Black Country Core Strategy Issue and Option Report

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Object

Black Country Core Strategy Issue and Option Report

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

Representation ID: 1926

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Consider that a full review should be undertaken. The respondent support the housing and employment growth which emphasises on regeneration, however consider that this approach has failed due to reasons relating to ownership, viability, market perceptions and suitability etc.
The CS approach is based on the revoked West Midlands Regional Spatial Strategy and was produced before the NPPF materialised. The Black Country needs to respond to the significant shift that has occurred in terms of amount of housing and employment land. Due to the different economic climate the respondent's consider that a new approach is needed for the Core Strategy review.
The adopted Core Strategy seeks to deliver the majority of the housing and employment through a "Growth Network" focussed on Regeneration Corridors. However section 2.5 -2.11 consider that the level of concentration in the growth corridors is "less than expected". This is due to the fact that more windfall sites will come forward than expected out of the Growth Corridor.
Appendix C-Black Country Monitoring Summary advises that there is currently a shortfall of 3,039 dwellings in the Black Country to meet the housing requirement for the plan period.
The Growth Network and Regeneration Corridor approach in the Core Strategy is based on the delivery of significant amount of housing on the employment land. However paragraph 2.5 of the emerging document considers that there is not much surplus land suitable for housing. This could be due to the improvements in the economy or sites being constrained due to various factors.
The current approach in the Core Strategy to provide new residential development on poor quality employment land will not deliver the housing numbers required.
The new evidence suggest that significant amount of additional employment land will be needed. Therefore the emerging Core Strategy should not rely heavily on employment land for the delivery of housing numbers.
The trajectory of the current plan will not be met due to its reliance on windfall sites, some of which may not suit market requirements or subject to contribution and viability problems.
A new Strategy is needed which provides opportunities on brownfield and greenfield (Green Belt) to enable housing delivery whilst being attractive to the market.
A portfolio of new strategic sites accommodation 150-500 units should be identified in the emerging Strategy which are more likely to be delivered. The respondent has suggested an opportunity for a major mixed use urban to the south west of Junction 3 of the M5.
The identification of the range of sites will ensure adequate supply and will avoid reliance on major urban extensions which may have constraints in terms of funding and delivery.
A more realistic approach needs to be considered for sites coming forward and a "non implementation" rate needs to be identified with respect to windfall element of housing delivery. This is because the review acknowledges the problems associated with bringing the brownfield sites forward.

The Strategy needs to have discussions with neighbouring authorities i.e. South Staffordshire, Wyre Forest and Bromsgrove and others which share functional and geographical linkages.
The Green Belt release should be considered at early stages of the plan process to ensure that a mix of sites is made available to meet the market needs. This will not only help with the early delivery of sites but will also ensure five housing supply in accordance with paragraph 47 of the NPPF. This will also be consistent with the requirements of NPPF footnotes 11 and 12 that require housing sites to be "deliverable and available" in order to be allocated. The employment led regeneration approach seems to have failed this test to some degree.
Higher levels of windfall development do not give accurate picture of the housing delivery. Many large housing sites concentrated in the Growth Network have multiple constraints and will require financial contributions to be delivered as is suggested by paragraph 2.10 of the emerging Strategy. This approach highlights issues of viability due to cost of land assembly, business relocation and land remediation requiring large sums of external funding to be delivered. These sites cannot be considered to be "deliverable" or "developable" with respect to paragraph 47 of the NPPF.
To be considered to be de deliverable the site should be available with a realistic housing delivery options.
To be considered to be developable the site should be in a suitable location and there should be a reasonable prospect for the site to be delivered. Majority of the employment sites do not fulfil the criteria of being "deliverable" or "developable".
The respondent considers that a more robust SHMA should be undertaken by the Black Country authorities. The housing market area should not be restricted to the Black Country administrative boundaries.

