Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you
Representation ID: 2529
Received: 04/09/2017
Respondent: Hawksmoor
Our clients agree that a partial review is appropriate, however the existing Core Strategy should be sufficiently updated to take account of the new, and expanded requirements for housing development arising from the wider Housing Market Area over the new Plan period. Our clients support the associated Call for Sites process.
Comment
Black Country Core Strategy Issue and Option Report
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there
Representation ID: 2530
Received: 04/09/2017
Respondent: Hawksmoor
Agree
Comment
Black Country Core Strategy Issue and Option Report
Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national gu
Representation ID: 2531
Received: 04/09/2017
Respondent: Hawksmoor
Agree
Comment
Black Country Core Strategy Issue and Option Report
Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
Representation ID: 2532
Received: 04/09/2017
Respondent: Hawksmoor
Our clients agree with the conclusions reached in paragraph 3.40 that the need to accommodate unmet housing needs can contribute towards establishing a case for exceptional circumstances to precipitate a Green Belt Review. We also consider that it will be crucial to ensure that the Green Belt Review is carried out holistically, that is to say incorporating the findings of the forthcoming South Staffordshire Green Belt Review and other surrounding Districts outside the Black Country. South Staffordshire has a large interface with the northern and western areas of the Black Country and as such will be an important area to take into account for any provision of housing that the Black Country cannot itself accommodate.
Comment
Black Country Core Strategy Issue and Option Report
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be
Representation ID: 2533
Received: 04/09/2017
Respondent: Hawksmoor
We agree that meeting the need for existing and future housing need is crucial to the Review process.
Comment
Black Country Core Strategy Issue and Option Report
Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
Representation ID: 2534
Received: 04/09/2017
Respondent: Hawksmoor
We agree with the majority of the principles, in particular the requirement for sustainable development and also a comprehensive approach to development. However, we contend that the 'brownfield first' principle will become outdated during the course of the new Plan period, and therefore this principle should be augmented to reflect such.
At Paragraph 3.11 of the Issues and Options document, the Strategic Housing Needs Study (2015) is referenced. The study concluded that the supply of brownfield land across the HMA is insufficient to accommodate this shortfall, and that the majority of that shortfall will have to be met on greenfield sites, including those in the Green Belt. Furthermore, many brownfield housing sites within the Black Country are unviable due to the substantial costs required to bring them forward for development such as remediation and access infrastructure.
Therefore, we would welcome reference in the vision and sustainability principles to the need to accommodate the majority of housing need on greenfield sites to ensure a sustainable supply of housing and therefore supporting economic growth.
Comment
Black Country Core Strategy Issue and Option Report
Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate
Representation ID: 2535
Received: 04/09/2017
Respondent: Hawksmoor
Again, reflecting the answer to Question 7 above, our clients believe that greater emphasis should be placed on the delivery of new housing developments on greenfield sites as opposed to the reference to "Model sustainable communities on redundant employment land" at spatial objective number 3.
Comment
Black Country Core Strategy Issue and Option Report
Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
Representation ID: 2536
Received: 04/09/2017
Respondent: Hawksmoor
Our clients wholeheartedly support Strategic Option 1A. Given the unprecedented need for new housing, there can be no other option but to deliver a significant proportion of it on Green Belt sites within Black Country Authorities and their adjoining counterparts.
Comment
Black Country Core Strategy Issue and Option Report
Question 11b - If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employm
Representation ID: 2537
Received: 04/09/2017
Respondent: Hawksmoor
Our clients disagree with Strategic Option 1B. As noted in the Issues and Options document, this would be an extremely challenging option given the viability and delivery constraints of many of the brownfield sites and current employment landholdings in the Black Country. Furthermore, there is not the capacity available to provide sufficient land for the Black Country's growth needs.
Comment
Black Country Core Strategy Issue and Option Report
Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re
Representation ID: 2538
Received: 04/09/2017
Respondent: Hawksmoor
Our clients are generally supportive of this approach, so long as it not relied upon to deliver all of the housing need. Sustainable Urban Extensions (SUEs) will also be required to provide the necessary infrastructure to accommodate large areas of housing growth.
