Black Country Core Strategy Issue and Option Report

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.

Q1. Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? If not, what do you think should be the scope of the review?

2.1 Paragraph 151 of the National Planning Policy Framework ('NPPF') establishes that Local Plans should be consistent with the principles and policies set out in the NPPF. The adopted BCCS was published in 2011, prior to the publication of the NPPF in March
2012. It is based on the housing needs identified by the now revoked West Midlands Regional Spatial Strategy ('WMRSS') and the subsequent WMRSS Phase II Review Panel Report. The Solihull MBC v Gallagher Homes Limited and Lioncourt Homes
Limited Judgment [2014] EWHC 1283 (Admin) was clear that the NPPF affected radical change.

2.2 The Housing White Paper (published in February 2017) establishes a national need for a minimum of between 225,000 to 275,000 new homes per year to keep up with population growth and to start addressing decades of under-supply in housing delivery.
2.3 The West Midlands Combined Authority Strategic Economic Plan ('WMCA SEP') (June 2016) recognises the importance of planning to meet these ambitious levels of growth. Indeed housing is one of the Plan's eight priority actions. Clearly the BCCS Review
needs to provide a robust strategy to meet the significant growth across the Black Country, reflecting the priority actions set out in the WMCA SEP.

2.4 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.

2.5 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.

2.6 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.

2.7 We discuss the need for a full review further in response to Q7, Q9 and Q21.

Q2. Do you think that the key evidence set out at Table 1 is sufficient to support the key stages of the Core Strategy review? If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas?

2.8 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).

2.9 If any existing sites are to be proposed for allocation as residential development the evidence base should demonstrate the suitability of the land. This includes consideration of contamination issues, whether the land is a suitably attractive location
for residential development, and whether existing neighbouring uses would provide an issue for future residents.

2.10 A number of infrastructure studies (including flood risk / water, waste, and viability) are to be undertaken to inform the BCCS Review Preferred Options Paper. Infrastructure viability will be a key factor in determining the deliverability of sites to meet the area's
housing and employment needs. To provide a robust assessment of infrastructure public consultation should be undertaken. This will ensure that a full picture regarding infrastructure viability is provided, as residents / landowners will have information which
the Black Country authorities' assessment work may not be aware of.

2.11 These studies should also not just assess infrastructure within the Black Country exclusively, but also the infrastructure required outside of the area which may be required to meet its needs. For instance, some residents from within the Black Country
attend schools in other authority areas, such as Birmingham and the South Staffordshire. Cross boundary working with other authorities will be crucial in this respect.

Q3. 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 guidance?

2.12 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.

2.13 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.

2.14 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.

Q5. Do you agree with the proposed approach to the Black Country Green Belt Review? If not, what additional work do you think is necessary?

2.15 We discuss the strategy to meeting housing and employment needs in the Green Belt in response to Q12a and Q13a.

2.16 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.

2.17 As part of this the methodology for the Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.

2.18 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.

2.19 The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the
Black Country Green Belt Review to conclude which land is suitable for Green Belt release. There may be opportunities within discounted areas for smaller parcels of land to be released as sustainable extensions to existing settlements.

Q6. 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? If not, what other key issues should be taken into account?

2.20 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.

2.21 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.

2.22 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).

Q7. Do you think that the Core Strategy vision and sustainability principles remain appropriate? If not, what alternatives would you
suggest?

2.23 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.

2.24 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).

2.25 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.

Q8. Do you think that the Core Strategy spatial objectives remain appropriate? If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?

2.26 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.

2.27 Meeting the emerging housing and employment needs will underpin the BCCS Review. It is therefore imperative they these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than
those of the current BCCS if they are to be meaningful.

Q9. Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?

2.28 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.

Q11a. Do you support Strategic Option 1A? If yes, please explain why. If no, do you support Option 1B?

2.29 Please refer to response to Question 11b.

Q11b. Do you support the release of further employment land for housing? If yes, what should the characteristics of these areas be?

