Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 50a - Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
Representation ID: 620
Received: 08/09/2017
Respondent: IM Properties
Agent: Harris Lamb
We believe that Policy EMP1 should provide a net employment land target in order to allow for losses to alternative uses to be taken into account.
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Black Country Core Strategy Issue and Option Report
Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?
Representation ID: 621
Received: 08/09/2017
Respondent: IM Properties
Agent: Harris Lamb
We would not encourage this as a design approach in the Black Country. Garden City proposals were developed expressly for new settlements. The Black Country has a different history and heritage as do the settlements that are geographically and functionally close to the Black Country. We do not consider the vernacular of the existing urban area and adjoining settlements appropriate for Garden City principles.
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Black Country Core Strategy Issue and Option Report
Question 98 - Do you support the proposed changes relating to Design Quality? Yes/No; If you think that any other changes should be made to Policy ENV3 please provide details.
Representation ID: 622
Received: 08/09/2017
Respondent: IM Properties
Agent: Harris Lamb
The introduction of the Nationally Described Space Standard has implications for viability since it introduces a significant additional cost to new house building without necessarily any uplift in values. It can, therefore, reduce the ability of schemes to provide other planning obligations. We, therefore, suggest it is removed.
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Black Country Core Strategy Issue and Option Report
Question 99c - Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropria
Representation ID: 623
Received: 08/09/2017
Respondent: IM Properties
Agent: Harris Lamb
In the context of our response to Question 98, we do not agree that National Space Standard should be introduced.
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Black Country Core Strategy Issue and Option Report
Question 101a - Do you support the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects? Yes/No; Further comments?
Representation ID: 624
Received: 08/09/2017
Respondent: IM Properties
Agent: Harris Lamb
Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications on site layout and viability do need to be considered. A flexible approach is required from the Local Authorities in assessing individual schemes taking into account matters such as viability and effects on density. In particular, a joint approach is needed by statutory undertakers to ensure that SuDS areas can be adopted if they are provided as part of wider open space areas.
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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: 663
Received: 08/09/2017
Respondent: IM Properties
Agent: Turley Associates
The Spatial Strategy therefore needs to be comprehensively reviewed and rethought. Others will make the case (including our subsidiary company IM Land) for a review of the Green Belt in order to accommodate a minimum of 14,270 dwellings which cannot be accommodated within the urban area, even allowing for an increase in urban capacity of 10,000 dwellings. This assumes the redevelopment of some existing industrial sites within the urban area for residential use.
Comment
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: 3026
Received: 08/09/2017
Respondent: IM Properties
Agent: Turley Associates
Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March 2012. It is based on circumstances and needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change in plan making.
2.2 The West Midlands Combined Authority's Strategic Economic Plan ('WMCA SEP') (June 2016) provides a city-regional perspective on economic growth and the consequential need for more housing. It envisages an additional 50,000 jobs across the West Midlands by 2030 over and above the 450,000 assumed in the current plans of the 3 LEPs and their constituent Councils, including the Black Country. This also has consequences in terms of housing, with 215,000 homes needed over the same period, about 50,000 more than in the current evidence base underpinning local plans.
2.3 Furthermore, the vision of the WMCA SEP is built on the premise of delivering an extra 1,600 hectares of brownfield land for "first class employment land of national significance", which the Black Country will play a crucial role in meeting. With concerns on the viability and size of regenerating brownfield land for employment uses of "national significance", it is imperative that the Black Country Authorities also assess greenfield land to deliver strategic employment sites.
2.4 This scale of ambition, which underpins the devolution deal which established the WMCA and is founded upon rebalancing the national economy, major investment in new infrastructure, including HS2 and its Connectivity Package to all parts of the West Midlands, the focus of the Midlands Engine and the Government's Industrial Strategy, will transform the Black Country over the next 15-20 years.
