Black Country Core Strategy Issue and Option Report

Re ‐ Response of Hagley Parish Council to Black Country Core Strategy consultation
Hagley Parish Council welcomes the opportunity to respond to the consultation. It does not want to comment on many of the aspects of the consultation, which it considers to be internal matters to be determined by the residents of the four Black Country boroughs. Our comments are accordingly limited to a few aspects of BCCS, where it is liable to have an impact, direct or indirect on our parish.
Keep the Green Belt intact Hagley is a commuter settlement of about 6500 people. The parish adjoins the southern boundary of Stourbridge,
one of the constituent towns of Dudley MBC. The built area of Hagley is separated from that of Pedmore (in Stourbridge) by a very narrow strip of countryside. Along Worcester Lane, Pedmore, the gap is 500 metres, and even this is interrupted by the presence of Treherns Farm buildings. Along Stourbridge Road, there is no gap at all on the west side, but 600 metres on the east side. One of the purposes of Green Belt is to keep towns from coalescing. This is a very sensitive narrow gap, which should be retained to prevent Hagley from coalescing with Stourbridge.

Whether Hagley should be classified as a village or a town is debateable. Hagley certainly has some (but not all) of the characteristics of a market town as defined in the former West Midlands Regional Spatial Strategy, policy RR3:
 It has a relationship with a rural hinterland, in that it has a shopping centre (in Worcester Road) to which people come to shop.
 However, it does not have a balance between employment and housing, not is there potential for this.
 It does not have a planned and coordinated local transport network.
 It fits in terms of a population in the range 2,000‐20,000
 Its capacity to grow is questionable.

The consultation document indicates that any Green Belt Review needed has not been undertaken. It appears to imply that cross‐boundary reviews will only look at encroachment into the South Staffordshire Green Belt, not that in Bromsgrove district: the four Black Country Boroughs appear not to have sought cooperation from Bromsgrove DC. As a matter of NIMBE views, we have to welcome the lack of encroachment.

A456, between Hayley Green and M5 J3 forms a robust landscape boundary between the conurbation and the Green Belt. Allowing development to breach this barrier would be a very serious matter indeed.

Housing and other development targets There has been a longstanding policy of segregating housing and industry into separate zones. Where small employment sites become redundant, it may well be appropriate for them to become housing sites, but this needs to be judged on a case by case basis. There should always be a preference for development to be on brownfield sites. However these are a renewable resource, not a fixed one. It is likely that new ones will become available, for example small poorly‐located employment sites. Any option to release green fields for development should be held back to force developers to
bring brownfield sites forward. Another of the five purposes of Green Belt is to encourage urban regeneration.

Accordingly, it is concluded that some green fields must be released to provide a long‐term land reserve for development, that land should be given a safeguarded status, with a relatively simple mechanism for its release, probably involving a single consultation, an Examination, and the adoption of a Supplementary Plan, with a trigger point of the housing or employment land supply falling to (perhaps) seven years' requirement. This will discourage developers from grabbing green fields before that is necessary.

Housing and other development targets

There has been a tendency in many Plans to apply subjective factors to distort Objectively Assessed Need to produce subjectively assessed targets to meet the aspirations of developers and politicians. NPPF requires councils only to meet Objectively Assessed Need. Furthermore, it is legitimate for LPAs to decide that they cannot fully accommodate their Objectively Assessed Need due to other constraints on what is available, including that the land is designated as Green Belt. NPPF further provides that the release of Green Belt through a Local Plan
Review (which of course includes the review of BCCS) should only take place in "exceptional circumstances", which it does not define further. The recent Housing White Paper proposed to gloss this term, by saying that all other options should have been considered before Green Belt release was undertaken. The present consultation document fails to establish that the required "exceptional circumstances" exist.

We regard the alleged housing land deficit in Birmingham as exaggerated. We suspect that the computations undertaken for BCCS also tend to exaggerate the need. This is partly because the Plan is intended to run until 2036, whereas the plans of most other authorities in the region expire a few years earlier.

The series of reports undertaken by Peter Brett Associates into how the alleged Birmingham housing land deficit could be met ultimately come up with no definite conclusions. One of the difficulties that its compilers found a great lack of consistency between the methods adopted by different LPAs for compiling their SHLAAs; in the case of BCCS, replaced by a HELAA. This inconsistency has been carried forward in the four separate borough‐wide reports lying behind the Black Country's HELAA. If the new BCCS is to become a sound Plan, the evidence‐base
lying behind it must be compiled in a consistent manner between the four boroughs.