2.30 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.

2.31 There is currently a deficit of 57 ha of gross employment space across the Black Country. The monitoring data at Appendix C of the I&O Report identifies that there is a surplus in local quality employment land (146 ha), but a deficit of 218 ha in high quality
employment land. This does not distinguish between different types of employment, including different use classes, size etc.
2.32 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.

2.33 As set out in our response to Q2 further employment land supply evidence is required. Through this there may be opportunities to replace derelict employment land with housing, however new employment sites tend to be of higher quality, reflecting more
modern industries (such as large logistic sites). They are unlikely to replace the smaller industrial unit stock, which have numerous benefits including lower rents, being suited for 'start up' and smaller businesses which reflect of the Black Country's employment
profile. New large, greenfield strategic employment sites are unlikely to be affordable for the types of businesses which currently occupy the smaller industrial unit stock.

2.34 With the Black Country facing an overall employment land deficit of 300 ha, the authorities should be seeking to protect the smaller industrial stock where possible and not maximising it for residential uses. 2.35 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.

Q12a. Do you support Spatial Option H1? What criteria should be used to select suitable sites? E.g. ability to create a defensible new Green Belt boundary, size, access to existing residential services.

2.36 Please refer to response to Question 13a.

Q13a. Do you support Spatial Option H2? What should the characteristics of Sustainable Urban Areas (SUEs) be? E.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? E.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements/ services, proximity to the existing growth network, potential to support urban regeneration.

2.37 Whilst there is no definition to the housing numbers associated with 'rounding off', this has been taken as any development site consisting less than 500 dwellings (the minimum threshold defined for SUEs).

2.38 The NPPF and PPG do not refer to 'rounding off' the Green Belt. The NPPF states at paragraph 85 that the boundaries of the Green Belt should be defined clearly, using physical features that are readily recognisable and likely to be permanent. These boundaries should be long term and enduring, and will not require adjustment at the end of the plan period.

2.39 Subject to meeting the NPPF and PPG, rounding off of the edges of the urban area within the Green Belt could assist in meeting some of the Black Country's identified housing needs, however the I&O Report acknowledges that Option H1 would not meet
all the area's outstanding housing growth.

2.40 Larger SUE sites will provide significant contributions towards delivering improved infrastructure given their critical mass. Relying too heavily on smaller sites through rounding off, would compromise the Black Country's ability to deliver new infrastructure
to meet its growth aspirations.

2.41 Furthermore, a number of SUEs will be required if the Black Country's housing shortfall, which cannot be accommodated within the existing urban area (between 14,270 and 24,670 dwellings), is to be met.

2.42 Turley is a member of the Home Builders Federation and regularly advises national and local house builders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. House builders require certainty in their own supply. A site of
less than 50-100 dwellings would provide one or two years supply maximum, where as an SUE site would between three and five years supply, depending on the size of the site.

2.43 Furthermore the costs associated with installing infrastructure for a site, including constructing the site access, connecting to the appropriate utility grids, establishing a compound, are broadly similar for small and larger scale development. As such smaller
sites are less cost effective for house builders. This could significantly compromise the potential delivery of the Black Country's housing needs.

2.44 In contrast SUEs are likely to have greater market interest. Large scale planned development, which is allocated within a Local Plan, provides certainty and developer confidence, as recognised by paragraph 52 of the NPPF. Therefore the sites are more likely to deliver, and can accommodate multiple housebuilders and outlets, increasing the rate of delivery once the required infrastructure has been installed.

2.45 Spatial Option H2 is therefore the most appropriate strategy for accommodating the area's housing shortfall, however Spatial Option H1 can make a small contribution in the right locations.

2.46 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. Whilst a potential SUE may not be immediately adjacent to local services or a rail station (which will be the case for the majority of the SUEs given their location on the edge of the urban area), there is the potential to make it more sustainable through new transport links (such as bus services) and on site provision.

