Black Country Core Strategy Issue and Option Report

No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS). The consultation document confirms that the delivery approach outlined by the adopted BCCS is proving problematic with limited residential development being delivered in the Regional Corridors. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy. The BCCS was produced prior to the adoption of the Framework. The emerging BCCS is also being prepared in a significantly different economic climate to the adopted document. Furthermore, there have been a significant shift in the amount of housing and employment land informed by a new evidence base that is required that the revised BCCS needs to respond to. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted BCCS seeks to deliver development by focusing the majority of the housing and employment land requirement in the Growth Network and a series of Regeneration Corridors. It is, however, advised in the "Delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of residential in the Regional Corridors is "less than anticipated". Housing delivery in the Black Country has been boosted by the windfall sites.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it has transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites currently concentrated the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver these housing sites. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the housing allocation tests put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and there should be a realistic prospect that housing will be delivered on the sites. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted BCCS; by the emerging Core Strategies own omission.

It is, therefore, our view that the approach of the adopted BCCS in seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employment land. As a consequence, the emerging BCCS should adopt an approach that places less reliance on the delivery of housing on employment land.

A new strategy is required which will provide a range of sites on both brownfield and greenfield (including Green Belt) land which are capable of being delivered in the plan period and are attractive to the market and viable. These allocations should be made within the Housing Market Area generally, not just the Black Country, in order to provide a variety of housing sites in sustainable locations.

The Strategy should also be focused on identifying development sites that are deliverable within the plan period. It is, therefore, our view that the emerging plan should not place an overreliance on delivery from large scale urban extensions that have the potential not to be built out during the course of the plan period. Large scale urban extensions have extremely long lead in times and can take 10 years plus to be built out. It is, therefore, our view that the emerging plan should seek to direct development of sites that are deliverable within the plan period and there should not be an over reliance on large scale urban extensions.

This approach is entirely consistent with the requirement of the Framework. The Framework requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites should be "deliverable" and "available" in order to be allocated. The employment land led Regeneration approach of the emerging Core Strategy has failed this test at least to some degree. A more flexible and dispersed approach advocated by the Representator is a Framework compliant approach.

No, we consider that a more in depth analysis needs to be undertaken of brownfield land take up rates, particularly on the employment sites that are expected to deliver housing to ensure that they are a credible source of supply. It is not clear that the development industry will bring these sites forward as anticipated. The existing SHLAA fails to provide sufficient information on the suitability of these sites for development and their availability and viability to properly inform whether they are a realistic source of housing land supply.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the Preferred Options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Authorities to properly digest the findings of the Green Belt review and identify a strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

As a starting point we are concerned with the approach the SHMA has undertaken towards the HMA. It is advised that the SHMA does not seek to revisit the HMA but builds upon the work undertaken in establishing the Greater Birmingham HMA as part of the preparation of the Birmingham Development Plan. HMAs overlap. The HMA for Birmingham will not be exactly the same as that for the Black Country. The emerging SHMA should have at least tested whether the HMA boundary remains valid for the purposes of its assessment.

It should also be noted that the SHMA does not fully address affordable housing requirements. It is confirmed in paragraphs 7.26 to 7.29 of the SHMA that the National Planning Practice Guide requires a "policy on" calculation of the housing needs for certain groups of people. Affordable housing need is not a direct component of the demographic part of the objectively assessed needs assessment. The SHMA has not factored in affordable housing needs. It is advised in the SHMA that it is for the client Authorities to consider whether more new homes over and above the housing needs figure identified in the SHMA should be provided in the plan area to address affordable housing need through policy adjustments.

The Framework confirms at paragraph 159 that Local Authorities should develop SHMAs to inform their local plans. The SHMA should, amongst other things, "address the need for all types of housing, including affordable housing and the need for different groups in the community". This process has not been completed by the SHMA. It does not, therefore, provide a complete picture of housing need within the subject Authority areas. The SHMA is not in accordance with national guidance. The SHMA needs to be supplemented with additional information that factor in affordable housing requirements to establish a true objectively assessed housing needs figure.

