Black Country Core Strategy Issue and Option Report

Comment

Representation ID: 2946

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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 in plan making. 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 3,039 dwellings against the stepped housing delivery trajectory. In Wolverhampton alone there is a shortfall of 1,396 dwellings. Across the area there is a shortfall in employment land of 57 ha and a shortfall in office space in strategic locations of 191,756 sqm. 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.

Comment

Representation ID: 2947

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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 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 South Staffordshire. Cross boundary working with other authorities will be crucial in this respect. 2.12 It is also considered that the Black Country authorities include a robust landscape character assessment in the scoping of the evidence base document Strategic Mapping of the Black Country's Natural Environment. BDW expect that an updated landscape character assessment will engage with stakeholders involved in landscape assessment and captures changes to the aesthetic, perceptual and experiential qualities of the landscape, particularly at Pennwood, where the site adjoins new residential built form and includes an operational solar farm.

Comment

Representation ID: 2948

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

We recognise that the Black Country authorities and South Staffordshire have sought to update their evidence base with regards to the future need for housing in the area, with the SHMA published in March 2017. This is presented as complying with the current Planning Practice Guidance (PPG). 2.14 The I&O Report cites the SHMA in seeking to meet the objectively assessed need (OAN) for 78,190 homes over the period 2014 to 2036 - equating to 3,554 dwellings per 3 annum - and confirms that this figure will be used as the basis for deriving the BCCS Review housing target. It is noted, however, that the SHMA and therefore the OAN may be updated in the context of new projections and guidance. This potential for the OAN to change is recognised and considered in the context of the current evidence and guidance below as well as factors which may affect this going forward. 2.15 The OAN for the Black Country in the SHMA is based on the following conclusions for each of the prescribed methodological steps set out in the PPG: * The 'starting point' is correctly identified as the 2014-based sub-national household projections (SNHP) which indicate a projected need for 75,502 dwellings for the period 2014 to 2036. This equates to circa 3,432 dwellings per annum; * No further demographic adjustments are concluded as appropriate following consideration of the factors which have historically shaped migration or household formation rates. It is concluded that there is no evidence of younger household suppression due to worsening affordability or undersupply of housing, or evidence of longer-term or more recent levels of population growth which suggest a higher or lower level of projected need;* No adjustment is considered necessary to support baseline (or policy-on) forecast employment growth, implying that the growth in labour force associated with the demographic projection is sufficient to accommodate future economic growth; * No adjustment to the demographic projection is considered appropriate in response to evidence of worsening market signals between housing supply and demand; and * The concluded OAN also seeks to resolve a shortfall in housing provision in the Black Country between 2011 in 2014, in order to maintain consistency with evidence prepared across the Greater Birmingham Housing Market Area (HMA). This does not suggest any accommodation of unmet needs, but simply addresses a recognised deficiency in supply over this historic period. This represents an addition of 2,603 dwellings in the Black Country to the 2014-based SNHP, translating into the concluded OAN of 78,105 dwellings over the plan period, or 3,550 dwellings per annum. 2.16 In essence, this means that the OAN for the Black Country is simply based upon a translation of the household growth in the latest 2014-based DCLG projections into dwellings by allowing for vacancy, with no subsequent adjustments made against each of the PPG's methodological steps. In considering the robustness of the conclusion for each of the steps above, we have a number of concerns that lead us to conclude that the OAN arrived at within the SHMA underestimates the full need for housing in the Black Country authorities. The planned level of provision proposed within the I&O Report is therefore considered to not be appropriate, requiring consideration of a higher level of housing provision to ensure that needs are met in full while retaining a level of flexibility. 2.17 We have outlined our main areas of concern relating to the OAN below.