Object

Black Country Core Strategy Issue and Option Report

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

Representation ID: 1927

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

The respondent considers that a more robust and in-depth analysis needs to be undertaken of the brownfield sites that make up the housing supply, particularly their ability to come forward.
It is not clear to the development industry that given the rates of completions and need for significantly more delivery targets that adequate amount of windfall sites will come forward. A further study needs to be undertaken of the realistic capacity which can be obtained from brownfield windfalls. This will help to identify any non-completion allowance.
As responded previously to question 1 SHMA needs to be reviewed to follow housing market area and not restricting to local authority administrative boundaries.
Support paragraph 3.11 which looks to explore new means of housing provision beyond the housing market area used by the review where there are clear migration or commuting links with the local authorities. This strengthens the argument that SHLAA will have to be reviewed due to the linkages with neighbouring authorities.
There is no acknowledgement of the current shortfall provision of 3000 units taken into account in the housing requirement figure. Black Country Green Belt review should be prioritised. The respondent notes that the greenbelt review will not be completed until mid 2018 whereas the Preferred Options consultation will be undertaken in September 2018.
Green Belt sites will be needed to deliver the housing requirements. Respondent has expressed concerns that there will not be sufficient time for the authorities to properly assess green belt study findings o inform the consultation document. Further research needs to be undertaken regarding the effect of the Government grant regimes in bringing forward sites.
They consider that these programmes can be time consuming, costly and have limited benefit towards increasing supply for housing needs.

Object

Black Country Core Strategy Issue and Option Report

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 gu

Representation ID: 1928

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

As stated previously the respondent considers that SHMA needs to be reviewed and could lead to increase in the overall requirement for the Black Country authorities. They expressed concerns regarding the approach taken by SHMA towards the HMA. They consider that SHM should not follow HMA but build on the work undertaken by Greater Birmingham HMA as a part of the Birmingham Development Plan.
The HMA for Birmingham will not be the same as for the Black Country authorities. The emerging SHMA has failed to reassess the HMA boundary to test whether it is valid for assessment purposes.
SHMA does not fully address the affordable housing requirements. Paragraphs 7.26-7.29 of the SHMA confirm that the NPPG requires a "policy" on calculating housing needs for certain groups of people. Affordable housing is not a direct component of the objectively assessed needs assessment. An updated calculation is not included in the SHMA. It is for the authorities to consider whether more new homes over and above the objectively assessed need to be identified in the SHMA to address more affordable housing needs.
It therefore does not provide an accurate housing need of the authorities and is not in accordance with the national guidance set out in paragraph 159 of the NPPF.
SHMA needs to include additional information on affordable housing to establish accurate objectively assessed housing needs figure.
It should be noted that there is difference between objectively assessed housing needs figure and amount of housing allocated in the Plan as not all the allocated sites will come forward as expected.
There is uncertainty regarding significant number of housing sites identified on the existing employment land by the current development plan documents.
Black Country has undelivered its housing requirement by 11.6% and the objectively assessed needs figure should be increased by a minimum of 11.6%. The current completion rates are significantly lower than what is required by approximately 3,690 units per annum. Even if the requirement is 78,190 units over the plan period requires 3,554 units to be provided annually which is a lot higher than what is actually delivered in the Black Country authorities.
Believe that there will be greater reliance on Greenfield/Green Belt sites which will exceed 25,000 that are identified.
The oversupply seems to depend on around 42,507 units from existing sites and 8,335 from existing employment sites. Also consider that the local plan relies on 65% provision on urban brownfield /windfall sites which is unrealistic and unachievable. The problem in terms of release of employment land is acknowledged in paragraph 3.16 and 2.5 of the document.
The respondent has highlighted that there is a big gap between what is required and what is being supplied. The requirement is 2,569 units based on total of 56, 520 units whereas only 2,325 are being supplied leaving a gap of 244 units per annum.
The contribution from brownfield sites should be reduced by some 25% and much larger contribution should be sought from Greenfield/greenbelt sites. These sites should not be confined to local authority administrative boundaries.

