Black Country Core Strategy Issue and Option Report

Comment

Representation ID: 2806

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. We do not agree that the Black Country Core Strategy (BCCS) review should be a partial review, retaining / stretching the existing spatial strategy and updating existing policies. The existing Core Strategy was adopted in 2011 prior to the publication of the NPPF and is therefore not fully consistent with more up to date national planning guidance. Whilst it may well be that certain objectives, strategies and/or policies of the BCCS remain relevant, a full and comprehensive review is necessary to ensure it remains fit for purpose and fully reflects Government guidance, albeit reflecting up to date evidence and local circumstances. Indeed, notwithstanding changes to national policy, there are a whole series of new challenges facing the area as identified within the document, such as HS2, extension of the Midland Metro and the identified housing shortfall within Birmingham (and the wider HMA).

A significant change in circumstances since the current BCCS was prepared is the fact that there is an identified shortfall in capacity within the Black Country's existing urban areas to accommodate future housing and employment land. The document acknowledges that the scale of the shortfall will therefore require the release of Green Belt within the area, noting that there has been no strategic review of the Green Belt since its designation in the late 1970's. This issue alone requires a fundamental review of the spatial strategy on the premise that the current BCCS sought to fully maintain original Green Belt boundaries.

In reviewing the documents, it is also clear that the current spatial strategy has failed to deliver the level of pre-NPPF housing required during the period 2011-2016, with a shortfall of just over 3,000 dwellings against the housing trajectory. A review of the spatial strategy is therefore required in order to address this problem, ensuring that going forward, the objectives of the NPPF to boost significantly the supply of housing is achieved from the outset by meeting in full the objectively assessed housing need for the area, together with any shortfall within the area and those required to be met within the Black Country under the Duty to Cooperate.

Comment

Representation ID: 2807

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. Additional key evidence to support the preparation of the BCCS review should include the following:

* Assessment of affordable housing need and viability
* Evidence of on-going Duty to Cooperate with adjacent authorities within / outside of the Birmingham HMA including any draft / emerging Memorandum of Understanding with Birmingham regarding its unmet need

The BCCS Review should also be informed by other existing / emerging evidence base documents including the Midlands Connect Strategy and Black Country Rapid Transit Review.

Comment

Representation ID: 2809

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. In terms of housing need, the SHMA has made no market signals uplift to the demographic starting point for any of the Black Country areas on the basis that housing across the HMA is generally more affordable than the national average. However, the SHMA has overlooked the recommendations of the Local Plans Expert Group on this issue, notably an assessment of the House Price Ratio as a key indicator of housing affordability, looking at the ratio of lower-quartile house prices to lower-quartile earnings. In a case where the ratio is higher than 5.3 and lower than 7.0, applicable to all four of the Black Country authorities (see fig 5.8, SHMA), the LPEG recommendation is that an uplift of 10% should be applied.

Notwithstanding the above, it is right to keep the OAN figure under review, recognising a review of the SHMA may be necessary prior to Examination in view of the publication of more up to date population and household projections, and proposed implementation of a standardised approach to the calculation of OAN through the revised NPPF.

In terms of unmet housing need, no evidence has been provided regarding the on-going Duty to Cooperate considering the matters relating to Birmingham City. Paragraph 3.18 indicates that the Black Country have committed to test the accommodation of an extra 3,000 homes up to 2031 to help address the shortfall in the wider HMA. There is however no explanation as to how 3,000 of the 37,900 dwellings from Birmingham City needed to be found elsewhere within the HMA by 2031 has been arrived at - there appears to have been no agreement to this level of housing from the other HMA authorities and no robust and thorough apportionment methodology adopted to justify this figure. In view of the strong migration and commuting links with Birmingham, it is queried whether a higher proportion of the unmet need would be more appropriate, or otherwise testing of a range of figures might be sensible.

In terms of housing supply, paragraph 2.5 of the document notes that whilst the majority of current planned growth is focussed within the growth network, the level of delivery has been less than expected to date. It continues by explaining this is because there is not as much surplus employment land suitable for housing as anticipated due to the economy strengthening and local firms being more robust than expected. However, at paragraph 3.16, in noting that a key source of housing supply under the existing spatial strategy is the release of surplus employment land, it is then suggested that a further 10,400 dwellings could be delivered from this source over the period 2026-36. It then states that to exceed past levels of allocations will be extremely challenging due to delivery constraints and need to protect viable employment premises. In our view, it is highly unlikely that greater or even similar levels of capacity can be expected from such a source in view of recent experience - the ability to allocate employment land does not necessarily mean it will be delivered, so to rely on similar level of supply from this source going forward is highly questionable and would fail to satisfy the requirements at paragraph 47 of the Framework.

