Black Country Core Strategy Issue and Option Report

We consider that Option 1A is to be preferred to strategic Option 1B. That said, we believe there continues to be an over reliance upon brownfield/greenfield sites in the existing housing supply and there is also an over reliance on brownfield windfalls in estimating further housing supply. We consider that overall the greenfield requirement should be increased to ensure delivery. Greenfield sites are typically less constrained than their brownfield alternative and, unlike a significant number of its active employment sites allocated for housing by the adopted Core Strategy; they are available for development now.

We do not support Option 1B. We believe it places an over reliance on brownfield/windfall sites and there is no real certainty that further employment land can be released over the plan period to provide housing opportunities. Indeed, current evidence would appear to suggest that a number of existing residential allocations in the emerging Core Strategy on former employment sites should be reallocated for employment development.

In this context, we consider that Option 1B would not meet the objectives of the housing policies of the Framework, particularly those that require the planning system to "boost significantly" the supply of housing land and to ensure that the allocations are deliverable and developable in the context of the requirements of paragraph 47 of the Framework.

We believe a combination of Options H1 and H2 will be required to deliver the significant housing requirement of the emerging Core Strategy. A range of sites of a variety of different sizes should be identified for development in sustainable locations within the HMA. Identifying a range of sites in a variety of different locations will help create the choice and competition of the market for land and ensure delivery. It must be ensured that any proposed urban extensions are deliverable within the plan period. It is, therefore, necessary to understand the infrastructure requirements, likely delivery rates and the ability of sites delivered quickly when making allocations.

As referred to above, we are of a view that a variety of different sites should be allocated for development to meet the growth requirements of the Black Country to provide choice and competition in the market for land. These sites should be located throughout the HMA. In particular, it is our view that it will be entirely appropriate to direct development towards sustainable settlements in the South Staffordshire District part of the HMA. South Staffordshire is included within the SHMA assessment area given its close ties to the Black Country Authorities. There are a number of settlements within South Staffordshire and a range of services and facilities that are capable of supporting relatively significant levels of development to meet the needs of the Black Country. These areas should be considered for allocation.

As referred to above, it is our view the combination of sites of a variety of different sizes in a number of different locations should be allocated for development to meet the growth requirements of the Core Strategy.

It will clearly be necessary for sites to be released for development outside of the Black Country administrative area to meet the housing employment requirements of the emerging Core Strategy. The SHMA identifies South Staffordshire as having a close functional relationship to the Black Country Authorities. It is, therefore, our view that it will be entirely appropriate for additional development to be directed towards the principal settlements within South Staffordshire to assist in meeting the growth requirements of the Black Country. In assessing the preferred locations for the development to meet the requirements of the Black Country, regard should be had to a range of different factors including those identified in Question 15a.

There may be areas of land where there is a need for change. Site specific circumstances will need to be taken into account in identifying whether it is appropriate to allocate a site for housing and/or employment development when it is known that an existing use is likely to cease.

Policy DEL1 needs to be revised given that it is now accepted that development will be required in the Green Belt. Policy DEL1 also needs to recognise that development will need to take place outside of the Black Country administrative area to meet the significant housing and employment requirements put in place by the plan.

We suspect that generally speaking there will need to be an incremental improvement of social infrastructure provision to meet the requirements of occupants of new developments over and the plan period. This should inform the identification of sites and the review of the Growth Network. Sites that can be delivered and take advantage of existing social infrastructure should be prioritised for allocation above sites that have significant infrastructures required. In short, development should be favoured where it has good access to a range of services and facilities. For example, where development is directed towards South Staffordshire settlements, priority should be given to sites that have the greatest range of services and facilities.

We have commented previously that the new BCCS will need to shift the emphasis away from urban regeneration towards a more balanced provision of brownfield and greenfield sites. Part of the problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now being given a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

We should add that in our experience of working of the Black Country Local Authorities do need to understand the constraints to developing in the Black Country, particularly in respect of highways and urban design standards. Many of the existing allocations are difficult to develop and the Council will need to apply development management considerations flexibly in order to ensure the site can come forward. Many brownfield sites present physical and topographical challenges which can influence the formation of layout and design solutions. All of these are factors which should be taken into account when identifying sites for development and determining subsequent planning applications.

Our concern is that it takes a considerable amount of time to make funding available for new development and this is holding back sites from being released. Furthermore, it cannot be guaranteed that funding which is provided now will continue to be available during the plan period. In this context, it is important to ensure that there is a balanced supply of housing provided; taking into account that intervention funding may not always be available. We suggest that a greater proportion of development should be directed towards greenfield/Green Belt sites that are less likely to require intervention.