2.47 Given the critical mass of SUEs, they have the potential to sustain significant on site services. An example is IM's proposals for 1,000 new homes at Gaydon Lighthorne in Stratford on Avon, which benefits from a resolution to grant. This will be capable of
sustaining on site leisure and retail facilities and all associated infrastructure.

2.48 The BCCS Review should also not make assumptions that SUEs will have major impacts on Green Belt purposes and environmental assets (as suggested in the 'challenges' section for Spatial Option H2). 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, SUEs 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.

Q13b. What infrastructure do you think would be needed for different sizes of SUEs?

2.49 For the reasons provided in response to Q12a and Q13a, further evidence will be necessary to inform infrastructure requirements for each SUE, including school and healthcare provision. The I&O Report indicates a number of infrastructure assessments are to be undertaken before the Preferred Options version of the BCCS Review is published.

2.50 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed IM is exploring infrastructure requirements for Columba Park and intends to submit this assessment work in due course.

2.51 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent, Western Power Distribution etc) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Q13c. Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what
infrastructure would be required to support these?

2.52 Columba Park represents a unique opportunity to create a new community, which could provide approximately 1,500 new homes. IM's aspirations are to create a new neighbourhood which delivers real health and wellbeing, and economic benefits for both
existing and new residents. This includes significant high quality open space, parkland and green infrastructure, well designed homes, and new community facilities.

2.53 IM is a market leader in the delivery of strategic housing and employment sites. Working in partnership with Bath and North East Somerset Council, IM is delivering a new community at MoD Ensleigh which includes a new 210-place primary school. IM is also
working successfully alongside Solihull Council to deliver the mixed use business and residential campus at Blythe Valley, is delivering 750 dwellings, 250 bed extra care and 1m sq ft of commercial space. This represents the largest allocation in Solihull's Local Plan. As set out previously IM is also promoting land at Gaydon Heath for 1,000 dwellings and new retail and leisure facilities, which benefits from a resolution to grant.

2.54 We explore the infrastructure requirements of the site further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations.

2.55 Given the site's location within the Green Belt we provide an assessment against the five purposes for including land within the Green belt below.

Purpose 1 - To check the unrestricted sprawl of the large built-up areas

2.56 The site is bound by residential development to the east, south and west. As such the site is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Walsall, utilising Aldridge Road, Queslett Road
and Doe Bank Lane as the defensible boundaries.

2.57 The release of the site would not result in any unrestricted sprawl of the built up area and on the contrary it would actually contain development within an existing urban form.

2.58 Consequently, the enclosed nature of the site results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Walsall. It is anticipated that once the site is released from the Green Belt, the newly formed boundary will better correspond with the urban form of the surrounding area and present a logical Green Belt boundary to protect against any unrestricted sprawl of the future built-up area.

Purpose 2 - To prevent neighbouring towns merging into one another

2.59 An important requirement of the Green Belt is to prevent neighbouring towns from merging however paragraph 85 of the NPPF sets out that there may be opportunities for land to be released from the Green Belt that would assist in creating longer term
permanent defensible boundaries.

2.60 The site currently presents a gap in the urban form of Walsall and residential development is located in the immediate vicinity to the east, south and west of the site. As illustrated on Walsall's policies map, the existing Green Belt bounda ry protrudes to the south east (to include the site) utilising Queslett Road East as a defensible boundary (the A4041). To release this site from the Green Belt would not result in any neighbouring towns merging into one another and the new defensible boundary would be formed by the northern edge of development, adjacent to the proposed parkland.

Purpose 3 - To assist in safeguarding the countryside from encroachment

2.61 Paragraph 84 of the NPPF states that when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. As such, development should be focussed towards urban areas inside the Green Belt boundary, towards towns and villages.

