Black Country Core Strategy Issue and Option Report

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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: 1464

Received: 08/09/2017

Respondent: IM Land

Agent: Turley Associates

Representation Summary:

The adopted BCCS did not release any Green Belt land for development. In stark contrast, the emerging BCCS proposes the release of Green Belt land to deliver a minimum of 14,270 dwellings in order to meet the Black Country's needs. This represents a significant departure from the approach of the adopted BCCS.

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 3039 dwellings against the stepped housing delivery trajectory. There is a shortfall of 57 ha of employment land. There is a shortfall of 191,756 sqm of office floor space in strategic locations.

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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: 1480

Received: 08/09/2017

Respondent: IM Land

Agent: Turley Associates

Representation Summary:

The evidence base currently comprises employment studies that assess strategic sites, high quality employment land and regional logistics sites. 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).

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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: 1481

Received: 08/09/2017

Respondent: IM Land

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 required to apply the new standardised methodology.

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.

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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: 1482

Received: 08/09/2017

Respondent: IM Land

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 required to apply the new standardised methodology.

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.

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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: 1483

Received: 08/09/2017

Respondent: IM Land

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 three key issues relating to housing and employment needs, 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 and employment needs of the area should be seen as a golden thread throughout the BCCS Review, reflecting issues specific to the Black Country. The key to unlocking this significant level of growth will be providing sufficient infrastructure (including highways, education etc).

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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: 1484

Received: 08/09/2017

Respondent: IM Land

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 and employment 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. In contrast no Green Belt was released by the adopted BCCS (indeed the boundaries have not been altered for over 30 years).

Furthermore, the adopted BCCS' vision is underpinned by three 'major directions of change', none of which specifically refer to meeting the Black Country's housing needs.

The BCCS Review vision would be more robust if it was underpinned by the nine key issues set out at Part 3 of the I&O Report.

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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: 1485

Received: 08/09/2017

Respondent: IM Land

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 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.

Meeting the emerging housing and employment needs will underpin the BCCS Review.

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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: 1486

Received: 08/09/2017

Respondent: IM Land

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 as appropriate. 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.

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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: 1487

Received: 08/09/2017

Respondent: IM Land

Agent: Turley Associates

Representation Summary:

Please refer to response to Question 11b.

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Comment

Black Country Core Strategy Issue and Option Report

Question 11b - If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employm

Representation ID: 1488

Received: 08/09/2017

Respondent: IM Land

Agent: Turley Associates

Representation Summary:

At the current time there is an established requirement for the Black Country Authorities to accommodate 81,190 new homes and up to 300 ha of new employment land between 2014 and 2036. It is clear that both are pressing needs which will require significant land.

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

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