2.5 The Spatial Strategy therefore needs to be comprehensively reviewed and rethought. Others will make the case (including our subsidiary company IM Land) for a review of the Green Belt in order to accommodate a minimum of 14,270 dwellings which cannot be accommodated within the urban area, even allowing for an increase in urban capacity of 10,000 dwellings. This assumes the redevelopment of some existing industrial sites within the urban area for residential use.
2.6 The counterpoint is that the local economy, whilst sustained on many smaller businesses which rely on urban locations, requires modernisation and the ability to attract inward investment, both within the Enterprise Zones and in new locations which are highly accessible and attractive to modern occupiers. This will require a thorough review of employment land supply, its suitability to meet modern requirements and
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market demand, and the potential for new sites to be identified which may require Green Belt release.
2.7 In this regard, a study of Strategic Employment Sites in 2015 (by PBA/JLL) on behalf of the West Midlands Local Authority Chief Executives group identified the need for a second stage of work to address what it concluded was an impending shortage of major employment sites. This reflects the policy vacuum since the demise of the WMRSS which had a suite of policy responses to identify Regional Investment Sites and Regional Logistics Sites. As current sites are used up, there is no policy response in preparation. IM Properties Limited has raised this as a matter of urgency with the LEPs within the WMCA area and proposed a brief for a second stage of work.
2.8 It is positive therefore to see in the WMCA Land Delivery Action Plan being considered at the WMCA Board on 8 September that a number of strategic studies are proposed, including one to review "modern business requirements". It is disappointing however that this falls short of a commitment to the second stage of the Strategic Sites Study but is however a positive direction of travel. This work should align with and provide strategic context for the further evidence base work required to support the Black Country Core Strategy Review.
2.9 A full review of the BCCS is therefore essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs.
* All policies and objectives of the emerging BCCS Review are consistent with national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the shortcomings of the adopted BCCS.
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: 3027
Received: 08/09/2017
Respondent: IM Properties
Agent: Turley Associates
See response to Q1 in respect of employment studies. This will also need to be supplemented by appropriate work on strategic infrastructure.
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: 3028
Received: 08/09/2017
Respondent: IM Properties
Agent: Turley Associates
The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.
2.12 As part of this, the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
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2.13 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.
2.14 The methodology for the Strategic Locations Study, made available in July 2017, is very broadbrush and it is currently unclear if the strategic nature of the study will be repeated by the Black Country review or a more fine-grained approach taken which uses the Strategic Locations Study as a fixed starting point.
2.15 Furthermore, the Strategic Locations Study is premised on addressing the shortfall in housing supply with no equivalent assessment of how much employment land is needed. The review would be fatally flawed in our view if it proceeds without a clear understanding of the need for development including both housing and employment.
Comment
Black Country Core Strategy Issue and Option Report
Stage 1: Strategic Options 1A and 1B - the role of the Growth Network
Representation ID: 3030
Received: 08/09/2017
Respondent: IM Properties
Agent: Turley Associates
Q11a. Do you support Strategic Option 1A? Yes / No; If yes, please explain why. 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 employment areas be?
There is a need for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both will require significant new land and infrastructure to support this level of growth, and this will require a different spatial strategy to the current one.
2.17 There is currently a deficit of 57 ha gross of employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality employment land. This does not distinguish between different types of employment, including different use classes and size or characterisation.
2.18 The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas and provide the backbone of the Black Country economy. In some cases, their loss to residential would negatively impact business in the area and remove local, sustainable job opportunities. Whilst there is pressure for increasing residential capacity and density within the existing urban area, care needs to be taken in ensuring a balance of what constitutes a sustainable pattern of development.
2.19 Further employment land supply evidence is required to achieve this balance between protecting smaller urban sites and the need as identified in our response to Q1 to provide larger high quality sites to meet the needs of modern industries and new operators, and their requirements for better accessibility to markets. This will facilitate the redevelopment of some urban sites for housing, but the Black Country faces choices with an overall employment land deficit of 300 ha and growth ambitions which will not be met simply by the regeneration of constrained urban sites. A number of larger employment allocations in more accessible locations will be needed.