2.62 The site adjoins the urban area of Walsall and a masterplan is currently being prepared for the site that respects the surrounding countryside to the north west of the site. The early stage of masterplanning demonstrates how a landscaped view corridor can be
included within the proposals and in particular how the existing landscape, including woodland, and ecological assets such as hedgerows and wildlife, can play a key role in the design of the community.

2.63 In accordance with the guidance set out in the NPPF, the site is located towards the urban area of Walsall and the release of this site from the Green Belt would not result in a detrimental encroachment into the countryside, as illustrated within the early stages of
masterplanning for the site.

Purpose 4 - To preserve the setting and special character of historic towns

2.64 The site is not located within close proximity to any historical town. In historic landscape character terms, the site is located within the Barr Beacon/ Eldridge Fields area (reference WL09) which comprises a large geographical area and simply characterises
this area as dispersed farms and recreation, enclosed field systems, with historic heath at Barr Beacon.

2.65 As discussed in response to Purpose 3, the early stages of masterplanning have demonstrated how important landscaping is for the proposed development site and in particular the proposals will comprise a large landscape buffer, protecting the setting for Barr Beacon. Furthermore, the site is not located within the setting to a historic town and as such this purpose is not considered to apply in this circumstance.

Purpose 5 - To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

2.66 The BCCS Issues and Options Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes and up to 300 ha of new employment land. It has been established that the Black Country has
severely limited opportunities to accommodate this anticipated growth within the present urban boundaries and it is therefore necessary to consider Green Belt release.

Q13d. Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies?
2.67 Any guidance for SUEs should not be considered until later in the preparation of the Plan, and should be informed by the relevant evidence base (including site specific evidence, the SHMA, and infrastructure assessments). Any guidance should be flexible
to ensure the Plan is able to respond to the most up to date evidence.

Q15a. If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
2.68 The NPPG is clear that local planning authorities should have fully explored all available options for delivering their housing and employment needs within their own boundaries before considering exporting growth to neighbouring authorities or the wider HMA.
Equally, neighbouring authorities will not accept accommodating any of the Black Country's needs if this exercise has not been thoroughly undertaken. Telford and Wrekin has so far declined to assist in meeting any of the Black Country's shortfall given
this exercise had not been undertaken. As such this option should only be considered as a last resort.

2.69 On this basis the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries.

Q21. Do you think that changes are required to policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt?

2.70 As set out in our response to Q1 a full review of the BCCS is necessary. This applies to Policy DEL1 also, particularly as the policy currently only reflects development within the urban area.

2.71 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Q25. Will there be any new social infrastructure requirements necessary to serve large new housing developments? If yes, please explain the type and scale of any new social infrastructure required.

2.72 Please refer to response to Question 28.

Q28. Do you think physical infrastructure is necessary to serve large new housing developments? If yes, what type and scale of physical
infrastructure is necessary?

2.73 Paragraph 5.7 of the I&O Report sets out that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

2.74 This approach will be necessary to understanding the full infrastructure requirements for new sites. As set out in response to Q2, the infrastructure assessments to be undertaken will be crucial in understanding these requirements further. This should also be informed by any site specific evidence base work undertaken by developers, as well as liaison with infrastructure providers (including statutory undertakers).

Q29. Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments?

2.75 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development.

2.76 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves
that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix, sustainable design features etc, does not comprise viability.

2.77 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.

Q31. Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy Review? If no, what alternative sources of funding or delivery mechanisms should be investigated?

