as set out in the Housing White Paper. As such, there will be a requirement through Duty to Co-operate discussions to explore whether there may be deliverable brownfield options in the Black Country to meet a proportion of the districts pitch requirements. On this basis, a flexible approach to setting pitch targets and exploring pitch/plot options is suggested.

It is clear that there are significant pressures for new housing, employment and Gypsy & Traveller provision and these key cross boundary issues will need to be addressed through our respective local plans. It is the Council's firm view that this is a two-way negotiation and the role that South Staffordshire might play in this regard needs to be very carefully explored. An equitable and fair approach, which recognises the environmental, physical and infrastructure constraints, as well as the availability of sites to meet specific needs, should be robustly evidenced when addressing these issues under the Duty to Cooperate.


Policy HOU5 - Education and Health Care Facilities

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

Expanding Policy HOU5 to include a criteria based approach which requires service providers to demonstrate why health care and education facilities are no longer required or viable is welcomed. It is agreed that this approach should be expanded to other types of social infrastructure such as community centres.

Including standards for built social infrastructure to serve major housing developments set out in Policy HOU5 is also considered appropriate.

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

This policy should be reviewed to reflect a clear criteria based approach to considering the loss of social infrastructure, and should be expanded beyond health and educational facilities where appropriate. One of these criteria could relate to ensuring that the developer demonstrates that there is adequate alternative provision to meet the needs of the community.

Policy Area C - The Black Country Economy

Policy DEL2 - Managing the Balance between Employment Land and Housing

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

The existing wording for Policy DEL2 seems very broad, setting out completions to date and how many are expected to come forward within each regeneration corridor. A clearer approach may be to specifically identify areas of Local Quality Employment Land that is considered poor quality and therefore suitable for release for housing, either through a revised Core Strategy policy or through allocation documents.

Question 49b - If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.

A revised policy could set out areas of poor quality employment land that could be suitable for release for housing or alternative uses, providing clarify on what uses may be acceptable.

Policy EMP1 - Providing for Economic Growth and Jobs

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

It is considered that the authorities themselves are best placed to decide if there is any value in setting a target for the total employment stock within the Black Country. Setting a target for the additional employment land that is required is a clearer approach; however if possible, there may be a need to have a mechanism in place to ensure that any loss of existing high quality sites to other uses is compensated by new provision reflected in updated targets. Robust monitoring and national guidance encouraging authorities to review plans in whole or part every 5 years should ensure that any issues around the loss of existing high quality employment land can be addressed.

Policy EMP2 - Strategic High Quality Employment Land and Policy EMP3 - Local Quality Employment Land

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

The criteria used to define High Quality Employment Areas are supported. There may however be scope to slightly amend the accessibility criteria to focus on good access the strategic road network, rather than just focusing on access to the motorway network.

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?

The criteria used to define High Quality Employment Areas are supported.

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 High Quality Employment Areas should be focused on advanced manufacturing and logistics and be protected for these uses.

Policy EMP4 - Maintaining a supply of readily available employment land

Question 54 - Do you agree that the current approach in Policy EMP4 is no longer fit for purpose and should be amended to reflect a portfolio based approach? Yes/No; If no, what alternative approaches would you recommend?

Removing the requirement to have a 'reservoir' of readily available shovel ready employment land is supported. The provision to review plans in whole or part every 5 years will help ensure that there is a constant supply of employment land, providing scope to allocate additional employment land if required. Ensuring provision for a balanced portfolio of sites is important

Policy EMP5 - Improving access to the labour market

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

Policy EMP5 encourages the use of planning objections to be negotiated with developers of new job creating development in order to support recruitment and training of local people. This approach is fully supported as access to a skilled workforce is a key consideration for businesses.

Policy EMP6 - Cultural Facilities and the Visitor Economy

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

Updating the list of visitor attractions and facilities in Policy EMP6, which seeks to develop the visitor economy and cultural facilities of the Black Country is supported.

Policy Area D - The Black Country Centres

Policy CEN1: The Importance of the Black Country Centres for the Regeneration Strategy

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

Merging these policies relating to the town centres seems logical.

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

The Council has no evidence to suggest that the hierarchy of centres is not appropriate. However, the Retail Capacity and Town Centre Uses studies should be used to inform the hierarchy. It is recognised that a number of the Black Country centres - particularly the strategic centres - play an important role in meeting the higher order needs of our residents including access to hospitals, retail and leisure. Therefore, their continuing regeneration is fully supported.

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

From the Council's knowledge, It appears that all the appropriate centres within the Black Country have been identified.

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

We have no evidence on the performance of centres or relating to their level within the hierarchy of centres.

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

As an indicative rule, development of around 1000 houses or more are likely to require a new centre. Therefore, if the evidence suggests a need for new developments around this scale then clear criteria for the creation of new centres will be required. It may however be appropriate to have site specific infrastructure requirements for large strategic allocations (e.g SUEs) identified in the Core Strategy. These would include the requirements for new centres.

Policy CEN3: Growth in the Strategic Centres

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

It is logical for the existing strategic centres such as Wolverhampton and Brierley Hill to be the focus for retail, office and commercial leisure development. This is important for their continuing regeneration.

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

It is agreed that retail and office floorspace needs should be revisited.

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

We have no evidence to confirm if there is a need to set a target for convenience retail floorspace. The proposed Retail Capacity and Town Centre Uses studies should be used to inform this.

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

Targets for leisure development may be appropriate where supported by evidence of need. It may be appropriate to undertake an audit of sports facilities as part of this evidence gathering and consider cross boundary provision dependent on the evidence of need/demand. If this is deemed appropriate then close liaison with Sports England is recommended.

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

The authorities will need to demonstrate that they have fully considered options for additional housing in the strategic centres, whilst recognising that other uses such as retail will also be the focus of these centres. The Council supports the authorities setting new housing targets for the strategic centres.

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

Retail, offices, housing, leisure and cultural facilities should be the focus of the strategic centres.

Brierley Hill Retail Pre-Conditions

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

The Core Strategy review is considered the correct time to re-examine any conditions relating to retail growth at Merry Hill.

Policy CEN4: Regeneration of Town Centres

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

It is considered appropriate to encourage convenience shopping and other mixed use development (e.g. community centres) to support new residential development within the strategic centres.

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

No specific suggestions.

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

Policy CEN5: District and Local Centres

The authorities will need to demonstrate that they have fully considered options for additional housing in the strategic centres, whilst recognising that other uses such as retail will also be the focus of these centres. The Council supports the authorities setting new housing targets for the town centres.

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

Flexibility of uses is encouraged in the Local Centres.

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

No specific suggestions.

The Centres Threshold Approach

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

No comment.