Comment

Black Country Core Strategy Issue and Option Report

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?

Representation ID: 1957

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Agree that a Green Belt review and will need to assess land release in the adjoining authorities including South Staffordshire, Wyre Forest and Bromsgrove.
Green belt sites are crucial in meeting the housing requirement and need to be considered at early stages of the plan production.
Green Belt review should extend beyond the current plan period in accordance with the advice set out in paragraph 83 and 85 of the NPPF.
Safeguarded land between urban areas and green belt should be identified to meet the development needs beyond the plan period. Green belt review should cover development needs up to 2051.

Comment

Black Country Core Strategy Issue and Option Report

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 w

Representation ID: 1958

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Seek clarity whether land lost to residential development has been accounted for. They highlight that majority of the employment land sites have failed to come forward due to various issues.
Consider that greenfield sites with good connectivity to the north and south of the Black Country should be identified.
Employment requirements should be based on a net addition to account for losses to other uses.
Agree that a range of sites will need to be allocated to attract inward investment.
Question the deliverability of 394ha of employment land and recommend that a further assessment be undertaken.

Comment

Black Country Core Strategy Issue and Option Report

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

Representation ID: 2165

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Consider that extensive review of the existing strategy should be undertaken as the reliance on the existing strategy will fail to meet the identified housing and employment needs.
SHMA needs further investigation. There is confusion among the number of homes to be provided. Is it 22000 or 22000+extra 3000. If latter is the case the strategy needs to identify housing sites for 28000 homes.
SHMA fails to take account of affordable housing needs. As all sites may not come forward the suggested gap between supply and demand will exceed 22000 dwellings.
Ss the existing plan has failed to deliver the required housing numbers; this will increase contributions from greenbelt/Greenfield sites within the Black Country and neighbouring authorities.
Green Belt should be considered as an integral part of the strategy and sites to be identified at early stages of plan production.

Comment

Black Country Core Strategy Issue and Option Report

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

Representation ID: 2166

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

The fourth bullet point "Brownfield First" is not relevant. The reliance on brownfield sites needs to be reduced significantly. About 22000-25000 homes will need to be allocated on greenbelt/Greenfield sites.
The respondent has expressed concerns over the reliance on brownfield sites could lead to some 40,000 units to be provided on the greenbelt/Greenfield sites.
Greenbelt/greenfied sites need to be released alongside brownfield sites. This approach is in line with paragraph 17 of the NPPF.
Question whether reference to "comprehensive approach to development" has got any real meaning concerning the delivery of individual sites.

Comment

Black Country Core Strategy Issue and Option Report

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 Strate

Representation ID: 2167

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Spatial objectives 2 and 3 need to be reviewed.
Strategic employment development on the north side of the Black Country and to south east adjoining J3 M5 should be identified.
Regeneration corridors have failed to deliver wide spread change and objective 3 should be amended to read "Identification of a series of deliverable housing sites on Brownfield and Greenfield within adjoining and well connected to the Black Country which will meet the BCCS requirement over the plan period. These sites will be of differing scales and will provide different market opportunities to delivering housing over the planning period."

Comment

Black Country Core Strategy Issue and Option Report

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

Representation ID: 2168

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

Policies CSP1 and CSP2 need to be changed. The policies need to reflect the fact that majority of the housing and employment will need to be provided on greenfield/greenbelt sites within and outside the Black Country authorities' administrative area.
Presumption in favour of brownfield sites first needs to be changed.

Comment

Black Country Core Strategy Issue and Option Report

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, whic

Representation ID: 2169

Received: 08/09/2017

Respondent: Barberry Developments

Agent: Harris Lamb

Representation Summary:

No comments on individual regeneration corridors. However the respondent did feel that these corridors need to be re-examined to establish if they are able to deliver the required amount of housing and employment land as required by the Strategy.

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