Black Country Core Strategy Issue and Option Report

Support

Representation ID: 3236

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR agrees with the proposed changes relating to Flood Risk, Sustainable Drainage and Urban Heat Island effects.

Support

Representation ID: 3237

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

The policy is already in accordance with national guidance and therefore is considered appropriate for inclusion within the forthcoming Core Strategy. SLR has no comments to make in response to this question.

Object

Representation ID: 3238

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

Current requirements are considered to be in accordance with national standards. Any further increase would likely result in the delivery of a housing site becoming more expensive to build and may not be achievable for many sites within the HMA. The introduction of such requirements could result in a further backlog in the provision of housing needs within the HMA, thereby failing to ensure that the Black Country delivers the housing numbers required over the plan period and placing non-allocated sites at risk of development.

Support

Representation ID: 3239

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

The approach to updating and amending Appendix 2 and Tables 2 and 3 of the existing Core Strategy is appropriate. This will need to take account of 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 needs within the HMA and the potential release of Green Belt land in collaboration with adjoining local
authorities. SLR does, however, view that it would be more sustainable to accommodate housing allocations
within the Green Belt rather than larger employment land sites.

Finally, consideration must be given to the deliverability of larger housing sites within the Growth Networks and Regeneration Corridors, especially given the constrained nature of these sites and their longer term timescales for release. The Core Strategy has already identified that there have been significant delays to bringing forward such sites given the costs of land assembly and remediation. As such, there will need to be an interim solution to meet short term housing need whilst the larger strategic brownfield sites are being released for development.

Support

Representation ID: 3240

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

SLR agrees with the streamlining and simplification of the Core Strategy Monitoring Framework to make the process more efficient and effective. As indicated, a number of Core Strategy indicators have been hard to collect and national policy on framework monitoring has changed since the Core Strategy was adopted in 2011.

This will, however, need to be an ongoing process with a number of strategies and policies requiring to be updated as the monitoring framework and evidence base documents are published.

Support

Representation ID: 3241

Received: 14/12/2017

Respondent: CJZ Design Limited

Agent: SLR Consulting

Given the current housing shortfall, the identified OAN for the Black Country up to 2036 and the need to accommodate development outside of the urban area, SLR would support the review of the Core Strategy
Policy.

There will need to be consideration given to the reparation of the additional evidence base documents that would support such policy, including a comprehensive Green Belt Review to ensure the allocation or safeguarding of sufficient housing sites for this plan period and beyond.

As such, a new policy section will be required to address this strategy and the findings of the evidence base documents that support the Core Strategy Review. It is also considered that this is likely to include the allocation of specific sites rather than broad areas for development.