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

No comment.

Policy CEN6: Meeting Local Needs for Shopping and Services

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

The approach of protecting local shops and small parades unless it can be demonstrated that they are no longer viable is supported. The authorities may want to consider setting out clear expectations on what evidence would be required to justify the applicants viability case.

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

No comment

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

Clarification that the policy applies to edge-of-centre and out-of-centre locations is supported

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

No comment

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

No comment.

Policy CEN7: Controlling Out-of-Centre Development

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

This approach seems appropriate.

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

No comment.

Policy CEN8: Car Parking in Centres

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

No comment.

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

No comment.

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

No comment.

Other Centres Issues

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

No specific suggestions.

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

As retail trends continue to change with the continued expansion of online shopping it is essential that Local Plan policies on centres strike the correct balance between ensuring that town centres uses cannot be too easily lost, whilst also ensuring there is flexibility to adapt to changing retail trends. Where retail, leisure or other commercial uses are not viable then reallocating these for housing or employment uses would be supported.

Policy Area E - The Black Country Transport Network

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

The overall transport strategy of providing better use of existing capacity as well as providing new sustainable transport capacity to provide an integrated transport system for the West Midlands is supported. Achieving this will help support the Core Strategy Spatial Objectives.

Policy TRAN1 - Priorities for the Development of the Transport Network

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

The updated transport priorities in TRAN1 are generally supported. However, reference of 'development of road to freight interchange facilities to serve the sub region' is vague. It is unclear if this is making specific reference to the development of a Strategic Rail Freight Interchange (SRFI), which by the Governments definition is an Interchange in excess of 60ha and capable of handling 4 trains a day, or a number of smaller RFI facilities within the Black Country. That said, Paragraph 6.1.40 of the Issues and Options makes specific reference to rail freight interchanges proposals coming forward at Bescot and Four Ashes (currently being promoted as West Midlands Interchange (WMI)) which suggests that the transport priority relating to rail freight at Para 6.1.36 may relate specifically to Four Ashes. As you are aware, the WMI proposal is in the Green Belt and is still at the pre-application stage and therefore any transport priorities that relate to this proposal are considered premature.

Policy TRAN2 - Managing Transport Impacts of New Development

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

Proposed changes to reference greater focus on choice of modes of transport for access to new developments, including electric vehicle charging infrastructure, provision for cycles etc. is supported.

Policy TRAN3 - The Efficient Movement of Freight

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

The proposed change to Policy TRAN3 is to remove reference to the 'principle road network' to be replaced with reference to the 'key route network' which is defined in the West Midlands Combined Authority 'movement for growth' plan. It is our understanding that the 'key route network' is a term used to describe the metropolitan main road network. The current reference in the policy is as follows:

Proposals which generate significant freight movements will be directed to sites with satisfactory access to the principal road network.

It is unclear from the Issues and Options report if this change is simply to provide consistent terminology with that used in the WMCA transport plan, or if this will result in a material change to the policy. Specifically, it is unclear if the reference to the principal road network was referring specifically to the road network within the Black Country? Whereas the 'key route network' seems to refer to a wider area across the region. Clarification on this would be welcomed.

Policy TRAN4 - Creating Coherent Networks for Cycling and Walking

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

The approach of providing a coherent network for walking and cycling is supported.

Policy TRAN5 - Influencing the Demand for Travel and Travel Choices

Question 93 - Do you support the proposed changes to Policy TRAN5? Yes/No; Please explain why.

The proposed inclusion of priorities in Policy TRAN5 around introducing new transport technologies such as ultra low emission vehicles is supported.

Policy Area F - The Black Country Environment

Environmental Infrastructure and Place-Making

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

The proposed changes to environmental policies to reflect adopted DPDs and include new proposals to address the environmental infrastructure needs of new developments in light of up-to-date evidence seems appropriate.

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

Good plan making objectives such as providing comprehensive green infrastructure, integrated and accessible transport networks, access to employment and affordable housing provision are amongst those that make up the garden city principles. These requirements will be picked up through applying the relevant individual policies.

Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.

The may be more scope to apply the garden city principles on larger greenfield sites. Considering that there may be viability issues on some brownfield sites, it may be less realistic to apply the garden principles on these sites.

Policy ENV1 - Nature Conservation

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

Updating the policy in line with the NPPF and the introduction of requirements for new development to incorporate biodiversity features, such as new natural green space, is supported.

Policy ENV2 - Historic Character and Local Distinctiveness

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

Updating the policy in line with the latest national policy and guidance is supported.

Policy ENV3 - Design Quality

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

Removing reference to requiring a specific code of sustainable home in line with national guidance is supported.

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

This is considered for the authorities to decide in consultation with the water companies.

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

Introducing an access standard so that a percentage of new builds would be usable or easily adaptable for those with disabilities is supported. However, in terms of the threshold of where this percentage is set, this would need to informed by viability evidence. It may be that it would not be viable to apply this policy on certain types of sites e.g. small brownfield sites; again this could be considered in the viability evidence.

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

Applying the Nationally Described Space standard (CLG, March 2015) is supported should the evidence suggest that this would not impact on viability.

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

It may be appropriate to have different standards for brownfield and greenfield; this could be considered in the viability evidence.

Policy ENV4 - Canals

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

It is understood that part of the route of the Hatherton Branch Canal is safeguarded in proposed Policy EN4 of Walsall's Site Allocations Document. On this basis it is considered appropriate to remove reference to the restoration of the Hatherton Branch Canal from the Core Strategy, and for this to be considered at the more local level.

Policy ENV5 - Flood Risk, Sustainable Drainage (SuDS) and Urban Heat Island Effects

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

The propose changes to align with national policy and guidance is supported.

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

None suggested.

Policy ENV6 - Open Space, Sport and Recreation

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

It is not clear what specific changes are proposed, however if the existing policy is in line with national policy then it may be that the changes needed are minimal.

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

It is considered that paragraph 74 of the NPPF offers sufficient protection from development for open space.

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

None suggested.

Policy ENV7 - Renewable Energy

Question 103a - Do you think that Policy ENV7 should be changed to allow increased energy efficiency standards to be accepted in lieu of renewable energy provision for non-domestic buildings? Yes/No; If not, please explain

Increased energy efficiency standards for non-domestic buildings would be supported; however this would need to be supported by plan viability evidence confirming that this is achievable.

Question 103b - Do you think that the 10% requirement should be changed? Yes/No; If yes, please specify what percentage would be more appropriate and to what type of site it should apply.

Any percentage requirement relating to energy demand would again need to be supported by plan viability work.

Policy ENV8 - Air Quality

Question 104 - Do you support the proposed changes relating to Air Quality? Yes/No; If you think that any other changes should be made to Policy ENV8 please provide details.