2.78 The recently published WMCA Land Delivery Action Plan identifies sources of funding
and immediate priorities. Of the £200m Land Remediation Fund, £53m is already
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allocated to the Black Country and a further strategic package of £97m is available to be
drawn down by the LEP. However, the plan states on page 44 that "to fund the current
pipeline of brownfield sites in the Black Country, a total of £700m of further LRF funding
is required". This, it states, will be a key requirement of the Housing Deal the WMCA is
hoping to negotiate with CLG.
2.79 Whilst the funding to date is a good start, it is clear that it is a fraction of the total needed
to deliver a substantial step change in brownfield delivery. As set out in our response to
Q29, it is crucial the four authorities are satisfied of the scale and pace of delivery and
that it is viable for new development on brownfield sites to contribute towards providing
infrastructure to meet their needs. The role of greenfield locations to deliver market
housing and contribute fully to meeting infrastructure costs should therefore be a key
component to derisk the BCCS housing strategy.
Q32. Do you think that the proposed approach to incorporate health and
wellbeing issues in the Core Strategy review is appropriate? If no, please
provide details
2.80 Please refer to response to Question 34b.
Q33. Is there more that the Core Strategy can do to address health and
wellbeing issues in the Black Country? If yes, is a new policy needed to
address such issues for example?
2.81 Please refer to response to Question 34b.
Q34a. Do you agree that the health and wellbeing impacts of large
development proposals should be considered at the Preferred Spatial
Option stage of the Core Strategy review through a Health Impact
Assessment approach?
2.82 Please refer to response to Question 34b.
Q34b. What design features do you think are key to ensuring new
development encourages healthy living, which could be assessed through
the HIA process?
2.83 We support the strategy to incorporate health and wellbeing issues in the BCCS
Review. Health and wellbeing underpin sustainable planning and creating places where
people want to live.
2.84 The Health and Wellbeing Technical Paper (June 2017) emphasises the importance of
integrating health and wellbeing into all policies, including those of the emerging BCCS
Review. In particular, the technical note encourages the creation of communities which
are:
* Well-connected and walkable;
* Have a wide choice of homes;
* Accessible to services; and
* Where people can belong to a cohesive community which fosters diversity, social
interaction and social capital.
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2.85 As such, health and wellbeing should not be standalone policies in the plan, but rather
should be a 'golden thread' running through the review and all policies. Any sites
promoted through the Local Plan process should demonstrate their health and wellbeing
benefits if they are to be proposed for allocation.
2.86 As demonstrated by the Vision Document (Appendix 3) submitted with these
representations, health and wellbeing are key principles at the heart of the proposals for
Columba Park. It will include significant new green infrastructure accessible to the
public, such as new parkland. New community facilities will also be delivered. New
pedestrian and cycle links will form a key component of the proposals, linking the site to
Barr Beacon and Sutton Park.
Q35. Do you support the proposed approach to housing land supply? If
no, please explain why.
2.87 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in
our response to Q1 a full review of the Plan is necessary given there are now greater
housing and employment 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 in full also.
2.88 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 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.
Q36. Do you think that the current accessibility and density standards set
out in Policy HOU2 and Table 8 should be changed? If yes, what standards
should be applied instead, for example should the minimum net density of
35 dwellings per hectare be increased to maximise brownfield housing
delivery?
2.89 Please refer to response to Question 42.
Q40. Do you agree that the 2017 SHMA findings should be used to set
general house type targets for the Plan period? If no, please explain why.
2.90 Please refer to response to Question 42.
Q42. Do you agree that the annual affordable homes target should be
increased to reflect the 2017 Black Country Strategic Housing Market
Assessment? If no, please explain why.
2.91 The NPPG states that wherever possible, local needs assessments should be informed
by the latest available information and the government's official population and
household projections are generally updated every two years.
2.92 The affordable housing requirement, preferred housing mix and types for the Black
Country therefore need to remain fluid in order to respond to the most up to date
evidence and market conditions. The BCCS Review should not comprise policies that
set standards for the whole Plan Period. The standards set out in Policy HOU2 should
be reviewed in full to ensure they comply with the NPPF, PPG and the most up to date
guidance.
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2.93 Columba Park will be capable of delivering a range of house types, including high
quality larger 'professional / executive' type housing which is currently in short supply in
Walsall and results in residents moving out the borough to find suitable housing.