Black Country Core Strategy Issue and Option Report

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.

St Modwen Developments Ltd ("St Modwen") have instructed Planning Prospects Ltd to prepare and
submit representations to the Issues and Options Consultation for the Review of the Black Country
Core Strategy (BCCS). St Modwen have extensive land ownership and development interests across
the BCCS area, and have a longstanding and extensive record in successfully bringing forward major
schemes in this part of the West Midlands. These representations are intended to support and
promote those interests.
As the BCCS Review progresses it is noted that further opportunities will arise for consultation in
September 2018, September 2019, and February 2020, before adoption scheduled for Autumn 2021.
St Modwen expect to make a contribution at each of these stages, and as plan preparation moves
forward it is anticipated that the comments made will become more detailed, technical and specific
in their nature. At the present stage in the process whilst the strategic direction of the BCCS Review
is still to be set, detailed policy wording has not been formulated, and certain key elements of the
evidence base have yet to be finalised the comments made on behalf of St Modwen are necessarily
more strategic and general in their nature. In the main they seek to influence the direction of travel
of the BCCS Review, rather than the detailed content. That said, some comments on matters of detail
are made where appropriate.
In this context, where a specific question, policy or section of text in the Issues and Options Report is
not commented on in these representations this should not be interpreted as meaning that St
Modwen necessarily agree (or indeed disagree) with it. Rather, these representations should be
understood as a statement of principles, which will be fleshed out where appropriate in subsequent
stages of consultation.
The approach taken is to assemble comments together in logical groups relating to individual
chapters or questions around specific topics. The representations should be read as a whole to
obtain a sense of the trajectory St Modwen consider the Review should follow. The short
questionnaire survey (ten questions) has also been completed on behalf of St Modwen, and
submitted separately.
However, a note of caution might be exercised at the outset. The Issues and Options Report (for
example at paragraph 2.13) is quite positive in its tone with regard to the effectiveness of the
adopted BCCS. There have undoubtedly been successes with the implementation of BCCS policy but
it must be remembered that over the relevant periods the overall targets in terms of new homes,
employment land, offices and retail have not been met (Issues and Options Report Appendix C). This
is not intended as a criticism, particularly in light of the challenging economic circumstances within
which it has operated. However, it does serve to emphasise quite strongly the importance of
ensuring the strategy and policy framework arrived at through the Review is formulated with great
care so as to maximise the opportunity and likelihood for development requirements across all
sectors in the Black Country to be met. St Modwen look forward to contributing positively to this
process and assisting the Black Country authorities with the Review.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 1
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that a "partial" review of the BCCS should be followed with a degree of caution. The
existing Core Strategy was, appropriately, focused on urban regeneration and accommodating
development needs entirely within the urban area, whereas the Review will necessarily adopt a
balanced approach across the BCCS area including, crucially, the Green Belt. The existing Core
Strategy was adopted in very different circumstances following the financial crisis at the end of the
last decade. It catered for different needs, with no requirement to accommodate overspill growth
from Birmingham, no certainty as to how employment land requirements would evolve in
subsequent years, and different expectations in terms of Midland Metro and HS2. It followed a
"Regeneration Corridor" approach which, for reasons expressed elsewhere in these representations,
is now considered outdated. It has proven challenging to meet development targets set by the
existing Core Strategy, and a step change is needed if current and future requirements are to be met.
For all these reasons it is difficult to see how the existing spatial strategy can be retained and
"stretched". The approach cannot be one that seeks to adapt the future strategy for the Black
Country into a variation of one which, by the time the Review is adopted, will be ten years old. A new
strategy is required.
Black Country Core Strategy: Response Form July 2017

Chapter / Page / Question / Paragraph
Question 2
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The evidence set out in Table 1 is likely to be sufficient to support the various stages of the Review,
but until certain key documents become available it is not possible to say with certainty that it will
indeed prove adequate. In particular, the outcome of the HMA Strategic Growth Study, the Green
Belt Review, and the second stage Economic Development Needs Assessment (EDNA) is likely to be
fundamental, and will be central to the nature of comments to be made by St Modwen in subsequent
consultations.
It is considered 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.
It is also considered that the scoping of the Green Belt Review should be informed by a consultation
process, to ensure that the exercise is ultimately completed in the most effective, and transparent,
manner. For example, care needs to be taken that the grain of analysis is not too coarse; if the spatial
framework is set too widely there will be a risk that smaller parcels of otherwise acceptable land are
overlooked within larger tranches. Furthermore, for this exercise it should also be the case that
administrative boundaries do not constrain the scope of the review or the identification of parcels.