Furthermore, there is a difference between the objectively assessed housing needs figure and the quantum of housing which should be allocated for development by the Plan. Not all housing sites deliver as expected. This is clearly evidenced by the existing BCCS where there has been significant under delivery in the Growth Network. As referred to in our response to Question 1, there is uncertainty regarding for delivery of a significant number of the housing allocation identified on the existing employment land by current Development Plan documents. It is necessary for former Core Strategy to identify housing requirement notably above the objectively assessed housing needs figure to take account of non-delivery of proposed housing allocations. At the present time, the Black Country Core Strategy has undelivered its housing requirement by approximately 11.6% (Appendix C - Black Country Monitoring Summary). An unexpected number if windfall sites have, however, bolstered supply using this as a proxy for delivery it is, our view that the finalised objectively assessed housing needs figure should be increased by a minimum of 20% to establish an overall housing requirement.

In terms of source of supply the current completion rates are significantly below what is required for even the current BCCS housing requirement. Taking the base SHMA housing requirement of 78,190 units over the plan period, results is an annualised requirement for 3,554 units per annum, which is far in excess of what has ever been achieved annually in the BCCS. In this context, we believe that it is going be important to significantly change the balance of the current supply with far greater reliance on greenfield/Green Belt sites.

We note that the overall supply from the urban area depends upon some 42,507 units from existing sites with a further 8,335 units from the urban area, much of which appears to be from employment sites. Given that the problems in delivering housing employment sites through the current strategy we consider that a Local Plan strategy which relies upon some 65% provision on urban brownfield/greenfield sites is wholly unrealistic.

In summary, the SHMA does not properly identify the housing requirement for the HMA. In addition, the reliance upon brownfield urban sites is not supported by evidence. There is, therefore, a requirement for a fundamental shift in the strategy of the plan with greater reliance placed upon Green Belt/greenfield land release in and around the wider HMA.

It is noted that there is a significant gap between the anticipated requirement for employment land and the supply of employment land. Approximately 300 hectares of new employment land is required during the plan period on unallocated sites. We have no particular concerns with the quantum of employment land identified and the recognition that it should be directed towards the Growth Network. Indeed, the emerging BCCS specifically advises that there are significant areas of employment land within the Black Country allocated for residential development that are now in an active and productive economic use. These locations should clearly be the preferred locations for employment land provision given that they are functioning and attractive employment sites.

This approach does, however, have clear implications for housing delivery. It is our view that the Black Country Authorities can no longer rely on significant new levels of residential development coming forward on employment sites. This further reinforces the Representor's view it is necessary for the emerging plan to look beyond the confines of the existing urban area and to deliver new residential development in sustainable locations on greenfield and Green Belt sites within the wider HMA.

We agree that a review of the Green Belt review is an imperative element of the new Core Strategy. As referred to above, it is our view that the Green Belt review should be prioritised so it is prepared in good time to inform the Preferred Options Consultation Core Strategy that is expected to be published in September 2018. The extent of the Green Belt review should be wide reaching. The Green Belt review should not just be focused on Green Belt land within the Black Country and immediately adjacent to it. A wide range of housing sites in a variety of locations within the HMA will be required to meet the significant housing shortfall identified by the emerging plan. The Green Belt review should examine the role that the Green Belt plays around the principle settlements within the HMA. In this regard we fully support the recognition that the Green Belt review should explore potential sites suitable for Green Belt land release within South Staffordshire. This should include the land surrounding the South Staffordshire's main settlements.

It is also our view that the Green Belt review should extend beyond the current plan period. Paragraph 83 of the Framework advises that once established Green Belt boundaries should only be altered in exceptional circumstances. When undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. When defining boundaries, Local Planning Authorities should, where necessary, identify areas of safeguarded land between the urban area and the Green Belt in order to meet long term development needs.

It is unlikely that significant new urban capacity will be found in the Black Country going ahead. Subsequent versions of the BCCS are likely to have to continue to rely upon Green Belt land release to meet the overall housing requirement. The Green Belt review and emerging plan should, therefore, look to identify land that can be removed from the Green Belt and safeguarded for development to meet development needs beyond the current plan period.