Rewording the policy to reflect the approach in the more recent Black Country wide SPD on Air Quality and the West Midlands Low Emissions Towns and Cities Programme (WMLETCP) seems appropriate.

Policy Area G - Waste

Question 105 - Do you think that Policy WM1 identifies all of the key waste issues that need to be addressed in the Core Strategy, in accordance with national policy? Yes/No; If not, please specify what changes should be made to the Policy. If you have any evidence that can be referred to in the Waste Study, please provide details.

No comment.

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

No comment.

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

No comment.

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

None suggested.

Question 107 - Do you think that there are any strategic waste management proposals that should either be removed from or added to the list in Policy WM3? Yes/No; If so, please provide details.

No comment.

Question 108 - Do you agree that Policy WM4 provides an appropriate level of control over the location and design of new waste management facilities? Yes/No; If no, what changes do you think should be made to the Policy?

No comment.

Policy Area H - Minerals

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

No comment.

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

No comment.

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

No comment.

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

No comment.

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

No comment.

Question 113 - Do you think that Policy MIN2 identifies all of the key aggregate minerals issues that need to be addressed in the Core Strategy up to 2036, in accordance with national policy? Yes/No; If not, what changes should be made to the policy?

No comment.

Question 114 - Do you have evidence of workable, viable deposits of brick clays outside the areas of search, which could justify defining new areas of search? Yes/No; If yes, please provide details.

No.

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

No.

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.

No comment.

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

No comment.

Policy Area J - Growth Network Detailed Proposals

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

Updating Appendix 2 and tables 2 and 3 of the existing Core Strategy to reflect proposals in the adopted and merging SADs and AAPs is supported.

Policy Area K - Monitoring and Additional Policies

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

Streamlining the monitoring framework to focus on the key quantitative indicators which relate to the delivery of development is supported.

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

If the authorities are required to allocate Green Belt sites then a new policy for this will be needed. It is likely that a proforma will be needed for each allocation setting out what will need to be delivered on site that hooks to the policy.

Attachments:

Object

Black Country Core Strategy Issue and Option Report

Representation ID: 1318

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley

Representation:

To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3,039 dwellings against the stepped housing delivery trajectory.

Therefore a full review of the BCCS is essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs (as opposed to those identified in the now revoked WMRSS).
* All policies and objectives of the emerging BCCS Review are consistent with national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the
shortcoming of the adopted BCCS.

Full text:

Response to Questions

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF.

The adopted BCCS was published in 2011, prior to the publication of the NPPF in March 2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change in plan making.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.

2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 The adopted BCCS did not release any Green Belt land for development. In stark contrast, the emerging BCCS proposes the release of Green Belt land to deliver a minimum of 14,270 dwellings in order to meet the Black Country's needs. This represents a significant departure from the approach of the adopted BCCS.

2.5 To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3,039 dwellings against the stepped housing delivery trajectory.

2.6 Therefore a full review of the BCCS is essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs (as opposed to those identified in the now revoked WMRSS).
* All policies and objectives of the emerging BCCS Review are consistent with
national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified
needs, and one that is effective, and measurably so, when compared to the
shortcoming of the adopted BCCS.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 The evidence base currently comprises employment studies that assess strategic sites, high quality employment land and regional logistics sites. Additional employment evidence is necessary to assess the entire supply of employment land across the Black Country, including the value, demand and characteristics of the existing supply. This will be crucial to informing whether it is feasible to release employment land to deliver approx. 10,400 new homes (Strategic Option 1B which is discussed further at Q11a).

2.9 If any existing employment sites are to be proposed for allocation as residential development, the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location for residential development with appropriate supporting community infrastructure, and whether neighbouring uses would conflict with the expectations of future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's housing needs and in particular there is a need for evidence to be collated to understand gaps in social infrastructure such as education provision. To provide a robust assessment of infrastructure, public consultation should be undertaken to ensure that a full picture is provided, as residents and landowners will have information of use.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country attend schools in other authority areas, such as Birmingham and South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

2.12 It is also considered that the Black Country authorities include a robust landscape character assessment in the scoping of the evidence base document Strategic Mapping of the Black Country's Natural Environment.

Q3. Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?

2.13 The consultation on a standardised approach to the calculation of OAN is scheduled for September 2017 and, according to correspondence from DCLG (dated 31st July 2017), any Plans which have not been submitted by March 2018 (as will be the case for the BCCS Review) will be required to apply the new standardised methodology.

2.14 In terms of the SHMA, the Objectively Assessed Housing Need ('OAHN') is derived from the 2014 Sub National Household Projections which PPG confirms represents the starting point for calculating need.

2.15 We reserve the right to comment further on the OAHN once the standardised
methodology has been published, and used to calculate the Black Country's needs.

Q5. Do you agree with the proposed approach to the Black Country Green
Belt Review? If not, what additional work do you think is necessary?

2.16 We discuss the strategy to meeting housing needs in the Green Belt in response to Q12a and Q13a.

2.17 The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.

2.18 As part of this the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
2.19 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.

2.20 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.21 The nine key issues identified at Part 3 of the I&O Report represent the matters which will be integral to the BCCS Review achieving its ambitious plans for growth.

2.22 Mindful of the ambitious levels of growth proposed for the Black Country, the key issues relating to housing needs, providing infrastructure to support growth and reviewing the Green Belt, are the most important to take account through the BCCS Review.

2.23 The need to review the role and extent of the Green Belt in order to meet the housing needs of the area is strategically significant and a fundamental shift from previous policy. This of course needs to be balanced against the desire to regenerate and make best use of brownfield sites, but the scale of growth anticipated overall will require a step change in physical and social infrastructure (including highways, education and recreation provision), as recognised in paragraph 3.52 of the I&O Report.

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you suggest?

2.24 In Q1 we make the case for a full review of the BCCS. This would also necessitate a review of the vision and sustainability principles underpinning the Plan. This is particularly relevant as to date the current vision has not delivered the necessary housing growth required by the BCCS.

2.25 The adopted BCCS vision and sustainability principles reflect the area's need at that time (i.e. February 2011). Since then the NPPF has been published and the WMRSS revoked. A new vision is therefore necessary to reflect the area's needs now, which are much higher than at the time the BCCS was adopted, which is demonstrated by the admission that Green Belt land will be necessary. In contrast, no Green Belt was released by the adopted BCCS (indeed the boundaries have not been altered for over 30 years).

