The local Greenbelt in Halesowen is of historic value as the Abbey is there. It is also an area of natural beauty with views on public paths towards clent hills. It also acts as a buffer against the noise and pollution caused by the nearby M5 junction. It should not even be in the core strategy and definately not built on. Over all the Greenbelt in the Black Country should stay and act as a buffer against urban sprawl. The figures for the estimated numbers of houses needed I believe are an over estimate.

Greenbelt should be sacrosanct. I don't believe that it is necessary to build on greenbelt as there is enough derelict land and disused housing elsewhere. Once built on it is lost forever. It will also have a huge impact on our wildlife. If it becomes necessary to look at greenbelt then we need to look at ways to reduce our population by reducing the number of children born to each couple and the number of people we allow into our country.

Previous assessments have been shown to underestimate the requirement for housing and therefore clearly need reassessing.

I don't feel that using areas of green belt is worth the benefit of providing additional space for housing/business when there are alternative spaces available.

a) There are numerous derelict or brownfield sites available in the Black Country area. In Halesowen, there are a numer of disused shops, warehouses with significant areas of empty space, and dilapidated homes which could be repurposed.

b) Rather than using land immediately adjacent to urban areas, it seems best to invest in creating new, self-contained village communities further out from the urban perimeter. This is less harmful to existing communities.

Every possible opportunity for using urban space should be explored before considering any use or green belt or green space

Additional work to explore all urban opportunities should be made

A review is helpful.

However, the remit should be such that the objective is not to reduce the green belt, but to extend where possible.
Without sufficient green space, our biodiversity of the planet, carbon storage facilities and land for leisure etc will slowly erode.

Planning for housing should consider the wider health benefits of access to existing natural environments. More detailed consideration of specific local areas is also needed rather than broad multi-authority strategy proposals.

The Review of the Green Belt is fundamental to meet housing need and demand stemming from the Review. It is essential that this review fully tests the capacity to accommodate BC housing need in the BC though the review of the Green Wedges and existing areas of Green Belt in the the BC before Green Belt in South Staffordshire
Equally there are opportunities n South Staffordshire to accommodate housing beyond the Green Belt at Penkridge the norther edge of which is not Green Belt.

A review of the green belt is supported.

I think there are low quality green(ish) zones that could be developed if they are in exactly the right place. in my ward whateley field is a green belt area ( Blakenall) but should be developed for housing as is plagued by ASB.
Access to the proposed expansion to the severn trent sewerage plant should not be via Goscote Lodge crescent in Blakenall where large new residential site proposed.. should be via a new access via Slacky lane

Unless a Green Belt Review is undertaken in a manner which articulates and targets a sustainable development pattern based upon a rigorous analysis of the contribution of the different parts of the Green Belt to the aims of Green Belt policy then there is a risk of an unsatisfactory leapfrogging of growth beyond its generating source. This will represent inappropriate strategic planning

In general terms the proposed approach follows both national policy and the approach set out in the 2017 Housing White Paper. However, we are concerned on two points.

Firstly, the review should address whether the changes to the green belt that would be required are such that they would restrain the ability of both the Black Country Authorities and the neighbouring authorities to meet the full extent of the assessed housing need. DCLG has recognised this as a possibility in its October 2014 statement, "Councils must protect our precious Green Belt land". This statement has been incorporated into National Planning Practice Guidance (ID 3-045-20141006, https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment) and is reiterated in the House of Commons Briefing Paper 'Green Belt' published in January 2016 (http://researchbriefings.parliament.uk/ResearchBriefing/Summary/SN00934)

Secondly, the review should integrate consideration of compensatory improvements to the environmental quality or accessibility of remaining Green Belt land that should be associated with the release of Green Belt land for development, as set out in paragraph 1.39 of the Housing White Paper.

The evidence on the need for use of the green belt is not there particularly for housing extensions or employment use which are not sustainable (not in served corridors).

Given the HMA -wide shortfall in hosing land supply and one of the most important objectives of any local plan is to ensure that it identifies sufficient land for housing, and that there has not be a strategic Green Belt review since the 1970s, it is essential that the Black Country Green Belt review is carried out in conjunction with South Staffordshire Council.

We welcome an evidence based review of greenbelt function but urge you to extend this across all of the Black Country, not just greenbelt. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife, geodiversity and people as some greenbelt sites. We would like to refer you to the Wildlife and Countryside Link guidance on Permission in Principal and Brownfield Registers of land for further information on this.
The Wildlife Trust can provide advice on conducting such a study.

LCP agree that a Green Belt review should be undertaken as part of the preparation of the Black Country Core Strategy. A Green Belt review will enable consideration to be given to the identification of the most sustainable sites for future development proposals.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

We welcome an evidence based review of greenbelt function but urge you to extend this across all of the Black Country, not just greenbelt. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife, geodiversity and people as some greenbelt sites.