Improve major highways

A major issue in Hagley is the level of traffic on A456, part of which is the busiest A‐class road in Hagley. Parts of
this are a single carriageway road, though wide enough for three lanes of traffic. Development that would
exacerbate traffic on A456 should be unacceptable. A456, where it passes through part of Dudley Borough as the
Quinton Expressway and Halesowen Bypass (Manor Lane) are congested to an unacceptable extent. Occasionally
at peak times traffic is backing up from the Grange roundabout (with A459 and B4551) as far as M5 J3, 2 km back.
We know of evidence of southbound traffic on M5 leaving at J4 (rather than J3) to avoid this congestion.
The last works carried out on the Grange roundabout made little difference to the congestion, though they may
have had a marginal effect on road safety. This island has been laid out through the unthinking application of a
text‐book design, which would be appropriate if all four arms of the crossroads were reasonably equal; but they
are not in this case. The volume of traffic entering and leaving B4551 is modest compared to the other arms. The
junction needs to be thought of as a T‐junction with a minor fourth arm, not as a standard crossroads.
 The ideal solution would be a tunnel to take one lane of traffic each way under the island, which should
alleviate congestion very considerably. By taking Hagley to Birmingham traffic off the roundabout the
flow of Birmingham to Halesowen traffic should be improved. By taking Birmingham to Hagley traffic
Website: www.hagleyparishcouncil.gov.uk. Email: clerk@hagleyparishcouncil.gov.uk
under it, its flow should become better, though a queue of vehicles trying to reach Halesowen is likely to
remain.
 Alternatively, the island needs to be altered so that three lanes of traffic can use the island abreast going

Re ‐ Response of Hagley Parish Council to Black Country Core Strategy consultation
Hagley Parish Council welcomes the opportunity to respond to the consultation. It does not want to comment on many of the aspects of the consultation, which it considers to be internal matters to be determined by the residents of the four Black Country boroughs. Our comments are accordingly limited to a few aspects of BCCS, where it is liable to have an impact, direct or indirect on our parish.
Keep the Green Belt intact Hagley is a commuter settlement of about 6500 people. The parish adjoins the southern boundary of Stourbridge,
one of the constituent towns of Dudley MBC. The built area of Hagley is separated from that of Pedmore (in Stourbridge) by a very narrow strip of countryside. Along Worcester Lane, Pedmore, the gap is 500 metres, and even this is interrupted by the presence of Treherns Farm buildings. Along Stourbridge Road, there is no gap at all on the west side, but 600 metres on the east side. One of the purposes of Green Belt is to keep towns from coalescing. This is a very sensitive narrow gap, which should be retained to prevent Hagley from coalescing with Stourbridge.

Whether Hagley should be classified as a village or a town is debateable. Hagley certainly has some (but not all) of the characteristics of a market town as defined in the former West Midlands Regional Spatial Strategy, policy RR3:
 It has a relationship with a rural hinterland, in that it has a shopping centre (in Worcester Road) to which people come to shop.
 However, it does not have a balance between employment and housing, not is there potential for this.
 It does not have a planned and coordinated local transport network.
 It fits in terms of a population in the range 2,000‐20,000
 Its capacity to grow is questionable.

The consultation document indicates that any Green Belt Review needed has not been undertaken. It appears to imply that cross‐boundary reviews will only look at encroachment into the South Staffordshire Green Belt, not that in Bromsgrove district: the four Black Country Boroughs appear not to have sought cooperation from Bromsgrove DC. As a matter of NIMBE views, we have to welcome the lack of encroachment.

A456, between Hayley Green and M5 J3 forms a robust landscape boundary between the conurbation and the Green Belt. Allowing development to breach this barrier would be a very serious matter indeed.

Housing and other development targets There has been a longstanding policy of segregating housing and industry into separate zones. Where small employment sites become redundant, it may well be appropriate for them to become housing sites, but this needs to be judged on a case by case basis. There should always be a preference for development to be on brownfield sites. However these are a renewable resource, not a fixed one. It is likely that new ones will become available, for example small poorly‐located employment sites. Any option to release green fields for development should be held back to force developers to
bring brownfield sites forward. Another of the five purposes of Green Belt is to encourage urban regeneration.

Accordingly, it is concluded that some green fields must be released to provide a long‐term land reserve for development, that land should be given a safeguarded status, with a relatively simple mechanism for its release, probably involving a single consultation, an Examination, and the adoption of a Supplementary Plan, with a trigger point of the housing or employment land supply falling to (perhaps) seven years' requirement. This will discourage developers from grabbing green fields before that is necessary.