2.26 Furthermore, the adopted BCCS' vision is underpinned by three 'major directions of change', none of which specifically refer to meeting the Black Country's housing needs or the infrastructure to support this. The BCCS Review vision would be more robust if it was underpinned by the nine key issues set out at Part 3 of the I&O Report and made direct reference to the supply of new homes and the infrastructure required to enable the growth required over the plan period.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.27 Similarly to the BCCS' vision and sustainability principles, the spatial objectives must be reviewed to ensure they are up to date. The BCCS Review will be produced in a completely different national, regional and local planning context to that of the adopted BCCS. In particular the existing objectives will not form a sound basis to deliver the anticipated levels of growth of the Black Country, let alone the current levels proposed by the BCCS.

2.28 Meeting the emerging housing needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust and refer to the infrastructure required to support the identified growth, if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.29 We set out in response to Q1 that a full review of the BCCS is necessary given the change in the planning policy, namely the publication of the NPPF and the revocation of the WMRSS. Policies CSP1 and CSP2 therefore need to be reviewed and updated. This is particularly relevant given neither policy reflects that a proportion of the Black Country's growth needs cannot be met within the urban area (which is explicitly acknowledged at paragraph 3.17 of the I&O Report), necessitating the release of land from the Green Belt.

Q11a. Do you support Strategic Option 1A? Yes / No; If yes, please explain why. If no, do you support Option 1B? Yes / No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

2.30 There is a need for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both will require significant new land and infrastructure to support this level of growth, and this will require a different spatial strategy to the current one.

2.31 There is currently a deficit of 57 ha gross of employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality employment land. This does not distinguish between different types of employment, including different use classes and size or characterisation.

2.32 The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas. Whilst some of the businesses may not be 'friendly' to neighbouring uses, these types of units form the back bone of the Black Country economy and their loss would negatively impact business in the area. The loss would also remove local, sustainable job opportunities.

2.33 As set out in our response to Q2, further employment land supply evidence is required to achieve the right balance between protecting smaller urban sites which have numerous benefits in providing affordable space for start-up and smaller businesses, which represent a significant proportion of the Black Country economy, and the need to provide larger high quality sites to meet the needs of modern industries and new operators, and their need for better accessibility to markets. This will facilitate the redevelopment of some sites for housing, but the Black Country faces choices with an overall employment land deficit of 300 ha. It cannot simply turn all of its employment land over to housing.

2.34 The Councils should also be mindful of the viability of regenerating employment land for residential use, and whether the market can sustain viable development on these sites. This is demonstrated by the number of previously developed sites in the Black Country allocated for housing in previous plans which are yet to be delivered, and show no sign of doing so in the near future.

Q12a. Do you support Spatial Option H1? Yes / No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.35 Please refer to our response to Q13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum / maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.36 OSH support the broad Housing Spatial Option H2 - Sustainable Urban Extensions.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the requirements of the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs without breaching the principles of including land within the Green Belt, however the I&O Report acknowledges that Option H1 would not meet all of the Black Country's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Sites such as that at Racecourse Lane, will also seek to provide the infrastructure required to support the identified growth, in this case by incorporating a primary school and g irls secondary school within the masterplan for development. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met. There is advantage in having a number of SUEs located around the edge of the built up area to provide the market with choice and to ensure that houses can be delivered simultaneously in a number of different market locations.

2.42 Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore, large sites are more likely to deliver and can accommodate multiple housebuilders and market outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.43 Spatial Option H2 is therefore the most appropriate strategy for accommodating the
area's housing shortfall, however Spatial Option H1 can make a small contribution in the
right locations.
2.44 Any site selection criteria should reflect the NPPF, recognising that planning should
actively manage patterns of growth to make the fullest possible use of public transport,
walking and cycling, and focus significant development in locations which are or can be
made sustainable. Whilst a potential SUE may not be immediately adjacent to local
services or a rail station (which will be the case for the majority of the SUEs given their
location on the edge of the urban area), there is the potential to make it more
sustainable through new transport links (such as bus services) and on site provision.
2.45 Given the critical mass of SUEs, they have the potential to sustain significant on site
services. The Racecourse Lane Masterplan (enclosed at Appendix 3) demonstrates
8
how new educational facilities could be provided alongside a new residential community,
serving the needs of existing and future residents.

2.46 The BCCS Review should also not make assumptions that SUEs will have major
impacts on Green Belt purposes and environmental assets (as suggested in the
'challenges' section for Spatial Option H2). Firstly, any site's performance against Green
Belt purposes is separate to any site selection process and the NPPF makes clear that
the purpose of reviewing the Green Belt is to promote sustainable patterns of
development. SUEs can have many environmental benefits, including delivering
significant public open space, providing access to the countryside, as well as
biodiversity enhancements.
Q13b. What infrastructure do you think would be needed for different sizes
of SUEs?

2.47 It is recognised (at paragraph 6.44 of the I&O Report) that increased birth rates have
significantly increased the need for new primary school places, which is now working
through to secondary schools and is placing pressure on the school estate. Therefore,
the potential for educational facilities at Racecourse Lane will contribute towards
meeting this need, serving existing residents in the area and also providing educational
facilities to support the ambitious growth across the Black Country.

2.48 However, on a general scale for the purpose of the BCCS Review, for the reasons
provided in response to Q12a and Q13a, further evidence will be necessary to inform
infrastructure requirements for each SUE, including school and healthcare provision.
The I&O Report indicates a number of infrastructure assessments are to be undertaken
before the Preferred Options version of the BCCS Review is published. Furthermore,
the Councils should be mindful of site specific evidence bases prepared by developers.

2.49 The Black County authorities should also liaise with the relevant statutory undertakers
(such as Severn Trent and Western Power Distribution) to ensure the BCCS Review
includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?

2.50 The land at Racecourse Lane, Stourbridge, represents a unique opportunity for an
educational led development alongside a new residential community and health care
facility. OSH's aspirations are to create a new development with a 2 form mixed primary
school for circa 420 pupils, and also a 3 form girl's secondary school for circa 450 pupils
to compliment the Foundation's existing boy's school and extend its education provision
to more of the local community. The masterplan includes significant high quality open
space, parkland and green infrastructure, promoting a well-balanced and sustainable
development opportunity.

2.51 We explore the infrastructure requirements of the site further in the Call for Sites form
(Appendix 2) and Racecourse Lane Masterplan (Appendix 3) enclosed with these
representations.

2.52 Given the site's location within the Green Belt we provide an assessment against the
five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.53 The site is bounded by residential development to the north, west, east and south-east. The proposed masterplan includes the relocation of the 18-hole golf course (circa 43 hectares) to the south of Racecourse Lane and the redevelopment of the existing
Stourbridge Golf Course principally for housing. As such, the new development would
be enclosed by existing built form along three boundaries and the new golf course will
act as a boundary to the south, restricting any sprawl of the built-up area. Racecourse
Lane will provide a strong defensible boundary for the Green Belt along much of its
length.