We respond to the identified key issues as follows:

* We agree the existing evidence base for the adopted BCCS is outdated. The adopted BCCS was based upon the requirements of the now revoked West Midlands Regional Spatial Strategy and is a pre Framework document. It was prepared in the middle of the economic downturn and its evidence base reflects these circumstances. There has been a fundamental change in the economy and significant changes to national and regional planning policies since the adoption of the Core Strategy. A selective review of the evidence base is not, therefore, appropriate. A comprehensive review of the evidence base is required.

* We agree that there is a need to continue to plan for a growing population. However, the SHMA underestimates the housing requirement as it does not taken into account affordable housing needs. Furthermore, the emerging plans housing requirement needs to take into account the fact that not all housing allocations deliver as expected. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and requirement for housing 22,000 dwellings is, therefore, less than that actually required.

* We note that evidence suggest that the economy is forecast to grow. This should be actively encouraged by the plan. The adopted BCCS relies upon significant new housing development on employment sites. Whilst these employment sites may have been largely vacant at the time and the preparation of the adopted BCCS, this situation has now changed. As demonstrated by the EDNA a number of these sites are now flourishing. The sites should, therefore, be protected for employment purposes and residential development directed elsewhere.

* We agree that the Green Belt review is essential to the emerging Core Strategy given the lack of urban capacity. We fully support the preparation of the Green Belt review. The Green Belt review should assess suitable development locations within the HMA generally in order to inform the emerging Core Strategy.

We are content with four of the five Core Strategy provisions and sustainability principles but the fourth bullet point "brownfield first" is no longer appropriate. Reliance on brownfield development will need to be significantly reduced. It is already acknowledged that at least 22,000 to 25,000 new dwellings may have to be allocated on greenfield/Green Belt sites. As referred to in above, we are of a view that the actual requirement is higher than this as the housing requirements should be in excess of the SHMA housing requirement which needs to be adjusted to take account of affordable housing needs. In addition, the housing requirements should exceed the objectively assessed housing needs figure as not all housing sites will deliver as expected. Furthermore, there is now evidence that a large number of the former employment sites allocated for residential development by the adopted Core Strategy are returning to employment use and are no longer available. Significant reliance will need to be placed on greenfield sites.

The brownfield first requirement is not in accordance with the guidance in the Framework. The Framework identifies 12 Core Planning Principles at paragraph 17. Here the Framework seeks to "encourage" the effective use of brownfield land. It does not, however, make it sequentially preferable to greenfield sites. The Framework acknowledges that there are instances where the development of greenfield land is preferable to brownfield sites for a variety of different reasons. This should be reflected in the emerging Plan.

We are concerned with Objective 3, which seeks to model sustainable communities on redundant employment land in the Regeneration Corridors. By the emerging Plans own admission, the Regeneration Corridors are now experiencing new in economic development. We therefore question the quantum of residential development that can actually be delivered on redundant employment land in the Regeneration Corridors. A comprehensive review should be undertaken of the role and allocation of the various Regeneration Corridors to properly establish what residential capacity they have. The Core Strategy should not be used as a mechanism for seeking to relocate existing and successful businesses that thrive within the identified Regeneration Corridors.

We agree that the policies should be revised. A Growth Network strategy will not provide the level of new housing and employment required by the emerging Core Strategy. The strategy needs to be amended to reflect the fact a significant proportion for housing and employment development will need to take place on greenfield/Green Belt sites outside of the current urban boundary and indeed, on sites outside of the BCCS administrative area.

The presumption in favour of using brownfield sites first also needs to be revised, as referred to above. The Core Strategy needs to provide a deliverable portfolio of residential and employment sites over the plan period.

We have no specific comments regarding the extent of the Regeneration Corridors. We do, however, believe there needs to be a fundamental review on the quantum and type of development each Regeneration Corridor should and can deliver. In particular, they should be re-examined to see if the existing employment sites are still suitable to be reallocated for housing development. Where the sites now perform an important economic role, they should be retained for employment purposes.