Black Country Core Strategy Issue and Option Report

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Object

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: 761

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

Read in conjuction with questions 12b and 13a

Promoting delivery and market certainty is more likely under Spatial Options H1 and this should be a strong influence in choosing this approach. Persimmon support the view expressed that there is considerable potential for "rounding off" and relatively modest incursions into the Green Belt for small to medium sized housing sites, and the "opportunities" identified in this regard in the table under paragraph 4.29 of the Issues and Options Report should all be recognised. Whilst there is some concern that such small sites may not contribute to infrastructure in significant ways, this is a matter which can be carefully planned for by the LPA's and cumulative contributions can be combined to support infrastructure provision without compromising CIL regulations.
Whilst there may be some opportunity for a very limited number of Sustainable Urban Extensions it must be a strong influence that the contribution such sites make to housing supply is only likely to be realised in the longer term. They are equally not always certain to make larger infrastructure contributions as they too invariable face viability challenges.

Object

Black Country Core Strategy Issue and Option Report

Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be tak

Representation ID: 762

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

The only circumstances in which any housing growth should be exported elsewhere in the HMA is if there is compelling evidence it cannot be accommodated within the Black Country, and there is a robust and certain framework in place to ensure that the homes will be required. An ongoing and open ended general process of discussion around this issue is unacceptable, as would be any policy in the BCCS Review which relegated it as a problem for another day. It is a problem for now. The export of housing from Birmingham is unprecedented in its scale, and the issue cannot simply continue to be passed down the line. At some point agreement needs to be reached in terms of how need across the HMA is going to be met, and the BCCS Review provides an ideal platform in this regard.
Persimmon do not support any contention at this stage that there is any sound reason why all housing need cannot be accommodated within the Black Country and there is no justification for exporting need to adjoining neighbouring Authorities.

Comment

Black Country Core Strategy Issue and Option Report

Question 16 - Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If yo

Representation ID: 763

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

Questions 16-20

A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development on, the Green Belt. Large, regular, and unconstrained sites with immediate access to the Strategic Road Network are required to contribute towards meeting the need for employment land, particularly in relation to logistics led requirements. There remains a role for the recycling of
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brownfield sites to contribute towards meeting employment land needs, but this will not meet the requirements of the highly location sensitive large space occupiers that the Black Country should be seeking to attract.
It might be that sites within Sustainable Urban Extensions (Spatial Option E3) can also make some contribution in this regard, but this cannot be relied upon, particularly in the short term, and it is unlikely that SUEs will provide an effective mechanism to accommodate large scale requirements. Exporting growth to neighbouring areas (Spatial Option E4) should only be entertained as a last resort and if there is compelling evidence it cannot be accommodated within the Black Country.
This again speaks to the point made elsewhere in these representations that for the second stage EDNA to be effective it must be informed by far wider consultation with landowners, developers and employers than appears to have been the case with the first stage exercise. The Stage 1 report appears to have been informed by a narrow range of consultees, and unless this is addressed fully at Stage 2 it is unlikely that the employment land requirement will be properly assessed.

Object

Black Country Core Strategy Issue and Option Report

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

Representation ID: 764

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

The general approach to review HOU1 is of course appropriate, but comments have already been set out above in respect of concerns about adopting a brownfield first approach. Any housing trajectory needs to reflect and support early delivery with a significant shift away from and reduction in the amount of housing to be built on brownfield sites. Any level of need identified, must be met with realistic assumptions about supply. Undue reliance upon windfall merely circumvents the proper planning of an area and reduces certainty. Discounts should be applied for non delivery of commitments and allocations. Some over provision in supply is essential and can ensure a choice and range of sites and greater market interest. Allowances for large scale demolitions as in the past should be removed. Assumptions which increase the expected density of development should also be avoided. There is no meaningful market interest or appetite for increasing the density of housing in the Black Country and delivery would be better supported by reflecting market needs which are focused on sensible and modest density ranges often associated with suburban family housing.

Comment

Black Country Core Strategy Issue and Option Report

Question 36 - Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for exam

Representation ID: 765

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

Read in conjunction with questions 38 and 40.

The type of approach set out in Policy HOU2 and Table 8 is appropriate in general terms, although greater clarity should be provided to confirm that the standards are general ones, that their practical application is highly location specific, and will be considered on a site by site basis to reflect local circumstances. There should be no requirement to increase the density standards, and again it should be clarified that these (and indeed the accessibility standards) should be regarded as indicative only.
For Green Belt releases, site specific standards should be avoided and density should reflect local circumstances. There should be no separate standards for particular housing types; this would add an unnecessary level of complexity and risk hindering the delivery of such units where they might have been provided as part of schemes otherwise broadly acceptable for their provision.
The SHMA should be used as a general guide to the types of houses to be delivered, but must be applied generally, rather than rigidly, or again this will hinder delivery.

Comment

Black Country Core Strategy Issue and Option Report

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.

Representation ID: 766

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

Read in conjunction with question 45

The affordable housing requirement is appropriate, but on the clear understanding that the provisions of Policy HOU3 in terms of viability testing remain in place. There should be no increased requirement for Green Belt release sites. It is simplistic to assume these sites will have greater financial viability in circumstances where they are likely to have additional costs associated with utilities and infrastructure provision. A target of 25% subject to viability is appropriate.

Object

Black Country Core Strategy Issue and Option Report

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

Representation ID: 767

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

Read in conjunction with question 95b

Given the particular challenges faced by the Black Country authorities in terms of development viability and attracting investment it is difficult to understand why "Garden City principles" should be pursued. It is of course important to ensure that the best practicable standards of design and environmental infrastructure are achieved, but this can be done within a conventional framework of fairly standard criteria based development management policies, rather than applying an additional, unnecessary and distracting "Garden City" approach.

Comment

Black Country Core Strategy Issue and Option Report

Policy ENV7 - Renewable Energy

Representation ID: 768

Received: 08/09/2017

Respondent: Persimmons Homes (West Midlands) Ltd

Agent: Planning Prospects Ltd

Representation Summary:

A "fabric first" approach should be supported and encouraged by policy and the 10% requirement for renewables applied and viewed more flexibly. This approach should be applied to housing as well as non domestic buildings

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