2.54 Consequently, the release of the site from the Green Belt would not result in unrestricted sprawl of the built up area further south than Stourbridge currently extends to the south and south-west.

Purpose 2 - To prevent neighbouring towns merging into one another

2.55 The relevant purpose of the Green Belt in this location is to contain the overall
conurbation to prevent it merging with Kidderminster (the nearest large town) and to a lesser degree to prevent Stourbridge merging with Hagley (a smaller settlement only partially separated from the conurbation).

2.56 The release of the Racecourse Lane site from the Green Belt would not result in Stourbridge merging with Hagley nor of the conurbation getting any closer to Kidderminster.

2.57 As set out above, the residential development would be enclosed by Racecourse Lane to the south, acting as the firm defensible boundary.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.58 Any development on land formerly in the Green Belt will to a degree extend into areas that are currently open. The land at Racecourse Lane is principally an existing golf course bounded on three sides by existing residential areas. By relocating the golf course to the south of Racecourse Lane where it can remain in the Green Belt, the residential development and the new schools can be located so as not to extend into open countryside. There is a pronounced ridge to the south of Racecourse Lane and there will be limited long distance views from the countryside into the site, other than those which would primarily be of the new golf course.

Purpose 4 - To preserve the setting and special character of historic towns

2.59 The site is not situated within the setting of a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of
derelict and other urban land

2.60 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate a shortfall of approximately 22-25,000 new homes. It has been established even with increased densities, the Black Country has severely limited opportunities to accommodate this level of growth within the urban area and it is therefore necessary to consider Green Belt release. The ongoing recycling of derelict and other urban land will also be needed to deliver the scale of housing and employment growth needed.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?

2.61 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible to ensure the Plan is able to respond to the most up to date evidence and be in line with paragraph 173 of the NPPF.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing
infrastructure, easy access to jobs?

2.62 The NPPF is clear that local planning authorities should have fully explored all available options for delivering their housing needs within their own administrative boundaries before considering exporting growth to neighbouring authorities or the wider HMA.

Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given this exercise had not been undertaken. As such this option should only be considered as a last resort. This option would also put further pressure on infrastructure in adjoining areas, which would need to be accommodated.

2.63 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.64 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.65 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q22. Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.

2.66 Paragraph 6.44 of the I&O Report acknowledges that as a result of increased birth rates, there is a requirement for new primary school places and this is now working through to secondary schools. The existing pressure on places will only be exacerbated as the levels of growth anticipated in the Black Country's economic strategy follow through into population growth.

2.67 Paragraph 70 of the NPPF establishes that to deliver the social, recreational and cultural facilities and services the community needs, planning policies should (amongst other issues) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. Consequently, the development potential at Racecourse Lane presents a prime opportunity to meet the requirement for future education provision, in a sustainable location in close proximity to existing and proposed residential communities.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.68 Please refer to our response to Q28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical infrastructure is necessary?

2.69 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.70 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.71 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities as part of this review will be critical in establishing the existing shortfall and future requirements to support growth.

2.72 Since the BCCS was adopted, it is apparent many brownfield sites are marginally viable at best and will struggle to deliver the necessary infrastructure required (as much is acknowledged at Section 2 of the I&O Report). There will be a need for public sector intervention and funding to deliver the scale of brownfield development anticipated. Also, where markets are weaker, it should not be anticipated that greenfield development can subsidise or provide infrastructure beyond what is required to support the development itself. Whether through CIL or S106, policy must be realistic and flexible to ensure that development can come forward on the scale and at the pace required to deliver growth and meet housing need.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.73 The recently published WMCA Land Delivery Action Plan identifies sources of funding and immediate priorities. Of the £200m Land Remediation Fund, £53m is already allocated to the Black Country and a further strategic package of £97m is available to be drawn down by the LEP. However, the plan states on page 44 that "to fund the current pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding is required". This, it states, will be a key requirement of the Housing Deal the WMCA is hoping to negotiate with CLG.

2.74 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed to deliver a substantial step change in brownfield delivery. As set out in our response to Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and that it is viable for new development on brownfield sites to contribute towards providing infrastructure to meet their needs. The role of greenfield locations to deliver market housing and contribute fully to meeting infrastructure costs should therefore be a key component to derisk the BCCS housing strategy.

Q32. Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? If no, please provide details

2.75 Please refer to our response to Q34b.

Q33. Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? If yes, is a new policy needed to address such issues for example?

2.76 Please refer to our response to Q34b.

Q34a. 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?

2.77 Please refer to our response to Q34b.

Q34b. What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?

2.78 We support the strategy to incorporate health and wellbeing issues in the BCCS Review. Health and wellbeing underpin sustainable planning and creating places where people want to live.

2.79 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of integrating health and wellbeing into all policies, including those of the emerging BCCS Review. In particular, the technical note encourages the creation of communities which are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social interaction and social capital.

2.80 As such, health and wellbeing should not be standalone policies in the plan, but rather should be a 'golden thread' running through the review and all policies. Any sites promoted through the Local Plan process should demonstrate their health and wellbeing benefits if they are to be proposed for allocation.

Q35. Do you support the proposed approach to housing land supply? If no, please explain why.

2.81 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in our response to Q1 a full review of the Plan is necessary given there are now greater housing needs, the NPPF has been published and the WMRSS has been revoked, and the adopted BCCS has not been delivering the required level of growth. As such the approach to housing land supply should be reviewed in full also.

2.82 Given there is a shortfall of 3,039 dwellings against the targets set in the adopted BCCS, largely as a result of brownfield sites not being developed due to viability issues, the Review should include a 10% lapse rate applied to the requirement to ensure flexibility in deliverability should sites in the supply not come forward.

Q36. Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/ No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?

2.83 Please refer to our response to Q42.

Q40. Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/ No; If no, please explain why.

2.84 Please refer to our response to Q42.

Q42. Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? If no, please explain why.

2.85 The NPPG states that wherever possible, local needs assessments should be informed by the latest available information and the government's official population and household projections are generally updated every two years.

2.86 The affordable housing requirement; preferred housing mix; housing types; and density standards for the Black Country therefore need to remain fluid in order to respond to the most up to date evidence and market conditions. The BCCS Review should not comprise policies that set standards for the whole Plan Period. The standards set out in Policy HOU2 should be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date guidance.

Q47. Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing developments? Yes/No; If no, please explain why.

Paragraph 6.46 of the I&O Report acknowledges that Community Infrastructure Levy contributions cannot provide sufficient sums to wholly fund new education and healthcare facilities and running costs. Therefore, the proposals presented by OSH should be assessed favourably by the Councils as it promotes a suitable opportunity to provide education provision as is required across the Black Country. This proposed education provision will be situated in a sustainable location, in close proximity to existing and potential future residents.

