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: 1124
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
Yes. Paragraph 153 of the National Planning Policy Framework (NPPF) states that each local planning authority should produce a Local Plan for its area and that this can be reviewed in whole or in part to respond flexibly to changing circumstances. Furthermore, the Planning Practice Guidance (PPG) identifies that for plans to remain effective, they need to be kept upto-date. The PPG highlights that policies will age at different rates depending upon local circumstances and that most local plans are likely to require updating in whole or in part at least every five years.
Overall Gallagher Estates support the partial review of the existing Core Strategy, subject to the above being achieved.
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Support
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: 1134
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
Overall Gallagher Estates support the partial review of the existing Core Strategy, subject to the above being achieved.
In particular, Gallagher Estates are supportive of the preparation of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study and the Black Country Green Belt Review. However, it is important to note that a methodology for the Green Belt Review has yet to be published.
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Object
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: 1139
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
No. Whilst Gallagher Estates support the on-going joint working between the Black Country Local Authorities and South Staffordshire District Council, Gallagher Estates do not agree with the identified Objectively Assessed Housing Need (OAHN) set out in the Black Country and South Staffordshire Strategic Housing Market Assessment (SHMA) (March 2017). Accordingly, Barton Willmore LLP's National Research Team have prepared a Housing Need Technical Review of the Black Country and South Staffordshire SHMA (attached at Appendix 3). The Housing Need Technical Review has been prepared in the context of the NPPF and the stepped approach prescribed by the PPG's OAHN methodology.
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Support
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: 1142
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
Yes. Gallagher Estates agree with the proposed approach to the Black County Green Belt Review. Gallagher Estates welcome and support that the Green Belt Review will be carried out in conjunction with South Staffordshire, particularly given the strong housing market links that the Black Country and South Staffordshire share.
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Object
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: 1143
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
No. Whilst Gallagher Estates broadly agree with the key issues set out in Part 3 in the Issues and Options Consultation Document, it is also considered that the key issues should place further emphasis upon the need to deliver sufficient housing for the Black Country and the wider HMA, as well as to meet some of Birmingham's housing shortfall.
One of the key issues is that the current evidence base is out of date and does not provide a sound basis to underpin the Black Country Core Strategy Review. Accordingly, Gallagher Estates support a review and update of the evidence base.
The Issues and Options Consultation Document at Paragraph 3.61 notes that another key issue is the growing population and that 'there is a gap between the need and anticipated supply of around 22,000 homes and there is a need to look beyond the existing Growth Network to meet
it'. This key issue is supported and it is also agreed that a large number of homes and supporting services will need to be accommodated outside the existing urban area of the Black Country which is currently designated as Green Belt.
Accordingly another key issue is the Green Belt, and the Issues and Options Consultation Document acknowledges that there has not been a strategic Green Belt Review in the Black Country since the 1970s and that it is inevitable that Green Belt land will be needed to accommodate the long-term development needs.
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Object
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: 1144
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
No. Whilst Gallagher Estates recognise that the Visions is based upon the three dimensions to sustainable development as set out at Paragraph 7 of the NPPF and broadly support the majority of specific sustainability principles, Gallagher Estates do not support the fourth principle 'putting brownfield first'. The specific sustainability principles include:
1. Facing up to climate change;
2. Sustainable development;
3. Social inclusion;
4. Putting brownfield first; and
5. A comprehensive approach to development.
With regard to the fourth sustainability principle, putting brownfield first, we acknowledge that
the effective use of brownfield land should be encouraged in line with Paragraphs 17 and 111 of the NPPF. However, it is important to note that the NPPF does not state that brownfield land should be put first. It is also clear that the Government and the West Midlands Combined Authority (WMCA) are prioritising development on brownfield land. However, the SHNS Stage 3 Report (August 2015) recognises that the Black Country has a good supply of brownfield
land.
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Object
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: 1146
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
No. Whilst Gallagher Estates broadly agree that these remain appropriate, Gallagher Estates do not agree with Spatial Objective 3 which currently states:
"Model sustainable communities on redundant employment land in the Regeneration Corridors".
It is considered that Objective 3 is out of date and needs to be amended to reflect the significant need to deliver sufficient land to accommodate the housing needs of the Black Country as well as Birmingham's unmet housing need. As highlighted in Key Issue 6 of the Issues and Options Consultation Document, the significant housing need within the Black Country and the wider HMA will require the identification of new sites on land outside the urban area, of which the majority are currently located within the Green Belt. Furthermore, as stated in our response to Question 7, the supply of brownfield land is finite and cannot be relied upon to the extent currently assumed to meet the identified housing need. It therefore needs to be recognised that sustainable communities cannot just be provided on employment land within the Regeneration Corridors and that greenfield sites will also need to be
development to support sustainable communities.
It is therefore requested that Strategic Objective 3 is revised to acknowledge that sustainable communities will also need to be provided on sustainable Green Belt release sites, in accordance with the amended spatial strategy.
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Support
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: 1147
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
Yes. Gallagher Estates support Strategic Option 1A which seeks to continue and strengthen the Growth Network with some corridors being housing led and others employment led, and with the remaining housing and employment land growth to be accommodated in the Green Belt. Gallagher Estates do not support Strategic Option 1B which seeks to restructure the existing Growth Network, with more occupied employment land being redevelopment for housing in the Regeneration Corridors and the remaining housing and employment land growth, and replacement employment land, to be accommodated in the Green Belt.
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Object
Black Country Core Strategy Issue and Option Report
Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re
Representation ID: 1149
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
No. Spatial Option H1 seeks to 'round off' the edge of the Green Belt, including internal Green Belt wedges, to release a large number of small to medium sized sites for housing. Gallagher Estates consider that Spatial Option H1 cannot be relied upon alone to deliver sufficient housing
in sustainable locations that is required in the Black Country and to meet the needs of the wider HMA. This view is supported by the Issues and Options Consultation Document, which identifies that Spatial Option H1 would not meet all of the required housing need. Therefore,
to ensure that sufficient housing is delivered to meet the needs of the Black Country and the wider HMA, it is considered that the development of Sustainable Urban Extensions (SUEs)outside of the urban area are also required.
Overall, it is considered that the allocation of SUEs is needed in order to accommodate significant housing growth outside of the urban area.
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Support
Black Country Core Strategy Issue and Option Report
Question 13a - Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibi
Representation ID: 1150
Received: 08/09/2017
Respondent: Gallagher Estates
Agent: Barton Willmore
Yes. Gallagher Estates support Spatial Option H2, a more focussed approach, which seeks to release land from the Green Belt to allocate a limited number of SUEs across the Black Country (including cross boundary options) in the most sustainable locations which are already or have the potential to be well served by infrastructure.
The need for housing is emphasised by the NPPF and Paragraph 17 encourages and supports sustainable economic development to deliver the homes that the country needs. A key objective of the NPPF is to deliver a wide choice of high quality homes. Paragraph 47 states that to boost
significantly the supply of housing, local planning authorities should identify key sites that are critical to the delivery of the housing strategy over the plan period.
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