Black Country Core Strategy Issue and Option Report

Search representations

Results for Iceni Projects search

New search New search

Comment

Black Country Core Strategy Issue and Option Report

1. Introduction

Representation ID: 2707

Received: 08/09/2017

Respondent: Iceni Projects

Representation Summary:

The Issues and Options consultation is the first stage of the review of the Black Country Core Strategy. The Core Strategy is a key part of the Local Plan for the Black Country Local Authorities which covers
4
the areas of Dudley Metropolitan Borough Council (MBC), Sandwell MBC, Walsall Council and the City of Wolverhampton Council.
The existing Core Strategy was adopted in 2011, covering the period up to 2026. Upon adoption, in accordance with national planning guidance, it was agreed that the Core Strategy would be reviewed in whole or in part at least every five years.
Since adoption there has been a number of changes to national policy, furthermore a housing shortfall has been identified in Birmingham which neighbouring authorities, notably the Black Country, have a duty to consider accommodating.
The Council state that although the Core Strategy is considered generally fit for purpose, this consultation stage will identify emerging issues and set out how the sustainable growth of the Black Country can be achieved.
The documents which make up the current evidence base for this consultation exercise, and are of key relevance to these representations, are set out as follows:
 Black Country and South Staffs Strategic Market Housing Assessment - March 2017; and
 Greater Birmingham and Solihull LEP Black Country Local Authorities Strategic Housing Needs Study - August 2015
Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services, such as open space, shops, schools and healthcare, are provided.

Comment

Black Country Core Strategy Issue and Option Report

Key Issue 2 - Meeting the housing needs of a growing population

Representation ID: 2709

Received: 08/09/2017

Respondent: Iceni Projects

Representation Summary:

The Black Country and South Staffs Strategic Market Housing Assessment (SHMA) 2017 concluded that the Objectively Assessed Housing Need (OAN) for the Black Country over the period 2014-36 is 78,190 homes. It is anticipated that the housing supply, identified in the SHLAA, can deliver 48,185 of the homes needed, approximately 60%. Identified sites and "windfall" sites could deliver approximately 8,000 homes. Initially, there is a gap between need and anticipated supply of around 22,000 homes across the Black Country.
The Greater Birmingham and Solihull LEP Black Country Local Authorities Strategic Housing Needs Study identifies a shortfall across the wider Housing Market Area (HMA) of approximately 38,000 dwellings.
The Black Country have committed to test the accommodation of an extra 3,000 homes up to 2031 beyond local need, to help address the shortfall in the wider HMA. This produces a total requirement for land to accommodate 24,670 new homes.
Given the foregoing, the Council acknowledge that a large number of new homes and supporting services will need to be accommodated outside the existing urban area of the Black Country. All such land in the Black Country is currently Green Belt.
Paragraph 3.15 of the Issues and Options Consultation document identifies that there may be potential to release limited areas of surplus open space for housing in some areas. The existing Goscote House site (Parcel A and B) could deliver 49 residential units.
5
In addition to this the vacant plot (Parcel C) could provide care-home uses comprising 5,600 sqm over 2 floors, and/or additional residential accommodation.
Needs of the ageing population
The SHMA provides guidance on the likely needs of different groups for housing over the new Plan period.
As set out within the Black Country Issues and Options Consultation, in addition to the SHMA, a key factor in household growth is that people are on average living longer than previous generations.
In particular, paragraph 6.30, of the Issues and Options Consultation, highlights a need for 162 new sheltered and extra care homes every year to meet the needs of older persons - 5% of the total housing need.
Utilisation of this site for the provision of care home uses, would contribute towards this need. Furthermore, a large percentage of the Black Country's ageing population rely on living within easy walking distance of healthcare. It is therefore important to locate new homes in areas with good access to existing healthcare and community services or where new, sustainable facilities can be created to serve new development.
Policy Area A, of the Issues and Options Consultation, focuses on Health and Wellbeing. Paragraph 6.10 stipulates that accessibility to health care and community facilities must be addressed in terms of location and physical access.
Accordingly, it is considered that redevelopment of this site, the provision of residential units, and or the provision of care home uses, would seek to achieve the objectives of Policy Area A. Furthermore, such redevelopment would meet the needs of the Black Country's ageing population, maintaining accessibility to existing health care.