Comment

Representation ID: 2811

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Agree. It is agreed that a comprehensive review of the Green Belt within the Black Country is critical to identifying suitable locations for release to meet the future housing and employment needs of the area. Due to the limits on capacity within the urban area and the extent of Green Belt outside the urban areas, the exceptional circumstances required by the NPPF have been met and it is considered that the review and amendment of Green Belt boundaries is justified.

It is also agreed that given the strategic importance, the allocation of specific sites (housing and employment) should be carried out through the Core Strategy Review as opposed to any subsequent Site Allocations DPD.

Object

Representation ID: 2814

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. Whilst we generally agree with the majority of key issues identified, the matter of Birmingham's unmet need and the related matter of Duty to Cooperate needs to be added.

Comment

Representation ID: 2815

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. In terms of sustainability principles, a sequential approach to the prioritisation of brownfield land is no longer a policy requirement within the NPPF, paragraph 111 merely requiring that planning policies should seek to make the most effective use of land by re-using brownfield land. In context, it is acknowledged that insufficient capacity is available to meet the areas full housing and employment needs to 2036 and greenfield/green belt land will need to be developed. The objective of prioritising brownfield land and no provision for development of Green Belt land within the current BCCS has resulted in a failure to fully keep up with the current housing requirements of the area and to continue such a policy has the potential to maintain/exacerbate the current problems.

Boosting the supply of housing is a fundamental Government objective and whilst delivering sustainable development should be inherent in all planning policy objectives, meeting the future housing and economic needs of the area are critical to the social and economic roles of sustainable development, as defined within paragraph 7 of the NPPF.

Comment

Representation ID: 2816

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. For similar reasons to those set out within our response to Question 1, the spatial objectives of the current BCCS require a comprehensive review as they are inconsistent with both national planning policy and the key challenges facing the area. For instance, very little if no mention is made within the objectives to meeting the housing needs of the area and wider HMA, a fundamental issue given significant importance within the NPPF. The need to release Green Belt land within the area due to capacity issues is also a significant issue that is absent within the existing BCCS objectives.

Comment

Representation ID: 2818

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

We agree that whilst the policies can be retained, Policy CSP2 in particular will require fundamental changes to reflect a revised spatial strategy that will cover development outside the current Growth Network and within existing Green Belt if the area's future housing and employment requirements are to be met in full to 2036.

Comment

Representation ID: 2822

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Agree (support Option 1A)
As very broad, high level strategic options, Option 1A appears to be the more appropriate and deliverable option. Option 1B raises significant challenges, not least the ability to deliver the area's housing and employment needs when it is needed. The key advantage of Option 1A identified in the table at paragraph 4.20 is that it can significantly boost the supply of housing and employment land. This has to be given significant weight in deciding which option is preferable, when assessing options against the objectives of the NPPF. Both options are identified as requiring significant adjustments to Green Belt boundaries, but in the context of there being exceptional circumstances to do so, this is not considered to be a determinative factor.

Comment

Representation ID: 2824

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Agree / Support Spatial Option H1.
It is considered that the focus should be on Spatial Option H1 Rounding Off: the identification of small to medium sized Green Belt releases (up to 500 dwellings) on the edge of existing urban areas within the Black Country. Due to the potential impact on key purposes of the Green Belt, larger scale SUEs are far more likely to give rise to concerns such as urban sprawl, coalescence and encroachment into the countryside, all key issues for a heavily urbanised area.

We would question why the table at paragraph 4.30 in respect of Spatial Option H2 states that one of the benefits of SUEs would be to significantly boost the supply of housing and maximise the provision of affordable housing. Spatial Option H1 would also achieve this objective assuming a similar quantum of housing overall is allocated and that such allocations are of sufficient scale (i.e. greater than 10 / 15 dwellings) to deliver on-site affordable housing. If anything, Spatial Option H1 has the ability to deliver greater levels of affordable housing sooner in the plan period, due to the ability to bring forward housing in sustainable locations without the need for extensive infrastructure provision, whereas it is common for SUEs to seek a reduction in overall affordable housing provision based on the need to fund supporting infrastructure early on in the build out.

Clearly, the Green Belt Review will help further inform the strategy and it may well be that there is scope to identify some SUEs without creating significant harm to the purposes of the Green Belt. A mixed portfolio of sites may therefore be an appropriate strategy, but the likelihood is that the majority will be small to medium sized sites, which in any case are likely to provide a more reliable and deliverable supply of housing throughout the Plan period, as opposed to an overreliance on a small number of large scale SUEs.