Black Country Core Strategy Issue and Option Report

Support

Representation ID: 1725

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: Yes
Detail: As stated, national planning guidance suggests that 'most Local Plans are likely to require updating in whole or in part at least every five years' and as the Black Country Core Strategy covers the period from 2006- 2026 and it was formally adopted in 2011. As such, given these timescales, the Core Strategy it is now due for review to remain relevant and to meet the needs of the Black Country area now and into the future.

In addition, although the extant Core Strategy has been perceived to be successful in the past six years, a review will ensure that it continues to support the delivery of housing, industrial and retail growth of the area, whilst protecting the environment.

SLR would agree that the most appropriate strategy is for a comprehensive review of the extant Core Strategy and its associated evidence base. This would provide an opportunity to continue the ethos and good work of the extant Core Strategy and ensure continuity of the Black Country vision going forward, including accounting for any uplift housing projection levels for the wider Housing Market Area.

Notwithstanding, any such review must be based on robust evidence. As such, SLR would emphasise that a comprehensive review of evidence base documents relating to the following topics should take place as part of the Core Strategy review:

Green Belt;
Strategic Housing Market;
Strategic Housing Land Availability;
Population and Household Forecasts;
Retail Study and Centres Healthcheck;
Infrastructure Deliverability & Planning Delivery;
Employment Land;
Minerals and Waste;
Strategic Flood Risk;
Sustainability; and
Transport.

2.1 Other Plans
SLR are fully supportive of the Black Country Core Strategy taking into account other strategic plans and strategies, such as the Black Country and West Midlands Combined Authority Strategic Economic Plans, as well as other local authorities working with the Black Country to meet the needs and aspirations of the Plan going forward. This will be especially pertinent for meeting the needs of the wider Housing Market Area and potentially allocating sufficient sites for both this plan period and beyond.

Indeed, SLR fully supports the statement within paragraph 1.19 of the document that "it will not be possible to accommodate all future development needs within the urban area. Therefore, an examination of the potential for additional development land outside the existing urban area... will need to take place as part of the Core Strategy Review."
This is particularly pertinent given the generally tightly constrained boundary to the Black Country urban areas which are preceded by the exhaustive surrounding Green Belt within other Authority Areas. A review of the Green Belt adjoining the edge of existing urban areas to the Black Country, in conjunction with adjacent authorities, is therefore imperative.



2.2 Consultation and Call for Sites Process
SLR understands that not all of the questions contained within the Core Strategy Issues and Options Review consultation need be answered. This document has sought to be concise in the areas that any such comments
are raised.

However, in accordance with paragraph 1.25 of the document, SLR has also completed a 'call for sites' form on behalf of our client(s). This submission seeks to promote the site at Springhill Lane, Wolverhampton for residential development. In addition, a Land Promotion Document has been prepared and is submitted to provide additional detail relating to the site at Springhill Lane.

This site is not located within the Black Country Core Strategy area but is located immediately adjacent to the administrative boundary of The City of Wolverhampton Council. As outlined within paragraph 1.27, it is understood that such sites are welcome for consideration and the submission of such details will facilitate discussions with adjoining authorities. We trust that this submission assists with the consideration of the Springhill Lane site and its potential release from the Green Belt.

However, please do not hesitate to contact SLR should you have any queries or require any further information relating to the promotion site. We would welcome the opportunity to hold a meeting with representatives from the authority to discuss this site in more detail, at the appropriate time.

Object

Representation ID: 1727

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: No

Detail: Whilst the evidence set out in Table 1 is comprehensive, SLR would question whether the content and findings of these documents would need to be updated following the completion of the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study which was commenced in March 2017 and due to be completed in September 2017. This report could ultimately require for the updating of the following key evidence base documents relating to housing in the sub-region:
Greater Birmingham and Solihull LEP / Black Country Authorities Strategic Housing Needs Study (SHNS) Stage 3 Report (PBA) - completed August 2015;
Strategic Housing Market Assessment for Black Country and South Staffordshire including Gypsy andTraveller needs (PBA) - completed February 2017;
Strategic Housing Land Availability Assessments for Dudley, Sandwell, Walsall and Wolverhampton (Local authorities) - completed 2016/2017; and
Housing Background Report (Local authorities) - completed May 2017.

