Black Country Core Strategy Issue and Option Report

Comment

Representation ID: 2992

Received: 08/09/2017

Respondent: Hallam Land Management

Agent: Turley Associates

Any site selection criteria should reflect the NPPF, recognising that planning should actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable. For instance, we consider that Great Wyrley, which is located to the immediate north of the Black Country Authorities plan boundary, is a suitable settlement to direct additional housing growth towards. This is largely attributable to the excellent transport services in the form of Landywood railway station and an extensive local bus network. In addition, the settlement is located within close proximity of employment and leisure opportunities at Longford and Bridgtown, which can be accessed through sustainable transport modes. Furthermore, there are a number of education establishments within the Great Wyrley area including a secondary school and three primary schools. The BCCS Review should also not make assumptions that new development will have major impacts on Green Belt purposes and environmental assets. Firstly, any site's performance against the Green Belt purposes is separate to any site selection process. The Green Belt Review is a separate exercise to determining the sustainability of a site. Secondly, potential sites in the Green Belt can have many environmental benefits, including delivering significant public open space (it is widely recognised the Black Country Green Belt is largely inaccessible), as well as biodiversity enhancements. Therefore, it is considered that land at Jones Lane offers a suitable opportunity for residential development and it will be critical for the Black Country Authorities to work with neighbouring authorities, such as SSDC, to identify sustainable locations for release from the Green Belt.

Comment

Representation ID: 2993

Received: 08/09/2017

Respondent: Hallam Land Management

Agent: Turley Associates

For the purpose of demonstrating soundness, the Black Country Authorities will need to demonstrate the BCCS Review is effective i.e. it must be deliverable over its plan period and based on effective joint working on cross boundary strategic priorities, which includes the delivery of significant housing growth. If the Black Country Authorities conclude that the objectively assessed housing need cannot be met within its own administrative boundary then it must act in accordance with paragraph 178 of the NPPF which outlines public bodies (e.g. local authorities) have a duty to cooperate on planning issues that cross administrative boundaries. It is therefore expected that should the Black Country Authorities be unable to meet their objectively assessed housing needs joint working will be required with neighbouring authorities, such as SSDC, where there are sustainable opportunities for housing growth (i.e. land at Jones Lane, Great Wyrley) in proximity to the edge of an existing urban area; proximity to a rail station; available existing physical and social infrastructure; and easy access to jobs.

Comment

Representation ID: 2994

Received: 08/09/2017

Respondent: Hallam Land Management

Agent: Turley Associates

Any site selection criteria should reflect the NPPF, recognising that planning should actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable. For instance, we consider that Great Wyrley, which is located to the immediate north of the Black Country Authorities plan boundary, is a suitable settlement to direct additional housing growth towards. This is largely attributable to the excellent transport services in the form of Landywood railway station and an extensive local bus network. In addition, the settlement is located within close proximity of employment and leisure opportunities at Longford and Bridgtown, which can be accessed through sustainable transport modes. Furthermore, there are a number of education establishments within the Great Wyrley area including a secondary school and three primary schools. The BCCS Review should also not make assumptions that new development will have major impacts on Green Belt purposes and environmental assets. Firstly, any site's performance against the Green Belt purposes is separate to any site selection process. The Green Belt Review is a separate exercise to determining the sustainability of a site. Secondly, potential sites in the Green Belt can have many environmental benefits, including delivering significant public open space (it is widely recognised the Black Country Green Belt is largely inaccessible), as well as biodiversity enhancements. Therefore, it is considered that land at Jones Lane offers a suitable opportunity for residential development and it will be critical for the Black Country Authorities to work with neighbouring authorities, such as SSDC, to identify sustainable locations for release from the Green Belt.

Comment

Representation ID: 2995

Received: 08/09/2017

Respondent: Hallam Land Management

Agent: Turley Associates

The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1, which in our view is considered necessary. There are now greater housing needs, the NPPF has been published and the WMRSS has been revoked, and the adopted BCCS has not been delivering the required level of growth. As such the approach to housing land supply should be reviewed. Given there is a shortfall of 3,039 dwellings against the targets set in the adopted BCCS, largely as a result of brownfield sites not being developed due to viability issues, the BCCS Review should include a 10% lapse rate should be applied to the requirement to ensure flexibility in deliverability should sites in the supply not come forward.