In line with guidelines in the NPPF, Planning practice guidance 2016 and Town&Country Planning Regulations 2012, the LNP can advise on conducting such a study. For Garden City aspirations to materialise, brownfield sites should be enhanced for nature conservation and quality of life values.

We agree that the evidence clearly demonstrates that a Green Belt review is needed to meet the development needs identified and that this is an essential component of the new Core Strategy.

However, it is also our view that the Green Belt review should extend beyond the current plan period in accordance with the Framework, which explains that when undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. In this context, it is highly likely that the need for housing and employment land will continue to grow and that capacity in the urban area will not exist to meet these needs. Consequently, safeguarded sites will also need to be identified. It is our view that the period up to 2051 should be considered. This is 15 years beyond the end of the existing plan period and links to the time period that local authorities are required to identified a supply of sites for (Paragraph 47).

Whilst the Green Belt review might be undertaken by the BCAs and South Staffordshire, it is important that the review is not just confined to their administrative area. Other authorities also directly adjoining the BCAs and an understanding of the function of the green belt along these boundaries is also important so that all the options available to deliver the housing need are considered.

We agree that a review of the Green Belt review is an imperative element of the new Core Strategy. As referred to above, it is our view that the Green Belt review should be prioritised so it is prepared in good time to inform the Preferred Options Consultation Core Strategy that is expected to be published in September 2018. The extent of the Green Belt review should be wide reaching. The Green Belt review should not just be focused on Green Belt land within the Black Country and immediately adjacent to it. A wide range of housing sites in a variety of locations within the HMA will be required to meet the significant housing shortfall identified by the emerging plan. The Green Belt review should examine the role that the Green Belt plays around the principle settlements within the HMA. In this regard we fully support the recognition that the Green Belt review should explore potential sites suitable for Green Belt land release within South Staffordshire. This should include the land surrounding the South Staffordshire's main settlements.

It is also our view that the Green Belt review should extend beyond the current plan period. Paragraph 83 of the Framework advises that once established Green Belt boundaries should only be altered in exceptional circumstances. When undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. When defining boundaries, Local Planning Authorities should, where necessary, identify areas of safeguarded land between the urban area and the Green Belt in order to meet long term development needs.

It is unlikely that significant new urban capacity will be found in the Black Country going ahead. Subsequent versions of the BCCS are likely to have to continue to rely upon Green Belt land release to meet the overall housing requirement. The Green Belt review and emerging plan should, therefore, look to identify land that can be removed from the Green Belt and safeguarded for development to meet development needs beyond the current plan period.

Dear Sirs

RE: Black Country Core Strategy-Issues and Options Report (June 2017)
We represent the West Midlands HARP Planning Consortium which includes all the leading Housing Associations Registered Providers (HARPs) across the West Midlands. Our clients' principal concerns are to optimise the provision of social/affordable housing and to ensure the evolution and preparation of consistent policies throughout the region.

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review?

In the context of a limited supply of brownfield and other opportunities within the existing Black Country Core Strategy area to accommodate substantial housing development we welcome the proposal to release some land from the Green Belt. By undertaking a thorough review of Green Belt opportunities and constraints the Council will be meeting the NPPF requirement to promote sustainable patterns of development.

Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy?

Should the Council introduce a policy approach towards self and custom build housing, any requirement should not be in place of traditional affordable housing requirements. Self and custom build has complex requirements for funding and as such is out of the reach of most households who seek affordable housing. Self and custom build is also not within the affordable housing definition of the NPPF. Any policy requirement should be fully tested in terms of its viability when assessed alongside all other policy requirements to ensure that any requirement will not result in affordable housing being reduced on viability grounds.

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.

Paragraph 158 of the National Planning Policy Framework (NPPF) requires local planning authorities Local Plan to be based upon adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics of the area. The Council's own evidence document, the Strategic Housing Market Assessment Part 2-Objectively Assessed Need for Affordable Housing (June 2017) (SHMA) states that the authority should aim for 28.6% of new housing to be affordable housing (this figure includes starter homes).

Paragraph 47 of the NPPF clearly sets out the Government's aim to "boost significantly the supply of housing". To achieve higher housing supply local authorities should:

"use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area".
There is a wealth of evidence to demonstrate that there is a national housing crisis in the UK affecting many millions of people who are unable to access suitable accommodation to meet their housing needs.

Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing?

With regards to Question 49a, we would encourage the Council to consider the wording of paragraph 22 of the NPPF which asserts that:

"Planning 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. Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities."