Chapter / Page / Question / Paragraph
Question 3
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the HMA Strategic Growth Study is complete it will not be possible to comment on this issue
fully, but a considerable degree of caution should be applied to the suggested approach which would
see just 3,000 homes from Birmingham's shortfall accommodated in the Black Country. The shortfall
of almost 38,000 homes arising from Birmingham's needs that cannot be accommodated within the
City is unprecedented, and needs to be addressed; it is essential that this housing need is met. It is
not clear how the figure of 3,000 homes has been arrived at, but might be compared with the 3,790
homes which North Warwickshire Borough Council are seeking to plan for as their contribution to
meeting need exported from Birmingham. North Warwickshire is a largely rural authority, with three
fifths of its land classified as Green Belt. It is vital that the four Black Country authorities make a full
contribution in this regard, and it is not immediately clear from the Issues and Options Report that
this is likely to be the case.
It will be fundamental to the success of the BCCS Review that this overspill from Birmingham is dealt
with fairly, comprehensively and transparently. The approach is an issue for now, and should be
tackled head on at the earliest possible stage.
That said, an approach which balances the contribution that can be made by releasing surplus
employment land for housing, with a significant requirement to release Green Belt land, is supported.
This represents a clear shift away from the existing BCCS approach with its almost exclusive urban
focus, but one that is necessary if development needs are to be met.

Chapter / Page / Question / Paragraph
Question 4
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Until the Stage 2 report is completed it is not possible with certainty to comment on whether the
requirement is appropriate. That said, and as expressed elsewhere in these representations, for the
second stage EDNA to be effective it should 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 fairly 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.

Chapter / Page / Question / Paragraph
Question 5
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is clear that a comprehensive review of the Green Belt is required. The existing BCCS is
characterised by an approach which protects the Green Belt and focuses development on
Regeneration Corridors. As acknowledged at paragraph 3.40 of the Issues and Options Report the
"exceptional circumstances" threshold for allowing development in the Green Belt has been met with
the development needs identified through the Review. It is appropriate that this should take place as
part of the Core Strategy Review, alongside the Strategic Growth Study, and in conjunction with other
neighbouring authorities.
That said, it is not possible to comment on whether the proposed approach to the Green Belt Review
is appropriate or not until the methodology has been identified. As expressed elsewhere in these
representations, this exercise is so fundamental to the emerging BCCS that it is essential the scoping
of the Green Belt Review should be informed by a consultation process, to ensure it is ultimately
completed in the most effective manner.

Chapter / Page / Question / Paragraph
Question 6
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Broadly, the key issues set out in Part 3 of the Issues and Options Report are the key ones to take into
account through the Review, subject to the comments made elsewhere in these representations
about dealing fairly, comprehensively and transparently with accommodating the overspill need for
homes from Birmingham, and ensuring the Green Belt Review is completed in the most effective
manner.
However, as expressed elsewhere in these representations, a further key issue is the need to
recognise where the existing BCCS has fallen short, the extent to which over the relevant periods it
has been unable to deliver the overall targets in terms of new homes, employment land, offices and
retail, and through the Review to ensure the policy framework becomes one which will ensure the
development needs of the Black County are met.

Chapter / Page / Question / Paragraph
Question 7
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The sustainability principles should be extended to include amongst their number the specific
recognition that the Black Country authorities must assist as fully as possible with meeting the
overspill development requirements of their neighbours (principally Birmingham).