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1371

Received: 08/09/2017

Respondent: Home Builders Federation Ltd

Representation:

The Councils should undertake a comprehensive review of the Black Country Core Strategy (adopted in 2011) because the adopted Core Strategy and its evidence base pre-date the requirements of the National Planning Policy Framework (NPPF). It may be that a wholescale review rather than partial review is necessary. The Councils should test whether or not future development needs of a growing population and economy can be met in full by merely "stretching" the existing spatial strategy. The Councils should also consider the implications of unmet housing needs across the wider Greater Birmingham & Black Country Housing Market Area (HMA) in particular from Birmingham city (circa 38,000 dwellings by 2031) as well as the Black Country unmet need of circa 22,000 by 2036. Whilst the focus on urban regeneration may remain it will not be possible to accommodate all future development needs within the urban area therefore a comprehensive review of the Green Belt will be necessary. It is expected that the Black Country Core Strategy
Review Preferred Spatial Option consultation in September 2018 will take into consideration the conclusions of the Greater Birmingham & Black Country Strategic Growth Study which on its publication (anticipated in October / November 2017) may have profound implications for the Black Country Core Strategy Review and whether or not a full or partial review is necessary. Although a two tiered Development Plan Document format is a reasonable proposal it is expected that strategic allocations will be made in the Core Strategy Review together with the setting of targets for individual authority Local Plans. The spatial objectives and strategy as well as policies should be reviewed. Some existing Core Strategy policies are now out of date and these should be superseded. The brownfield first approach is inconsistent with national policy which should not be retained in its existing form. The Councils should be encouraging the re-use of previously developed land (PDL) by maximising its re-use but should not be prioritising brownfield first. PDL is a finite resource a spatial strategy overly focussed on PDL is a high risk strategy as experienced by past delivery where no as much surplus employment land was suitable for housing development as anticipated because since 2011 the economy strengthened and local firms were more robust then envisaged and sites were more constrained than expected.

Full text:

Introduction
Thank you for consulting with the Home Builders Federation (HBF) on the above mentioned consultation. The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which includes multi-national PLC's, regional developers and small, local builders. In any one year, our members account for over 80% of all new "for sale" market housing built in England and Wales as well as a large proportion of newly built affordable housing. We would like to submit the following responses to specific questions in the Councils consultation document.
Question 1 : Do you agree that the Core Strategy Review should be a partial review retaining and stretching the existing spatial strategy and updating existing policies?
The Councils should undertake a comprehensive review of the Black Country Core Strategy (adopted in 2011) because the adopted Core Strategy and its evidence base pre-date the requirements of the National Planning Policy Framework (NPPF). It may be that a wholescale review rather than partial review is necessary. The Councils should test whether or not future development needs of a growing population and economy can be met in full by merely "stretching" the existing spatial strategy. The Councils should also consider the implications of unmet housing needs across the wider Greater Birmingham & Black Country Housing Market Area (HMA) in particular from Birmingham city (circa 38,000 dwellings by 2031) as well as the Black Country unmet need of circa 22,000 by 2036. Whilst the focus on urban regeneration may remain it will not be possible to accommodate all future development needs within the urban area therefore a comprehensive review of the Green Belt will be necessary. It is expected that the Black Country Core Strategy

Review Preferred Spatial Option consultation in September 2018 will take into consideration the conclusions of the Greater Birmingham & Black Country Strategic Growth Study which on its publication (anticipated in October / November 2017) may have profound implications for the Black Country Core Strategy Review and whether or not a full or partial review is necessary. Although a two tiered Development Plan Document format is a reasonable proposal it is expected that strategic allocations will be made in the Core Strategy Review together with the setting of targets for individual authority Local Plans. The spatial objectives and strategy as well as policies should be reviewed. Some existing Core Strategy policies are now out of date and these should be superseded. The brownfield first approach is inconsistent with national policy which should not be retained in its existing form. The Councils should be encouraging the re-use of previously developed land (PDL) by maximising its re-use but should not be prioritising brownfield first. PDL is a finite resource a spatial strategy overly focussed on PDL is a high risk strategy as experienced by past delivery where no as much surplus employment land was suitable for housing development as anticipated because since 2011 the economy strengthened and local firms were more robust then envisaged and sites were more constrained than expected.
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?
It is agreed that previously used evidence is old and out of date. The Core Strategy Review should be prepared using new up to date evidence. The key evidence outlined in Table 1 is a reasonable list of evidence. It is important that there is commonality between timeframes of key evidence and the proposed plan period of 2014 - 2036. Furthermore evidence on compliance with the Duty to Co-operate should be included as key evidence.
Question 3 : Do you agree that the housing need identified in the Black Country over the period 2014 - 2036 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance?
The key issue is that the Black Country Core Strategy Review makes provision for the meeting in full of the housing needs of the sub region. The Councils should also have due regard to the proposals in the Housing White Paper for a standard methodology for Objectively Assessed Housing Needs (OAHN) calculation and the housing delivery test. The DCLG Planning Update Newsletter dated 31st July 2017 confirms that if a Plan is submitted for examination on or before 31st March 2018 the Plan may progress using the existing methodology for OAHN as set out in current guidance. However if that Plan is withdrawn from examination or found unsound the new Local Plan would be prepared using the standardised methodology.
The OAHN for the Black Country of 78,190 dwellings (including a notional figure of 3,000 dwellings for unmet needs between 2011 - 2014) for the plan period 2014 - 2036 is set out in the Black Country & South Staffordshire Strategic Housing Market Assessment (SHMA) Final Report dated March 2017 by Peter Brett Associates (PBA) which supersedes the OAHN set out in Greater Birmingham & Solihull Local Enterprise Partnership & Black Country