Housing and other development targets

There has been a tendency in many Plans to apply subjective factors to distort Objectively Assessed Need to produce subjectively assessed targets to meet the aspirations of developers and politicians. NPPF requires councils only to meet Objectively Assessed Need. Furthermore, it is legitimate for LPAs to decide that they cannot fully accommodate their Objectively Assessed Need due to other constraints on what is available, including that the land is designated as Green Belt. NPPF further provides that the release of Green Belt through a Local Plan
Review (which of course includes the review of BCCS) should only take place in "exceptional circumstances", which it does not define further. The recent Housing White Paper proposed to gloss this term, by saying that all other options should have been considered before Green Belt release was undertaken. The present consultation document fails to establish that the required "exceptional circumstances" exist.

We regard the alleged housing land deficit in Birmingham as exaggerated. We suspect that the computations undertaken for BCCS also tend to exaggerate the need. This is partly because the Plan is intended to run until 2036, whereas the plans of most other authorities in the region expire a few years earlier.

The series of reports undertaken by Peter Brett Associates into how the alleged Birmingham housing land deficit could be met ultimately come up with no definite conclusions. One of the difficulties that its compilers found a great lack of consistency between the methods adopted by different LPAs for compiling their SHLAAs; in the case of BCCS, replaced by a HELAA. This inconsistency has been carried forward in the four separate borough‐wide reports lying behind the Black Country's HELAA. If the new BCCS is to become a sound Plan, the evidence‐base
lying behind it must be compiled in a consistent manner between the four boroughs.

Improve major highways

A major issue in Hagley is the level of traffic on A456, part of which is the busiest A‐class road in Hagley. Parts of
this are a single carriageway road, though wide enough for three lanes of traffic. Development that would
exacerbate traffic on A456 should be unacceptable. A456, where it passes through part of Dudley Borough as the
Quinton Expressway and Halesowen Bypass (Manor Lane) are congested to an unacceptable extent. Occasionally
at peak times traffic is backing up from the Grange roundabout (with A459 and B4551) as far as M5 J3, 2 km back.
We know of evidence of southbound traffic on M5 leaving at J4 (rather than J3) to avoid this congestion.
The last works carried out on the Grange roundabout made little difference to the congestion, though they may
have had a marginal effect on road safety. This island has been laid out through the unthinking application of a
text‐book design, which would be appropriate if all four arms of the crossroads were reasonably equal; but they
are not in this case. The volume of traffic entering and leaving B4551 is modest compared to the other arms. The
junction needs to be thought of as a T‐junction with a minor fourth arm, not as a standard crossroads.
 The ideal solution would be a tunnel to take one lane of traffic each way under the island, which should
alleviate congestion very considerably. By taking Hagley to Birmingham traffic off the roundabout the
flow of Birmingham to Halesowen traffic should be improved. By taking Birmingham to Hagley traffic
Website: www.hagleyparishcouncil.gov.uk. Email: clerk@hagleyparishcouncil.gov.uk
under it, its flow should become better, though a queue of vehicles trying to reach Halesowen is likely to
remain.
 Alternatively, the island needs to be altered so that three lanes of traffic can use the island abreast going

Re ‐ Response of Hagley Parish Council to Black Country Core Strategy consultation
Hagley Parish Council welcomes the opportunity to respond to the consultation. It does not want to comment on many of the aspects of the consultation, which it considers to be internal matters to be determined by the residents of the four Black Country boroughs. Our comments are accordingly limited to a few aspects of BCCS, where it is liable to have an impact, direct or indirect on our parish.
Keep the Green Belt intact Hagley is a commuter settlement of about 6500 people. The parish adjoins the southern boundary of Stourbridge,
one of the constituent towns of Dudley MBC. The built area of Hagley is separated from that of Pedmore (in Stourbridge) by a very narrow strip of countryside. Along Worcester Lane, Pedmore, the gap is 500 metres, and even this is interrupted by the presence of Treherns Farm buildings. Along Stourbridge Road, there is no gap at all on the west side, but 600 metres on the east side. One of the purposes of Green Belt is to keep towns from coalescing. This is a very sensitive narrow gap, which should be retained to prevent Hagley from coalescing with Stourbridge.

Whether Hagley should be classified as a village or a town is debateable. Hagley certainly has some (but not all) of the characteristics of a market town as defined in the former West Midlands Regional Spatial Strategy, policy RR3:
 It has a relationship with a rural hinterland, in that it has a shopping centre (in Worcester Road) to which people come to shop.
 However, it does not have a balance between employment and housing, not is there potential for this.
 It does not have a planned and coordinated local transport network.
 It fits in terms of a population in the range 2,000‐20,000
 Its capacity to grow is questionable.