In addition, SLR would suggest that a comprehensive Black Country Green Belt Review needs to take place, not only reviewing Green Belt within the Black Country sub-region but also reviewing Green Belt land within the adjoining authority areas such as South Staffordshire District Council. It is understood that this document is currently being scoped with an intention to be completed by mid-2018. SLR will seek to submit further representations to this document on behalf of our clients at the appropriate time.

As stated, it is important that the key documents are updated when required and the review is based on up-to -date and robust evidence. With this in mind, SLR would encourage the Black Country to work with adjoining local authorities to ensure that a comprehensive and coherent approach is taken to the Call for Sites, any Strategic Housing Land Availability Assessments (SHLAAs) and Green Belt Reviews going forward.
Without this housing need and delivery will not be met and the existing shortfall will continue to increase, leading to pressure to release unallocated land throughout the Black Country region. SLR therefore urges the Black Country to allocate and safeguard sufficient sites for housing needs beyond the forthcoming plan period.

Support

Representation ID: 1730

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Birmingham's needs up until 2031 that cannot be accommodated within the City, even allowing for the proposals in the Plan to utilise land within the Green Belt (paragraph 3.10). The Strategic Housing Network Study (SHNS, completed in 2015) considered scenarios for distributing this housing shortfall. The study concluded that the supply of brownfield land across the HMA is insufficient and that the majority of this shortfall will need to be met on greenfield sites, including green belt outside Birmingham's administrative area (paragraph 3.11).

SLR supports the premise that through the duty to cooperate there is a mechanism in place to explore new housing provision beyond the HMA where there are clear migration and commuting links. Notwithstanding, as detailed within paragraph 3.12, it is clear that South Staffordshire provides a clear opportunity to accommodate some of this shortfall given that it is a logical sub-market of the HMA. SLR would, therefore, encourage the Black Country to actively work with South Staffordshire District Council to consider whether there are opportunities for cross boundary working/allocation of housing sites.

SLR supports the findings of the Strategic Housing Market Assessment (SHMA) completed in 2017 which identifies that the Objectively Assessed Housing Need ('OAN') for the Black Country over the period 2014-36 is 78,190 homes. SLR also supports that the OAN has made an allowance for a national backlog which has arisen over the period 2011-14 where the annual need for housing was greater than that planned for in the existing Core Strategy.

It is noted that paragraph 3.13 identifies that "The SHMA may be updated during the review as and when new Government projections and guidance become available and housing supply information changes". SLR encourages the authority to undertake this update as swiftly as possible following publication of such information.

Given the above, SLR also considers that a comprehensive review of the Green Belt should be undertaken for both the Black Country area and the adjoining local authorities within the HMA to ensure that sufficient housing sites are either allocated or safeguarded for both the forthcoming and subsequent plan periods. This is especially pertinent given that the SHMA has already accounted for a significant backlog and that these figures are likely to be increased once the Government projections and guidance are updated.

In this respect, SLR duly requests that the Black Country Core Strategy Review consider our Client's site for suitability for release from the Green Belt and either allocation in the short term or a longer term safeguarding. The site can either be brought forward as a smaller independent site or, if the adjoining County Council land is released, as a strategic allocation which could go toward meeting the housing need for the HMA.

With regard to any Green Belt Review, this should be comprehensive in its remit, covering both the Black Country area and Green Belt areas immediately adjoining the settlement boundaries. On this point, it should be noted that the NPPF states that when local authorities are reviewing established Green Belt boundaries they should take account of the need to promote sustainable patterns of development, channelling development towards urban areas inside the Green Belt boundary (NPPF paragraph 84). Indeed, paragraph 85 of the NPPF identifies that when defining boundaries, local planning authorities should:
ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
not include land which it is unnecessary to keep permanently open;
where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the
Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;
make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a
Local Plan review which proposes the development;
satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and
define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We would encourage any comprehensive Green Belt Review to accord with the thrust of these criteria defined within paragraph 85 of the NPPF.