Local Authorities Strategic Housing Needs Study Stage 3 Report by PBA dated August 2015. The OAHN calculation is based on 2014 SNPP / SNHP with no further adjustments for market signals or economic growth. There is also no proposed uplift to the housing requirement above OAHN to help deliver more affordable housing. It is noted that the OAHN / housing requirement figures have not yet been tested at any Local Plan Examination. Whilst the demographic starting point may be reasonable the lack of adjustments for market signals, economic growth and affordable housing delivery may be contested at Examination. Furthermore the OAHN calculation is likely to be re-worked in line with the Government's proposals for a standard methodology before the Black Country Core Strategy Review is examined. The proposed figures also exclude any unmet needs from Birmingham although it is proposed to test a notional figure for the city's unmet needs of 3,000 dwellings. However there is no evidence to justify this proposed notional figure.
The strategic allocations of the Black Country Core Strategy Review together with non-strategic allocations in Local Plans should meet housing needs in full over the plan period. The desire to regenerate brownfield land should be balanced with meeting development needs. The remaining brownfield capacity does not necessarily exist in the locations with highest housing needs and encouraging housing redevelopment should not erode the existing supply of employment sites. Furthermore the restricting of greenfield opportunities will not make unviable brownfield sites become viable. Currently the Black Country is under performing by 3,000 dwellings against the adopted Core Strategy housing target. The residual Housing Land Supply (HLS) figure of circa 21,670 (or 24,670 including notional 3,000 dwellings of unmet need from Birmingham) dwellings should be met from a mixture of HLS including brownfield, greenfield and Green Belt land releases where appropriate. It is also likely that the residual HLS figure is greater than stated by the Councils as the 10,400 dwellings proposed on currently occupied employment land have viability funding gaps which are not yet resolved (see answer to Q10 below).
The Black Country Core Strategy Review should provide a contingency in the overall HLS. The planning in of some additional flexibility is necessary because not all land is developed and Sustainable Urban Extensions (SUEs) are developed over long periods of time often extending beyond plan periods. The development criteria for SUEs should be set out in the Core Strategy Review. The HBF always recommends as large a contingency as possible (circa at least 20%) to the overall HLS to provide sufficient flexibility to respond rapidly to changing circumstances and in acknowledgement that the housing requirement is a minimum not a maximum figure.
Question 4 : Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance?
Housing and economic strategies should be fully integrated and aligned. There is a large discrepancy between OAHN / housing requirements in adopted and emerging Local Plans and number of homes needed to support

jobs targets such as the West Midlands Combined Authority (WMCA) Strategic Economic Plan (SEP) which by 2030 forecasts 49,000 jobs above the combined existing targets of the 3 Local Enterprise Partnerships (LEPs) SEPs in the West Midlands and potentially generates 48,000 more dwellings compared to previous OAHN calculations. If housing and economic strategies and spatial planning remain un-co-ordinated then economic growth potential will remain unfulfilled.
Question 5 : Do you agree with the proposed approach to the Black Country Green Belt Review?
It is agreed that the formal review of the Green Belt and any subsequent release of sites including the allocation of specific strategic sites for development by 2036 should be part of the Core Strategy Review. The proposed Green Belt Review should be undertaken at a strategic level and used to inform the review of Green Belt boundaries and the "exceptional circumstances" test for Green Belt release as part of the Core Strategy Review. A rolling back of the Green Belt could be pursued so there is no net loss but long term growth is not stifled. It is appropriate to include South Staffordshire.
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?
The key issues are as set out in Part 3 which should be taken into account in the Core Strategy Review.
Question 7 : Do you think that the Core Strategy vision and sustainability principles remain appropriate?
The Core Strategy vision and sustainability principle of "putting brownfield first" is no longer appropriate (also see answer to Q1).
Question 8 : Do you think that the Core Strategy spatial objectives remain appropriate?
The spatial objectives of the Core Strategy should be reviewed in the context of both a growing population and economy and the meeting of these needs in full. As set out in the consultation document Policies CSP1 - CSP5 will be subject to changes.
Question 9 : Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network?
Policies CSP1 & 2 should be updated to reflect growth proposals beyond the Growth Network.

Question 10 : In continuing to promote growth within the Growth Network is there a need to amend the boundaries of the Growth Corridors in the existing Core Strategy?
The existing boundaries of the Growth Corridors should be amended to promote future growth within the Growth Network. However it is known that many large allocated housing sites within the Growth Network have development constraints and financial assistance will be necessary to bring these sites forward. It is understood that 300 hectares of occupied employment land allocated for housing (10,400 dwellings) in the adopted Core Strategy have viability issues associated with land assembly, business re-location and land remediation which despite external funding from the Black Country LEP and WMCA will remain insufficient to cover costs of compulsory purchase to ensure delivery by 2026.
Question 11A : Do you support Strategic Option 1A? Do you support Strategic option 1B?
The current focus for housing growth is within the urban area however this strategy alone will not meet OAHN in full in the future so development in other locations will also be needed. There are also risks associated with an over reliance on brownfield sites within the urban area (see answer to Q.10 above concerning viability of sites). The artificial constraint of housing on greenfield sites will not ensure delivery of unviable brownfield sites. It should also be acknowledged that the availability of brownfield land will decline over time as it is a finite resource. Therefore it is the HBFs opinion that all options should be considered. The most appropriate solution is likely to be a combination of the continuing promotion of growth within the Growth Networks and Growth Corridors together with Options 1A, 1B, H1 and H2.
A broad portfolio of sites will maximise housing delivery and ensure that the Black Country Core Strategy is positively prepared, justified and effective. Therefore large strategic sites should be complimented with smaller scale non-strategic sites. When allocating sites the widest possible range of sites, by size and market location are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. The maximum delivery is achieved not just because there are more sales outlets but because the widest possible range of products and locations are available to meet the widest possible range of demand. The Housing White Paper also emphasises the importance of a wide range of sites because a good mix of sites provides choice for consumers, allows places to grow in sustainable ways and creates opportunities to diversify the construction sector.
Question 12A : Do you support Strategic Option H1?
See answer to Q11A above.
Question 13A : Do you support Strategic Option H2?

See answer to Q11A above.
Question 14 : Do you think there are any other deliverable and sustainable Housing Spatial Options?
See answer to Q11A above.
Question 15 : If all housing need cannot be met within the Black Country do you support the export of housing growth to neighbouring authorities within the HMA?
The Black Country Core Strategy Review should fulfil the objectives of the Government's Housing White Paper to plan for the right homes in the right places in particular making enough land available to meet assessed housing requirements. It is the HBF's opinion that housing needs should be met where those needs arises if this is not possible then there should be a bigger than local approach involving cross boundary collaboration throughout the wider HMA so the distribution of housing needs is led by a strategic planning process. The Greater Birmingham & Black Country Strategic Growth Study will be a critical piece of evidence which by identifying potential locations will provide important evidence to inform the land use allocations of each of the 14 constituent HMA authorities when preparing Local Plans including the Black Country Core Strategy Review. The West Midlands Combined Authority's proposal for a Land Delivery Action Plan will also commit its constituent and non-constituent authorities to joint action to accelerate the delivery of housing and employment in order to provide enough homes and jobs for people in all the communities of the West Midlands. This commitment will ensure appropriate provision is made within Greater Birmingham & Black Country HMA to accommodate Birmingham's shortfall of circa 38,000 dwellings to 2031 and unmet needs of 22,000 dwellings to 2036 in the Black Country. It is noted that non-constituent authorities such as Telford & Wrekin which is outside the Greater Birmingham & Black Country HMA will also be bound by this commitment indeed the main modifications to the Telford & Wrekin Local Plan identify the potential to contribute to meeting unmet needs (not yet quantified in evidence).
Question 21 : Do you think changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?
Policy DEL1 should be updated in the Core Strategy Review
Question 34A : Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Options stage of the Core Strategy Review through a Health Impact Assessment approach?
The Councils should be working with public health organisations to understand and improve the health and well-being of the local population (para 171 NPPF). The requirement for Health Impact Assessments should be justified on evidence.