The consultation document indicates that any Green Belt Review needed has not been undertaken. It appears to imply that cross‐boundary reviews will only look at encroachment into the South Staffordshire Green Belt, not that in Bromsgrove district: the four Black Country Boroughs appear not to have sought cooperation from Bromsgrove DC. As a matter of NIMBE views, we have to welcome the lack of encroachment.

A456, between Hayley Green and M5 J3 forms a robust landscape boundary between the conurbation and the Green Belt. Allowing development to breach this barrier would be a very serious matter indeed.

Housing and other development targets There has been a longstanding policy of segregating housing and industry into separate zones. Where small employment sites become redundant, it may well be appropriate for them to become housing sites, but this needs to be judged on a case by case basis. There should always be a preference for development to be on brownfield sites. However these are a renewable resource, not a fixed one. It is likely that new ones will become available, for example small poorly‐located employment sites. Any option to release green fields for development should be held back to force developers to
bring brownfield sites forward. Another of the five purposes of Green Belt is to encourage urban regeneration.

Accordingly, it is concluded that some green fields must be released to provide a long‐term land reserve for development, that land should be given a safeguarded status, with a relatively simple mechanism for its release, probably involving a single consultation, an Examination, and the adoption of a Supplementary Plan, with a trigger point of the housing or employment land supply falling to (perhaps) seven years' requirement. This will discourage developers from grabbing green fields before that is necessary.

Housing and other development targets

There has been a tendency in many Plans to apply subjective factors to distort Objectively Assessed Need to produce subjectively assessed targets to meet the aspirations of developers and politicians. NPPF requires councils only to meet Objectively Assessed Need. Furthermore, it is legitimate for LPAs to decide that they cannot fully accommodate their Objectively Assessed Need due to other constraints on what is available, including that the land is designated as Green Belt. NPPF further provides that the release of Green Belt through a Local Plan
Review (which of course includes the review of BCCS) should only take place in "exceptional circumstances", which it does not define further. The recent Housing White Paper proposed to gloss this term, by saying that all other options should have been considered before Green Belt release was undertaken. The present consultation document fails to establish that the required "exceptional circumstances" exist.

We regard the alleged housing land deficit in Birmingham as exaggerated. We suspect that the computations undertaken for BCCS also tend to exaggerate the need. This is partly because the Plan is intended to run until 2036, whereas the plans of most other authorities in the region expire a few years earlier.

The series of reports undertaken by Peter Brett Associates into how the alleged Birmingham housing land deficit could be met ultimately come up with no definite conclusions. One of the difficulties that its compilers found a great lack of consistency between the methods adopted by different LPAs for compiling their SHLAAs; in the case of BCCS, replaced by a HELAA. This inconsistency has been carried forward in the four separate borough‐wide reports lying behind the Black Country's HELAA. If the new BCCS is to become a sound Plan, the evidence‐base
lying behind it must be compiled in a consistent manner between the four boroughs.

Improve major highways

A major issue in Hagley is the level of traffic on A456, part of which is the busiest A‐class road in Hagley. Parts of
this are a single carriageway road, though wide enough for three lanes of traffic. Development that would
exacerbate traffic on A456 should be unacceptable. A456, where it passes through part of Dudley Borough as the
Quinton Expressway and Halesowen Bypass (Manor Lane) are congested to an unacceptable extent. Occasionally
at peak times traffic is backing up from the Grange roundabout (with A459 and B4551) as far as M5 J3, 2 km back.
We know of evidence of southbound traffic on M5 leaving at J4 (rather than J3) to avoid this congestion.
The last works carried out on the Grange roundabout made little difference to the congestion, though they may
have had a marginal effect on road safety. This island has been laid out through the unthinking application of a
text‐book design, which would be appropriate if all four arms of the crossroads were reasonably equal; but they
are not in this case. The volume of traffic entering and leaving B4551 is modest compared to the other arms. The
junction needs to be thought of as a T‐junction with a minor fourth arm, not as a standard crossroads.
 The ideal solution would be a tunnel to take one lane of traffic each way under the island, which should
alleviate congestion very considerably. By taking Hagley to Birmingham traffic off the roundabout the
flow of Birmingham to Halesowen traffic should be improved. By taking Birmingham to Hagley traffic
Website: www.hagleyparishcouncil.gov.uk. Email: clerk@hagleyparishcouncil.gov.uk
under it, its flow should become better, though a queue of vehicles trying to reach Halesowen is likely to
remain.
 Alternatively, the island needs to be altered so that three lanes of traffic can use the island abreast going