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: 962

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

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: 963

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:


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.

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: 964

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:


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 We consider that these figures are outdated and the figures in the Housing Supply Background Report should be based on up to date housing requirement figures as set out in the Strategic Housing Market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.

Support

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: 965

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

Support

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: 966

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

We agree.

Object

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: 967

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

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: 968

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

Object

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: 969

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.

Representation ID: 970

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:


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.

Comment

Black Country Core Strategy Issue and Option Report

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 re

Representation ID: 971

Received: 23/10/2017

Respondent: Savills

Agent: Savills

Representation Summary:

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.

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