Question 35 : Do you support the approach to HLS?
It is agreed that Policy HOU1 should be updated and based on the latest housing requirement figure. It is also agreed that a re-distribution of development should be included and the proportion of development built on previously developed land will change however the prioritising of brownfield first should not continue (see answers to Q1, Q3 and Q11A above). Any proposed reductions to lapse rates / non-implementation allowances should be justified by evidence. Any inclusion of a windfall allowance in the 5 YHLS calculation should be in the latter years to avoid double counting. The proposal to increase high density housing allocations should be treated with extreme caution (see answer to Q36 below).
Question 36 : Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed?
The Councils have already identified that there is no appetite for high density development so a cautious approach should be applied when considering any proposed changes to density standards.
Any proposed changes to the current accessibility standards should only be undertaken using the criteria set out in the NPPG.
Question 37 : Do you think that existing Policy HOU2 site size threshold should be kept at 15 homes or more?
It is known that site viability in the Black Country is particularly challenging 25% of the HLS is not viable under current market conditions. The Councils viability evidence should be updated as part of the Core Strategy Review. Any proposed change to site size thresholds should only be considered on the basis of updated viability evidence.
Question 38 : Do you think that the current accessibility and density standards are appropriate for green belt release locations?
The application of accessibility and density standards for green belt release sites should be based on evidence.
Question 39 : Do you think separate accessibility standards are needed for particular types of housing?
If the Councils wish to apply accessibility standards these should only be adopted using the criteria set out in the NPPG.
Question 40 : Do you agree that the 2017 SHMA finding should be used to set general house type targets for the plan period?
The setting of any house type targets should not be overly prescriptive. Any such targets should be flexible enough to allow variations over time and for differing local circumstances.

Question 41A : Do you support the introduction of a policy approach towards self and custom build in the Core Strategy?
The HBF is supportive of self-build for its additionality to housing supply. However this is not considered a strategic matter which requires the introduction of a new policy approach in the Core Strategy Review. The existence of only 9 entries on the Councils self / custom build register provides insufficient evidence of need to justify a policy in the Core Strategy Review.
Question 41B : A target for each authority?
No.
Question 41C : A requirement for large housing sites to provide serviced plots?
The HBF is less supportive of a housing mix approach whereby a requirement to provide a proportion of self / custom build plots is imposed on sites above a certain size. Such a policy approach only changes the house building delivery mechanism from one form of house building company to another without any consequential additional contribution to boosting housing supply. If these self-build plots are not developed in a timely manner or remain undeveloped then the Councils have effectively caused an unnecessary delay to the delivery of these homes or removed them from the HLS. Therefore appropriate release mechanisms are essential. The Councils should also give detailed consideration to the practicalities (for example health & safety implications, working hours, length of build programme, etc.) of implementing any such housing mix policy approach. It is considered inappropriate for large sites to provide serviced plots.
Question 41D : Another approach altogether?
The HBF is supportive of a positive development management policy approach to self / custom build planning applications combined with allocation of a proportion of small sized sites, land allocation on Council owned sites and exception sites. Therefore the Councils should encourage self / custom build via the aforementioned approaches.
Question 42 : Do you agree that the annual affordable housing target should be increased to reflect the 2017 SHMA?
The annual affordable housing target should be the most up to figure identified in the Councils latest evidence.
Question 43 : Do you think that existing Policy HOU2 site size threshold should be kept at 15 homes or more?
The site size threshold should be justified by viability evidence. It is unlikely that an alternative threshold of less than 15 dwellings could be justified.

Question 44A : Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site?
The Councils viability evidence should be updated to confirm that 25% remains viable. It is understood that 25% of the HLS is unviable under current market conditions. The Updated viability evidence should include robust testing of PDL, greenfield sites and SUEs. The Councils are reminded that development should not be over-burdened the policy requirement should not be set so high that viability negotiations are undertaken routinely rather than occasionally.
Question 44B : If no should the percentage be increased to allow for the provision of affordable homeownership?
The overall percentage should not be increased. The affordable tenure mix should be flexible to incorporate the provision of affordable homeownership products.
Question 45 : Should an increase in affordable housing requirement be set for green belt release sites to reflect the likely financial viability of these sites?
The setting of affordable housing targets should be based on robust viability testing of all sites including previously developed land and greenfield.
Question 55 : Do you agree with the proposal to retain Policy EMP5?
HBF disagree with the proposal to retain Policy EMP5.
Question 98 : Do you support the proposed changes relating to design quality?
The reference to Code for Sustainable Homes in Policy ENV3 is out of date. Policy ENV3 should be updated.
Question 99A : Do you think that the national standards for housing developments on water consumption should be introduced in the Black Country?
The adoption of optional higher water efficiency standard should only be applied using the criteria set out in the NPPG (ID 56-013 to 56-017). The Black Country has not been identified as a water stress area in an up to date Water Cycle Study.
Question 99B : Do you think that the national access standards for housing development should be introduced in the Black Country?
No. National accessibility standards should only be introduced in accordance with the criteria set out in the NPPG.

Question 99C : Do you think that the national space standard for
housing development should be introduced in the Black Country?
The nationally described space standard should only be introduced in
accordance with the criteria set out in the NPPG (ID: 56-020).
Question 99D : Do you think the standards should be different for
brownfield and greenfield sites?
No. It is not relevant to whether site is brown or green field.
Question 118 : Do you agree with proposals to streamline and simplify
the Core Strategy Monitoring framework?
The plan making process in the Black Country should be improved. The
existing adopted Core Strategy is over-due for review and second tier Local
Plans are still not yet in place six years after adoption of the Core Strategy.
Any streamlining and simplification of the monitoring framework should
incorporate more effective monitoring mechanisms such as key performance
indicators. Currently the Councils are underperforming by 3,000 dwellings
against adopted Core Strategy housing targets without triggering any positive
policy response.
Appendix B and C - housing trajectories
The housing trajectories in Appendix B and C should be up dated in the Core
Strategy Review.
Conclusion
It is hoped that these responses are helpful in informing the next stages of the
Black Country Core Strategy Review.