Chapter / Page / Question / Paragraph
Question 8
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is considered that the legacy spatial objectives do not remain relevant. They are framed around a
strategy which focused almost entirely on directing development towards the Regeneration
Corridors. It is very clear that the BCCS Review will need to take a material change in direction and
allow for the prospect of significant growth in the Green Belt as part of a balanced approach to
accommodating growth. This should be recognised through the spatial objectives, i.e. acknowledging
the requirement to accommodate development in the most sustainable manner and in the most
appropriate locations within the Green Belt.
This recognition should extend beyond the housing sector, which presents perhaps the most
immediate and obvious challenges, and also include employment. The legacy spatial objectives seek
to direct employment towards the Strategic Centres and Regeneration Corridors, and there should
still be a role for this in the Review, but there should also be explicit recognition that needs for large
scale (particularly logistics focused) employment development will only be met in full if additional
unconstrained sites with immediate access to the Strategic Road Network are also provided.
The backdrop of development requirements identified in the early parts of the Issues and Options
Report provides the context for the spatial objectives to be revisited, and they should be recast
accordingly.

Chapter / Page / Question / Paragraph
Question 9
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
In broad terms the parts of Policy CSP1 dealing with objectives to focus growth within the Strategic
Centres are appropriate. However, greater emphasis should be placed on the recognition that this
forms one part of a balanced approach to accommodating growth. For the reasons set out elsewhere
in these representations it is considered that the Regeneration Corridor focused approach is no
longer appropriate, and should be discontinued.
The implications of this include the requirement for a change of direction for Policy CSP2. This should
deal generally with accommodating growth in an even and balanced manner outside the Strategic
Centres, without reference to the Regeneration Corridors. It will also need to allow for the planned
growth required in the Green Belt.

Chapter / Page / Question / Paragraph
Questions 10, 11a and 11b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
The Regeneration Corridors are now a somewhat dated and perhaps artificial construct, and this
approach should be discontinued. They are somewhat insensitive to market and occupier needs. The
approach should be simplified by removing the corridors and accommodating development through
carefully identified and allocated sites, with a balanced approach to urban regeneration, redeveloping
existing employment land where appropriate, and expanding into the Green Belt. This should be
coupled with a straightforward criteria based approach to the development of land that is not
allocated. This would be an approach focused very much on the provision of land for development,
rather than protecting land or unnecessarily channelling growth. It would seek to optimise urban
capacity, broadly defined, whilst also recognising that some development needs can only be met in
the Green Belt.
Separate submissions will be made on behalf of St Modwen to the "call for sites".

Chapter / Page / Question / Paragraph
Questions 12a, 12b and 13a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
It is important that Spatial Options H1 and H2 are not treated as alternatives, but rather as
approaches that might be combined in seeking to ensure that development needs are fully met.
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. A limited
number of Sustainable Urban Extensions should also be supported, albeit recognising that the
contribution such sites make to housing supply is only likely to be realised in the longer term.
Balance between the two Spatial Options is most likely to ensure continuity of delivery, choice to
housebuilders and buyers, and manageable impacts and infrastructure delivery challenges.

Chapter / Page / Question / Paragraph
Question 15a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
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 not appropriate, as would be any policy
in the BCCS Review which relegated it as a problem for another day; it is an issue for now. The
export of housing from Birmingham is unprecedented in its scale, and the issue cannot continue to be
passed down the line. 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.

Chapter / Page / Question / Paragraph
Questions 16 - 20
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
A combination of Spatial Options E1 and E2 is appropriate, i.e. expansion into, and new development
on, the Green Belt. Large, regular, deliverable, 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; it might also prove to be the case that such sites
are capable of contributing more significantly towards infrastructure requirements. There remains a
role for the recycling of 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 most effective it should 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 somewhat 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.

Chapter / Page / Question / Paragraph
Question 34a
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
Health and wellbeing impacts should be assessed, but only for large development proposals, and only
through the plan preparation process. There should be no development management policy around
this issue in the new BCCS, and no requirement for it at any stage in the process for small scale
development.

Chapter / Page / Question / Paragraph
Questions 36 - 40, 41a - 41d
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
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 is 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 formulated to reflect local circumstances.
The exact nature of these standards should be consulted upon following further stages of plan
preparation once there is greater clarity as to what those sites are likely to be. 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.
There should be no requirement for larger housing sites to provide serviced plots. Where there is
clear and quantified evidence of a need for self and custom built housing then a broad target should
be set for each of the constituent authorities. The ability to accommodate such provision should be
considered on a site by site basis, i.e. considering the contribution that might be made in this regard
by all housing sites, not just the large ones.

