Black Country Core Strategy Issue and Option Report

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Object

Black Country Core Strategy Issue and Option Report

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you

Representation ID: 1318

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

To date the BCCS has failed to meet the Black Country's needs since 2006. As at 31 March 2016 there is a shortfall of 3,039 dwellings against the stepped housing delivery trajectory.

Therefore a full review of the BCCS is essential to ensure:
* The plan is up to date and is prepared in the current planning context, and reflects the area's current needs (as opposed to those identified in the now revoked WMRSS).
* All policies and objectives of the emerging BCCS Review are consistent with national planning policy.
* It comprises a strategy which will deliver against the Black Country's identified needs, and one that is effective, and measurably so, when compared to the
shortcoming of the adopted BCCS.

Comment

Black Country Core Strategy Issue and Option Report

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there

Representation ID: 1338

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

Made the comment that "Additional employment evidence is necessary to assess the entire supply of employment land across the Black Country, including the value, demand and characteristics of the existing supply. This will be crucial to informing whether it is feasible to release employment land to deliver approx. 10,400 new homes (Strategic Option 1B which is discussed further at Q11a)".

Comment

Black Country Core Strategy Issue and Option Report

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national gu

Representation ID: 1339

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

The consultation on a standardised approach to the calculation of OAN is scheduled for September 2017 and, according to correspondence from DCLG (dated 31st July 2017), any Plans which have not been submitted by March 2018 (as will be the case for the BCCS Review) will be In terms of the SHMA, the Objectively Assessed Housing Need ('OAHN') is derived from the 2014 Sub National Household Projections which PPG confirms represents the starting point for calculating need.

We reserve the right to comment further on the OAHN once the standardised methodology has been published, and used to calculate the Black Country's needs.

Comment

Black Country Core Strategy Issue and Option Report

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?

Representation ID: 1340

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.

The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.

Comment

Black Country Core Strategy Issue and Option Report

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be

Representation ID: 1341

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

The nine key issues identified at Part 3 of the I&O Report represent the matters which will be integral to the BCCS Review achieving its ambitious plans for growth.

Mindful of the ambitious levels of growth proposed for the Black Country, the key issues relating to housing needs, providing infrastructure to support growth and reviewing the Green Belt, are the most important to take account through the BCCS Review.

The need to review the role and extent of the Green Belt in order to meet the housing needs of the area is strategically significant and a fundamental shift from previous policy.

Comment

Black Country Core Strategy Issue and Option Report

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?

Representation ID: 1342

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

In Q1 we make the case for a full review of the BCCS. This would also necessitate a review of the vision and sustainability principles underpinning the Plan. This is particularly relevant as to date the current vision has not delivered the necessary housing growth required by the BCCS.

The adopted BCCS vision and sustainability principles reflect the area's need at that time (i.e. February 2011). Since then the NPPF has been published and the WMRSS revoked. A new vision is therefore necessary to reflect the area's needs now, which are much higher than at the time the BCCS was adopted, which is demonstrated by the
admission that Green Belt land will be necessary.

Comment

Black Country Core Strategy Issue and Option Report

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate

Representation ID: 1343

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

Similarly to the BCCS' vision and sustainability principles, the spatial objectives must be reviewed to ensure they are up to date. The BCCS Review will be produced in a completely different national, regional and local planning context to that of the adopted BCCS. In particular the existing objectives will not form a sound basis to deliver the anticipated levels of growth of the Black Country, let alone the current levels proposed by the BCCS.

Comment

Black Country Core Strategy Issue and Option Report

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think

Representation ID: 1344

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

We set out in response to Q1 that a full review of the BCCS is necessary given the change in the planning policy, namely the publication of the NPPF and the revocation of the WMRSS. Policies CSP1 and CSP2 therefore need to be reviewed and updated. This is particularly relevant given neither policy reflects that a proportion of the Black Country's growth needs cannot be met within the urban area (which is explicitly acknowledged at paragraph 3.17 of the I&O Report), necessitating the release of land from the Green Belt.

Comment

Black Country Core Strategy Issue and Option Report

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.

Representation ID: 1346

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

It is clear that both will require significant new land and infrastructure to support this level of growth, and this will require a different spatial strategy to the current one.

The Black Country's employment land is characterised by its supply of smaller industrial units which are typically adjacent to residential areas. Whilst some of the businesses may not be 'friendly' to neighbouring uses, these types of units form the back bone of the Black Country economy and their loss would negatively impact business in the area. The loss would also remove local, sustainable job opportunities.

Further employment land supply evidence is required to achieve the right balance between protecting smaller urban sites which have numerous benefits in providing affordable space for start-up and smaller businesses,which represent a significant proportion of the Black Country economy, and the need to provide larger high quality sites to meet the needs of modern industries and new operators, and their need for better accessibility to markets. This will facilitate the redevelopment of some sites for housing, but the Black Country faces choices with an overall employment land deficit of 300 ha. It cannot simply turn all of its employment land over to housing.

The Councils should also be mindful of the viability of regenerating employment land for residential use, and whether the market can sustain viable development on these sites. This is demonstrated by the number of previously developed sites in the Black Country allocated for housing in previous plans which are yet to be delivered, and show no sign of doing so in the near future.


Comment

Black Country Core Strategy Issue and Option Report

Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re

Representation ID: 1347

Received: 08/09/2017

Respondent: Feoffees of Old Swinford Hospital

Agent: Turley Associates

Representation Summary:

Please refer to our response to Q13a.

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