Black Country Core Strategy Issue and Option Report

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Comment

Black Country Core Strategy Issue and Option Report

Question 15c - Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affo

Representation ID: 2759

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

5.23 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.

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Comment

Black Country Core Strategy Issue and Option Report

Question 20 - Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.

Representation ID: 2760

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

5.29 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.30 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. Indeed, there is likely to be a significant growth in the need for logistics floorspace to accommodate rapid increases in the dot.com purchasing of goods and demand for next day delivery. Efficient access to motorway junctions and the strategic road network and the availability of large sites will therefore take priority, as well as other considerations such as the ability to operate 24 hours. Placing such sites directly next to the existing urban area may therefore be impractical. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.31 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.

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Comment

Black Country Core Strategy Issue and Option Report

Question 21 - Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide de

Representation ID: 2762

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.

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Comment

Black Country Core Strategy Issue and Option Report

Question 22 - Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located

Representation ID: 2763

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.2 Richborough Estates is in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals.

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Comment

Black Country Core Strategy Issue and Option Report

Question 25 - Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastruc

Representation ID: 2765

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.5 It is recognised that delivery of new housing developments may give rise to the need to deliver supporting infrastructure. Richborough Estates is committed to working with the relevant authorities and service providers to determine the capacity of existing infrastructure and determine the level of mitigatory provision necessary to support an increase in the population in this location. It is however important that each potential large new housing development is given independent consideration in respect of any infrastructure obligations, recognising that pressures will be dependent on location and existing infrastructure capacity.

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Object

Black Country Core Strategy Issue and Option Report

Question 28 - Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?

Representation ID: 2767

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.

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Support

Black Country Core Strategy Issue and Option Report

Question 29 - Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.

Representation ID: 2769

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with any Core Strategy advanced. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions through the Black Country Core Strategy Review are needed.

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Comment

Black Country Core Strategy Issue and Option Report

Question 30 - Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites

Representation ID: 2770

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of greenfield and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing greenfield and Green Belt sites should come forward for development as soon as practically possible. Given lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the Plan period and the needs are met.

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Comment

Black Country Core Strategy Issue and Option Report

Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mec

Representation ID: 2771

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

6.11 When delivering greenfield/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous communities.

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Comment

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: 2773

Received: 08/09/2017

Respondent: Richborough Estates Ltd

Agent: Pegasus Group

Representation Summary:

7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.

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