Comment

Black Country Core Strategy Issue and Option Report

Key Issue 6 - Reviewing the role and extent of the green belt

Representation ID: 2710

Received: 08/09/2017

Respondent: Iceni Projects

Representation Summary:

As set out above, evidence has identified that a significant amount of Green Belt will be required to help meet the housing need within the Black Country and the wider HMA. Given this, is has been decided that a formal review of the Black Country green belt should be carried out through the Core Strategy review.
In this instance, two studies have been commissioned. The evidence base for Key Issue 6 will comprise:
 Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study; and
 Black Country Green Belt Review.
We expect that the two studies together will provide a robust and thorough examination of the green belt to assess and identify the potential to release sites from the green belt, alongside growth within the urban area, to meet the projected needs identified for housing and employment growth up to 2036.
This site is located within the Green Belt. Given the existing built form, the land at Goscote Hospital which falls within the red line boundary, constitutes previously developed land within the Green Belt.
It is evident, as set out below, that the site in its entirety, encompassing the existing health and social care facilities, does not serve the five purposes of the Green Belt. Accordingly, these representations seek the release of the entire site from the Green Belt.
Given the Evidence Base for the Black Country Issues and Options document, it is apparent that extra homes required across the Black Country will need to be built on Green Belt land.
6
Paragraph 1.19, of the Issues and Options Consultation document, seeks to ensure that that any release of green belt sites for development does not take place at the expense of urban regeneration. Given the characteristics of this site, this is not a concern which should be associated with future development in this location, as small scale redevelopment would ensure that the characteristics of this area are retained.
The NPPF identifies that Green Belt serves five purposes:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Green Belt is central to the Black Country Core Strategy. It is considered, that when assessing the function this site performs within the Green Belt, it is very low.
The sites natural boundaries, prevent future development from unrestricted sprawl and the countryside from encroachment. Given the sites location, redevelopment would not result in neighbouring towns merging together. Furthermore, redevelopment of this site, given its existing built form would encourage the recycling of derelict land, which should take preference over untouched green belt land.
Accordingly, when reviewing release of land from the Green Belt, given the foregoing, it is sites such as this which should be considered first

Comment

Black Country Core Strategy Issue and Option Report

Stage 2: Strategic Options 2A and 2B - Housing and Employment outside the urban area

Representation ID: 2711

Received: 08/09/2017

Respondent: Iceni Projects

Representation Summary:

Reviewing the Spatial Strategy
Strategic Option 2A seeks to accommodate housing growth outside the urban area. Within this option, two broad Housing Spatial Options have been identified.
Spatial Option H1
Spatial Option H1 is based on 'round off' the Green Belt edge. It is considered that this could be done by way of a large number of small to medium size sites.
We consider that this is a suitable option for future growth of the Black Country, specifically Walsall. It is anticipated by the Council that sites could range in size from a few homes to hundreds of homes, where this would provide a defensible new green belt boundary and sufficient services exist. Furthermore, identifying large and medium sites would not require significant infrastructure, and would be deliverable in a lesser time period.
The site at Goscote Lane should be identified as one of such sites, given that it adjoins the existing built up area and contributing to the housing need of Walsall and the Black Country. This site is available, achievable and deliverable.
Spatial Option H1 would provide for development to take place within the urban area closer to where need arises.
Spatial Option H2
Spatial Option H2 seeks to identify a limited number of large scale Sustainable Urban Extensions (SUEs). It is considered by the Council, that such an option would significantly boost the supply of housing and maximise provision of affordable housing.
7
Given that no SUEs are currently being promoted in the Black Country it is considered that a significant level of work would be required in order to identify suitable locations. Consequently, such sites would require a range of infrastructure and services.
It is considered that Spatial Option H2 would concentrate delivery later in the plan period, and place a heavy reliance on a limited number of large sites.
In our view, exploring both options H1 and H2 would seek to ensure housing is delivered across the Black Country in the short and long term. Both options would promote wider choice and opportunity within the housing market and allow diversification of the housing stock.
In utilising both spatial options, housing units could be delivered in the short term, building upon existing infrastructure. Whilst locations could be identified for SUE's and understand the need, timing and cost of the range of infrastructure and services required.

Need help completing this? Click here for our simple user guide.