Chapter / Page / Question / Paragraph
Questions 44a and 45
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
The affordable housing requirement is appropriate, but on the understanding that the provisions of
Policy HOU3 in terms of viability testing remain in place. There should not necessarily be an
increased requirement for Green Belt release sites. It might prove simplistic to assume these sites
will have greater financial viability in circumstances where they are likely to have significantly greater
costs associated with utilities and infrastructure provision. A general target of 25% subject to viability
is appropriate, although for larger allocations this might be determined on a site by site basis.

Chapter / Page / Question / Paragraph
Questions 49a and 49b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
There is a need for a policy to regulate the conversion of poorer quality employment land, but this
should be made more permissive of change. The approach should be to support and encourage the
recycling of such sites for alternative uses unless this is clearly and demonstrably unacceptable or
inappropriate. Policy DEL2 should be simplified and made more permissive. The release of
employment land to alternative uses should not be restricted to housing, and the conversion to
different forms of employment generating activity should also be viewed positively where
appropriate.

Chapter / Page / Question / Paragraph
Questions 50 - 54
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree / Disagree
Comments (continue on a separate sheet if necessary)
It is important that the BCCS Review provides clear guidance and structure to ensure that the "right"
employment land is delivered; the quantitative need is important but equally so the qualitative need.
The distinction between "Strategic High Quality" and "Local Quality" employment land is a useful one
in headline terms, but requires more refinement such that the sum of allocations ensures all
development needs are met.
The criteria used to define "Strategic High Quality" sites are broadly appropriate. However, it is
considered that whilst proximity to a large workforce is required, this need not be "skilled"; such an
approach would tend to discourage locations where upskilling is required and could be encouraged
by development. It is considered that "good proximity to an existing or proposed knowledge cluster"
should be deleted, as this is unnecessary for some key types of high quality employment, for example
sites focusing on logistics. All criteria should be refined to clarify that it is not just the presence of
each feature that is required, but potential for it to be provided where it does not already exist. Such
wording is currently provided for the "environmental quality" criterion but not the others, and it
should be included for all.
Some flexibility should be provided for alternative uses in the "Strategic High Quality" sites where this
would enable complementary activities (for example around eating and drinking, every day retail, or
hotel accommodation) which help to create an environment to attract major employers, and enable
them in turn to attract and retain employees. Equally, some allowance for employment generating
uses outside of the manufacturing and logistics sectors should be made. In both cases it is perhaps
difficult to see how this can be achieved other than on a site by site, case specific basis. The objective
should be for these sites to have a strong and clear focus on the manufacturing and logistics sectors,
and this should not be unnecessarily diluted, but where there are strong arguments for supporting
activities or other types of job creation this should be accommodated.
Against this background a portfolio, rather than reservoir, based approach seems more appropriate.
This should provide general guidance on the size, type and quality of sites that is needed, rather than
simply the amount. It need not be overly prescriptive, but rather supportive of the needs of
employers and the development industry.

Chapter / Page / Question / Paragraph
Questions 95a and 95b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Disagree
Comments (continue on a separate sheet if necessary)
Given the particular challenges faced by the Black Country authorities in terms of development
viability and attracting investment it might prove to be the case that it is difficult to pursue "Garden
City principles". It is of course important to ensure that the best practicable standards of design and
environmental infrastructure are achieved, but it may be that this can be done within a conventional
framework of fairly standard criteria based development management policies, rather than applying
an additional "Garden City" prism. Further consideration will be given to this point as any such
principles are established in subsequent stages of plan preparation.

Chapter / Page / Question / Paragraph
Questions 103a and 103b
Do you agree or disagree with the approach set out in the relevant section and /
or question?
Agree
Comments (continue on a separate sheet if necessary)
A "fabric first" approach should be supported and encouraged by policy and the 10% requirement
retained, subject to viability.