South Staffordshire District Council have, to date, excluded urban/conurbation edge sites from consideration for release through their Partial Green Belt Review. We consider that the Black Country area should be encouraging/requiring the need for these sites to be included for consideration within a more comprehensive
Green Belt Review as they could be more located in closer proximity to infrastructure and more sustainable than other sites further afield.

Support

Representation ID: 1785

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: Yes

Detail: The Economic Development Needs Assessment (EDNA) has been developed for the area during 2016/2017 and it is highlighted that 90-170 ha of land in South Staffordshire (including the proposed West Midlands Interchange) has the potential to contribute towards meeting Black Country needs. Notwithstanding, SLR would encourage any future SHMA to duly consider the needs of the EDNA in terms of both retaining existing employment land and ensuring that sufficient housing land is provided to meet the likely increase in population within the HMA as a result of any increase in economic activity.

Support

Representation ID: 1787

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: Yes

Detail: It is identified within paragraph 3.41 that there has not been a Strategic Green Belt Review in the BlackCountry since the designation of the existing green belt in 1970. Furthermore, given that not all of the housing needs identified can be accommodated within the Black Country area, there is a need to accommodate a proportion of the Black Country housing needs within the wider HMA. As such, SLR welcomes the approach to reviewing the Green Belt along the urban fringe within South Staffordshire as there are likely to be a number of sites along this authoritative boundary which could be more suitable, available and deliverable than sites located within the Black Country itself.


As highlighted in the Issues and Options document, the NPPF identifies that Green Belt boundaries should only be reviewed whilst conducting a Local Plan review and in exceptional circumstances. It is considered that the need 'to accommodate unmet housing needs', especially given the backlog experienced between 2011-2014 and the likely findings of the Greater Birmingham and Black Country HMA Strategic Growth Study, such a Green
Belt Review is now entirely appropriate within both the Black Country and the wider HMA.
As outlined above, SLR duly requests that the Black Country Core Strategy Review consider our Client's site for suitability for release from the Green Belt and either allocation in the short term or a longer term safeguarding.
Given that the site can either be brought forward as a smaller independent site or, if the adjoining County Council land is released, as a strategic allocation which could go toward meeting the housing need for the HMA, this location affords flexibility in the scale of release.
With regard to any Green Belt Review, this should be comprehensive in its remit, covering both the Black Country area and Green Belt areas immediately adjoining the settlement boundaries. On this point, it should be noted that the NPPF states that when local authorities are reviewing established Green Belt boundaries they should take account of the need to promote sustainable patterns of development, channelling development towards urban areas inside the Green Belt boundary (NPPF paragraph 84). Indeed, paragraph 85 of the NPPF identifies that when defining boundaries, local planning authorities should:
ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
not include land which it is unnecessary to keep permanently open;
where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the
Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;
make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a
Local Plan review which proposes the development;
satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and
define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We would encourage any comprehensive Green Belt Review to accord with the thrust of these criteria defined within paragraph 85 of the NPPF.
South Staffordshire District Council have, to date, excluded urban/conurbation edge sites from consideration for release through their Partial Green Belt Review. We consider that the Black Country area should be encouraging/requiring the need for these sites to be included for consideration within a more comprehensive
Green Belt Review as they could be more located in closer proximity to infrastructure and more sustainable than other sites further afield.

4.5 Key Issue 9- Working Effectively with Neighbours
SLR supports the use of collaborative working with adjoining local authorities, especially in meeting the housing needs of the wider HMA and the completion of a suitable and comprehensive Green Belt Review. The strategic priorities must be dealt with across local authority boundaries given the constrained nature of the Black
Country and the significant levels of potentially suitable, available and deliverable Green Belt sites that could be released along the settlement edge of Wolverhampton.