Employment land has not been designated in perpetuity so if suitable and more practical uses are available we suggest that the Council takes this into consideration, via a more flexible policy; this will ensure that the Local Plan is in accordance with national policy and therefore passes the tests it will be assessed against in order to be found 'sound' at the eventual examination.

Other comments

The SHMA is clear on the increase in need for all tenures, of all sizes. In translating these needs into suitable policies the Council should look to involve Housing Associations as far as possible in setting a local definition of affordable housing that will encourage delivery of all affordable housing types. As the presumption should always be in favour of on-site affordable housing delivery, the preference for early engagement with local Housing Associations should be emphasised in the Plan policies.

The Council's SHMA highlighted a need for 162 new sheltered and extra care homes every year to meet the needs of the ageing population however there is no policy on older peoples housing within the document. We are of the opinion that a separate policy is needed to fully represent the needs of housing and care for older people.

Example policy wording is:

"Care, Continuing Care Retirement Communities and Extra Care Housing
The Council will, through the identification of sites and/or granting of planning consents, provide for the development of residential care homes, nursing homes, close care, extra care and assisted care housing, and Continuing Care Retirement Communities which encompass an integrated range of such provision.
In identifying sites and/or determining planning applications, regard will be had to:
* Commission for Social Care Inspection and other operational requirements;
* Locational sustainability. Suitable sites at defined settlements will be prioritised, but where such sites are not available regard will be had to the availability of public transport and the potential for developments to be self-contained, thereby reducing travel requirements;
* The potential to co-locate a nursing/residential care home and other care related accommodation on the site where there are demonstrated needs.
The Council will also work with its partners Dudley Metropolitan Borough Council, Sandwell Metropolitan Council, Walsall Council and the City of Wolverhampton Council and the relevant Primary Care Trusts in identifying suitable sites and securing the provision of schemes."

The above comments are intended to be constructive, to ensure the Local Plan is sound. We would like to be consulted on further stages of this document and other publications by the Council, by email only to consultation@tetlow-king.co.uk; please ensure that the West Midland HARP Planning Consortium are retained on the consultation database, with Tetlow King Planning listed as their agents.

We agree that a review of the Green Belt review is an imperative element of the new Core Strategy. As referred to above, it is our view that the Green Belt review should be prioritised so it is prepared in good time to inform the Preferred Options Consultation Core Strategy that is expected to be published in September 2018. The extent of the Green Belt review should be wide reaching. The Green Belt review should not just be focused on Green Belt land within the Black Country and immediately adjacent to it. A wide range of housing sites in a variety of locations within the HMA will be required to meet the significant housing shortfall identified by the emerging plan. The Green Belt review should examine the role that the Green Belt plays around the principle settlements within the HMA. In this regard we fully support the recognition that the Green Belt review should explore potential sites suitable for Green Belt land release within South Staffordshire. This should include the land surrounding the South Staffordshire's main settlements.

It is also our view that the Green Belt review should extend beyond the current plan period. Paragraph 83 of the Framework advises that once established Green Belt boundaries should only be altered in exceptional circumstances. When undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. When defining boundaries, Local Planning Authorities should, where necessary, identify areas of safeguarded land between the urban area and the Green Belt in order to meet long term development needs.

It is unlikely that significant new urban capacity will be found in the Black Country going ahead. Subsequent versions of the BCCS are likely to have to continue to rely upon Green Belt land release to meet the overall housing requirement. The Green Belt review and emerging plan should, therefore, look to identify land that can be removed from the Green Belt and safeguarded for development to meet development needs beyond the current plan period.

Projections of employment and population and hence housing needs all pre-date Brexit. There should be no review of Green Belt until there has been time to assess better the impact on the local economy - not less than five years. The 2015 Greater Birmingham and Black Country Strategic Housing Needs Study was based on assumptions and projections that should be revisited before accepting its now dated conclusions. Any removal of restriction on Green Belt development prior to its absolute necessity will undermine continuing development of brown field sites, with their necessarily higher than Green Belt financial costs.

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.

I am very concerned about this threat to the Halesowen Green Belt. I came to Halesowen in 1978 to work as a junior doctor at the General Hospital in Birmingham. I was born and bred in Greater London and remember very well going to view the house we now live in on Priory Road off Manor Lane. Two things really impressed me about this house. The beautiful natural back garden with lovely mature trees and shrubs, an oak tree in the front garden and then driving down Manor Lane and as you went down the hill the beautiful vista of open country greeted your gaze, with the Clent Hills in the near distance. Too many times I had to turn left for work rather than head for that open country which was so inspiring and uplifting. I knew my wife would love it and brought her to see it and she was enthralled and we have been ever since. I subsequently got a Consultant job at City Hospital where I worked for many years.

