Black Country Core Strategy Issue and Option Report

Object

Representation ID: 3166

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

Whilst the evidence set out in Table 1 is comprehensive, SLR would question whether the content and findings of these documents would need to be updated following the completion of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study which was commenced in March 2017 and due to be completed in September 2017.

Support

Representation ID: 3167

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR supports the findings of the SHMA that there is a housing shortfall of 38,000 homes based on Birmingham's needs up until 2031 that cannot be accommodated within the City, even allowing for the proposals in the Plan to utilise land within the Green Belt (paragraph 3.10). The Strategic Housing Network Study (SHNS, completed in 2015) considered scenarios for distributing this housing shortfall. The study concluded that the supply of brownfield land across the HMA is insufficient and that the majority of this shortfall will need to be met on greenfield sites, including green belt outside Birmingham's administrative area.

SLR supports the premise that through the duty to cooperate there is a mechanism in place to explore new housing provision beyond the HMA where there are clear igration and commuting links. Notwithstanding, it is clear that there are opportunities to accommodate some of this shortfall on Green Belt sites within the Black Country that no longer meet the necessary purposes detailed within the NPPF.

Support

Representation ID: 3168

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

The Economic Development Needs Assessment (EDNA) has been developed for the area during 2016/2017 and it is highlighted that 90-170 ha of land in South Staffordshire (including the proposed West Midlands Interchange) has the potential to contribute towards meeting Black Country needs for employment
land. Notwithstanding, SLR would encourage any future SHMA to duly consider the needs of the EDNA in terms of both retaining existing employment land and ensuring that sufficient housing land is provided to meet the likely increase in population within the HMA as a result of any increase in economic activity.

Support

Representation ID: 3169

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

It is considered that the need 'to accommodate unmet housing needs', especially given the backlog experienced between 2011-2014 and the likely findings of the Greater Birmingham and Black Country HMA Strategic Growth Study, such a Green Belt Review is now entirely appropriate within both the Black Country and the wider HMA.

SLR duly requests that the Black Country Core Strategy Review consider our Client's site for suitability for release from the Green Belt and either allocation in the short term or a longer term safeguarding. Given that the site can form a strategic allocation, it has the ability to provide a significant quantum of development which could go toward meeting the housing need for the HMA.

Support

Representation ID: 3170

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR supports the use of collaborative working with adjoining local authorities, especially in meeting the housing needs of the wider HMA and the completion of a suitable and comprehensive Green Belt Review. The strategic priorities must be dealt with across local authority boundaries given the constrained nature of the Black Country and the significant levels of potentially suitable, available and deliverable Green Belt sites that could be released.

Support

Representation ID: 3171

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR agrees with the key issues identified within Section 3 of the Core Strategy Issues and Options Report. SLR would, however, suggest that weighting needs to be applied to those key issues which are considered to be more pressing in terms of growth and investment for the Black Country Core Strategy area. Indeed, SLR would suggest that the completion of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study is a key priority which would subsequently likely require a comprehensive review of both housing needs within the HMA and for the completion of a comprehensive Green Belt Review in collaboration with adjoining local authorities.

Support

Representation ID: 3172

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR agrees with the overall mantra of the Core Strategy vision and sustainability principals identified within Sections 4.3-4.5 of the Issues and Options document. Notwithstanding, as outlined above, SLR is of the view that there needs to be a comprehensive Green Belt Review both within the Black Country HMA and for adjoining local authority areas.

It is contended that any such Green Belt Review, Call for Sites and any subsequent SHLAA will identify potential housing sites that are more suitable, available and deliverable than those previously considered under the extant Core Strategy. These sites, whilst located within the Green Belt, may provide a more sustainable spatial and strategic solution to the housing needs of the HMA than at present.

Object

Representation ID: 3173

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

Whilst SLR agrees with the appropriateness of the majority of the spatial objectives, there is a need to consider rewording objective 3 to recognise that land will need to be released from the Green Belt to meet the housing need of the HMA both for the forthcoming Core Strategy and beyond.

Support

Representation ID: 3174

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR agrees that Policy CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network. SLR would suggest that the policies should be updated to reflect the findings of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study and any findings it may have that influence both housing needs within the HMA and the potential release of Green Belt land.

With regard to Policy CSP2, clear reference should be made to need for a comprehensive Green Belt Review, the release of sites for housing allocation and the safeguarding of sites for future needs beyond the plan period.

Object

Representation ID: 3175

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

There is no requirement to update the boundaries of the Regeneration Corridors as they are fit for purpose and meet their intended purpose of encouraging growth within these areas. Notwithstanding, it is appreciated that evidence currently suggests that 22-25,000 new homes and 300ha of new employment land will be required outwith of these Regeneration Corridors, especially given the likely increase cost for releasing, remediating and developing brownfield sites within these areas. Indeed, the Issues and Options document has already identified that Green Belt land will need to be released to meet housing need up to 2036.