Black Country Core Strategy Issue and Option Report

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Black Country Core Strategy Issue and Option Report

Question 13c - Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?

Representation ID: 1152

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Yes. Gallagher Estates have submitted land at Yieldfields Farm on the edge of Bloxwich as part of the Call for Sites exercise which runs alongside this Issues and Options consultation.

As outlined in our response, the Site comprises approximately 122 hectares of land that lies over the two administrative authorities of South Staffordshire and Walsall. The Site is currently located within the Green Belt and provides the opportunity to deliver a total of approximately 2,000 new homes alongside local community facilities and infrastructure. Further details of the Site are provided in the submitted Development Framework Document

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Object

Black Country Core Strategy Issue and Option Report

Question 13d - Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details

Representation ID: 1154

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

No. Gallagher Estates consider that detailed guidance for the development of SUEs should be determined by the individual local planning authorities which take account of the local circumstances and requirements for that District or Borough.

Paragraph 50 of the NPPF states that to deliver a wide choice of high quality homes, widen opportunities for home ownership and create a sustainable, inclusive and mixed communities,local planning authorities should:

* Plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in community (such as, but not limited to,
families with children, older people, people with disabilities, service families and people wishing to build their own homes); and
* Identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand.

As such it is considered that the detailed guidance for the development of SUEs should be determined by Local Authorities in order to assess the particular locations of sites and to reflect local demand.

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Comment

Black Country Core Strategy Issue and Option Report

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

Representation ID: 1155

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Gallagher Estates consider that the BCCS should endeavour to meet their full objectively assessed housing need for market and affordable housing before any unmet housing need is exported to neighbouring authorities.

As stated in our response to Question 3, Gallagher Estates are supportive of the cross-boundary working between the Black Country Authorities and South Staffordshire District Council. The housing needs of the Black Country and South Staffordshire have jointly been assessed as part of the evidence for the Review.

Gallagher Estates are concerned that if housing growth is exported on a large scale to local authorities such as Telford and Stafford, that these locations would not help meet the housing requirement of the Black Country as well as Birmingham's unmet need. Therefore it is considered that the Black Country Local Authorities should endeavour to meet their full OAHN.

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Support

Black Country Core Strategy Issue and Option Report

Question 15b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.

Representation ID: 1156

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Yes. Gallagher Estates' site at Yieldfields Farm represents a sustainable and logical extension to Bloxwich and has the capacity to deliver 2,000 homes. The Site has been submitted as part of the Call for Sites exercise which runs alongside this Issues and Options Consultation. The Site covers approximately 122 hectares of land that currently falls within the Green Belt. The Site has good accessibility to a range of sustainable modes of transport, including Bloxwich North Railway Station, as well as the surrounding road network.

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Support

Black Country Core Strategy Issue and Option Report

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

Representation ID: 1157

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Yes. Gallagher Estates support adopted Core Strategy Policy DEL1.

Whilst the allocation of Green Belt release sites for SUEs may require additional infrastructure and community services and facilities, it is considered that these contributions can continue to be provided through Section 106 Agreements and the Community Infrastructure Levy. Accordingly, it is considered that adopted Policy DEL1 should be updated to be more explicit to ensure that 'all new developments' cover Green Belt release sites as well as sites located within the existing urban area.

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Object

Black Country Core Strategy Issue and Option Report

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

Representation ID: 1159

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

No. Gallagher Estates do not support possible phasing of brownfield sites. It is recognised that the development of brownfield land needs to be encouraged in line with Paragraphs 17 and 111 of the NPPF. However, as stated in our response to Question 7, the findings of the SHNS Stage 3 Report (August 2015) identify that brownfield land cannot be relied upon alone to meet the identified housing need. Furthermore, it is considered that brownfield sites are notoriously slow to deliver and that most viable sites have already been delivered. Therefore, Policy HOU1 must recognise that greenfield and Green Belt release sites will need to be relied upon in order to help meet the housing needs of the Black Country and the wider HMA.

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Object

Black Country Core Strategy Issue and Option Report

Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and

Representation ID: 1162

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

No. Adopted Core Strategy Policy HOU2 states that the density and type of new housing providing on each site will be informed by the need to achieve high quality design and minimise amenity impacts, taking into account the characteristics and mix of uses in the area where the proposal is located. Policy HOU2 also states that all developments will aim to achieve a minimum net density of 35 dwellings per hectare, except where higher densities would prejudice historic character and local distinctiveness as defined in Policy ENV2.

In light of the above, it considered that the current standard for 35 dwellings per hectare could be difficult to apply to Green Belt release sites due to the urrounding landscape setting and characteristics. It is therefore suggested that minimum densities of 30 dwellings per hectare should be sought for Green Belt release sites. Higher densities could be delivered where it is sensible and reasonable to do so, but this must take into account the landscape and visual opportunities and constraints related to the site.

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Object

Black Country Core Strategy Issue and Option Report

Question 41a - Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:

Representation ID: 1226

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Gallagher Estates acknowledge that the Black Country Local Authorities have a requirement to deliver a wide range of accommodation, including self-build and custom housebuilding. However, Gallagher Estates do not support a specific policy being introduced into the Core Strategy that requires larger housing sites to provide a proportion of serviced plots self-build and custom housebuilding. Instead, it is suggested that the Black Country Local Authorities seek to: deliver self-build and custom housebuilding through small-scale allocations; use their
own land where possible for self-building and custom housebuilding; and work with custom build developers to maximise opportunities for self-build and custom housebuilding.

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Object

Black Country Core Strategy Issue and Option Report

Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.

Representation ID: 1227

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

No. The Issues and Options Consultation Document identifies that one of the options to increase affordable housing delivery would be to introduce an increased affordable housing requirement for Green Belt release sites, where such an increase is suggested to be more financially viable. However, Gallagher Estates do not agree that an increased affordable housing requirement should be set for Green Belt release sites.

Green Belt release sites are likely to be subject to increased costs, such as those related to the provision of infrastructure and local services and facilities. As such, the viability of residential developments is an important factor that should be taken into account when determining the level of affordable housing provision to be provided. This matter is strongly supported at Paragraph 173 of the NPPF.

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Support

Black Country Core Strategy Issue and Option Report

Question 89 - Do you support the proposed changes to the priorities for the development of the transport network? Yes/No; Please explain why.

Representation ID: 1228

Received: 08/09/2017

Respondent: Gallagher Estates

Agent: Barton Willmore

Representation Summary:

Yes. Gallagher Estates broadly support the proposed changes to the priorities for the development of the transport network. In particular, Gallagher Estates support the priority which seeks to improve existing railway stations and provide new railway stations to meet demand.

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