Man is not a natural urban dweller. He originated in the forests and the countryside. Urbanisation has had many downsides. It is vital that the confinement of urban living is relieved by access to the green and pleasant land that most of us love so well. We need to be the guardians of the very precious Green Belt. it is where we go to breathe less polluted air, to exercise, to relax and make ourselves whole again. It is very tempting to nibble away at this asset but that would start us on the road to ruin. The introduction of the concept of the Green Belt was a thoroughly brilliant inspirational idea. Those introducing it had vision and foresight. It is one of the UKs treasures along with our National Parks and the Coastal Path. If we create a precedent and start invading it, a chain reaction of further development is a distinct possibility until the land is covered with concrete.

From talking to neighbours and friends I know my view is widely held. Yes we need more homes but land that is not green belt needs to be utilised to the fullest extent. There is also concern about the haphazard so-called consultation ending on the 8th September. People should have been informed about this by a leaflet through every door of every resident in Halesowen. This should have set out what the consultation was about, where and who could answer questions with contact numbers and e-mail addresses. All people have had is the front page of a Halesowen News giving a very rough idea on what is happening. Not everybody can access the Internet and the Dudley website is not particularly user friendly. Some folk found a questionnaire and they have complained to me that the whole thing seemed biased with one question making it difficult to express an opposing view.

In summary the Green belt was established for a noble purpose and it becomes more important to our society every day that passes. My wife and I feel it should be sacrosanct and fully respected. We are totally opposed to any prospect of its development.

With kind regards, Ken and Gwen Taylor. 1,Priory Road.

Dear Sir or Madam

I write regarding the proposed Review of the Black Country Core Strategy 2017 as I strongly object to to Housing and Industrial Development in the Green Belt.

I oppose all development on designated Green Belt land, but my experience, and intimate knowledge, relates primarily to the Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'.

You do not ask for a detailed representation, but I list some pertinent issues:

1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.

2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.

3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.

4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.

6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.

7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.

8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

Will you please record my objection and reply to acknowledge safe receipt?

Please keep me informed of progress and of future stages.


Yours Faithfully,


S. Beaumont

Halesowen, B63

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)

Our primary concern is ensuring that the Local Plan is informed by appropriate evidence and that where higher levels of growth are identified and policies and sites proposed, that these are informed by up to date and proportionate evidence. Table 1 on page 18 details the range of evidence base and which areas may need updating. Unfortunately, there is no reference to any historic environment evidence base within this table. What evidence base do the Council's have? Does it need updating? Are there areas missing? If sites are proposed through the Black Country Core Strategy review then we would expect a heritage impact assessment to be undertaken, or similar.

I attach a link below to some relevant advice notes to assist in the preparation of the Black Country Core Strategy Review:

Conservation Principles -

https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/

Good Practice Advice Notes -

https://historicengland.org.uk/advice/planning/planning-system/

Site Allocations Advice Note -

https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/

Page 29 looks at the issue of a Green Belt Review and we would want to ensure that the historic towns purpose of the Green Belt is fully considered.

We would support the inclusion of a specific spatial objective for the historic environment.

Where growth is considered and there are options for amending boundaries to regeneration corridors, creating new sustainable urban extensions, allocating development sites, we would need to ensure that appropriate assessment has been undertaken on how this growth will impact the significance of heritage assets, including their setting. Please see advice notes above and also access Historic England's website for further information.

Question 16 raises the idea of what criteria to consider when choosing sites for development - we would request that the Council's consider what the impacts are for the historic environment and consider sites where there is no negative impact or impacts can be mitigated. There are also opportunities for development to positively enhance and better reveal the significance of heritage assets and we would also request that these opportunities are considered. This point is relevant for all types of development.

We would be happy to offer advice and comment on any proposals to amend Policy ENV2 on the historic environment and we are supportive of the policy being updated in line with national policy and guidance.

Page 66 raises the issue of building density and the need to look at increased density. As a result we would be keen to ensure that the Council's have appropriate design and building heights policies to ensure that there are specific policies to deal with issues that may arise because of increased density of sites.

Where sites are identified for Gypsy, Traveller and Travelling Showpeople, alongside other forms of development, we would expect these to be fully assessed against the potential negative impacts for the historic environment.

Where transport initiatives are proposed we would recommend that these are considered against the impact to the historic environment and that relevant avoidance, mitigation and enhancement measures are included within the Core Strategy.

We are content with the proposed amendment to Policy ENV2. We would recommend that a section is included on Heritage Statements and when they are required.

Historic England is currently preparing some additional advice on preparing minerals plans and the historic environment. We would recommend that the Council's consider all appropriate evidence base to ensure that the proposals are appropriate and compliant with the National Planning Policy Framework. Historic England does also have access to a number of studies that have looked at archaeology and aggregate minerals and we would be happy to share the relevant evidence with you