Demographic Adjustments 2.18 The PPG highlights the importance of sensitivity testing the demographic trend-based 1 assumptions which underpin the 'starting point' of the official 2014-based projections . As set out above, the SHMA applies no demographic adjustment in this regard, retaining the level of population and household growth implied by the 2014-based projections despite alternative longer term trend-based projections presented in the SHMA indicating a higher level of housing need in the Black Country over the plan period. 2.19 Since the publication of the 2014-based projections, the Office for National Statistics (ONS) has continued to estimate the population of local authorities in England. The latest 2016 mid-year population estimates - which were not available when the SHMA was produced - indicate that the population of the Black Country has increased by circa 16,000 persons since 2014. This represents a level of population growth which is some 27% higher than projected over the same period by the latest 2014-based projections, which anticipated population growth of around 12,600 within this geography. This has resulted from higher levels of net international migration and a significantly smaller net outflow of residents to other parts of the UK, suggesting greater success in retaining those assumed to have moved elsewhere. 2.20 Importantly, this indicates that official projections have underestimated population growth to date, which if sustained could underestimate the future need for housing in the Black Country. It is considered important to ensure that the latest available demographic evidence is taken into account in planning to meet housing needs in the Black Country, particularly given the SHMA's retention of the 'starting point' projection without adjustment as its concluded OAN. The Relationship with Employment Growth 2.21 The SHMA considers the relationship between future employment growth and the changing size of the projected labour-force. The conclusion is reached that the concluded OAN can accommodate forecast employment growth. This takes account of the upward adjustment to South Staffordshire's demographic need, which is applied on the basis of a market signals uplift. 2.22 There is a notable concern, however, that the approach adopted in considering the relationship between jobs and housing need risks failing to adequately support future job growth. The SHMA confirms that the analysis has directly extracted the demographic outputs of the economic forecasting houses' models, without subjecting the assumptions applied in "flexing" future labour-force behaviour changes to any sensitivity testing.

The limitations of this approach were recently recognised by the Inspector examining the Telford and Wrekin Local Plan. Direct reference was made in the uplifting of the housing requirement in the Draft Plan through the Inspector's proposed main modifications to a recent appeal decision allowing a housing development at Kestrel 2 Close in Newport . Within this appeal decision, the Inspector raised concern with the approach adopted in the SHMA, preferring the appellant's transparent presentation of a 'series of cumulative numerical steps' which explain the impact of different adjustments to labour-force behaviour. The SHMA does not include sufficient information to ensure PPG Reference ID 2a-017-20140306 Council's Formal response to the Inspector's interim note F10 of 30 March 2017, EiP Library Ref: F10b 1 2 5 confidence in the reasonableness of the adjustments applied, thereby posing a risk that the pressures on housing need would be higher than estimated in order to support even a baseline level of growth. 2.24 Outside of this baseline employment growth, it is also important to reference with regards to the appropriateness of the future housing requirement that at a sub-regional level there is an ambition to deliver a level of employment growth which exceeds a 'baseline' position. The West Midlands Combined Authority (WMCA) recently published a Strategic Economic Plan (SEP) based on an 'Economy Plus' scenario that aims to create 504,000 additional jobs and secure gross value added (GVA) which is 5% higher than the national average by 2030. Importantly, the SEP also calls for a level of housebuilding significantly greater than currently provided in development plans or being delivered across housing market areas in the West Midlands.

2.25 The Government has confirmed its commitment to rebalancing economic growth across 3 the country in developing its modern industrial strategy . This requires the realisation of the WMCA's objectives, and indeed the importance of both the Northern Powerhouse and Midlands Engine initiatives in delivering 'more balanced growth' is recognised. This 4 is further articulated within the Midlands Engine Strategy published in March 2017, which signals new funding of £55 million to support local growth in the Black Country - the second highest level of funding of Local Enterprise Partnerships (LEPs) in the region. 2.26 It is noted that the I&O Report recognises the importance of supporting the resurgent economy, with the Economic Development Needs Assessment (EDNA) highlighting the impact of the economic growth ambitions of the Black Country SEP in its concluded employment land requirement. 2.27 The SHMA considers the implications of a 'policy-on' level of economic growth within Appendix B. It indicates that under the SEP scenario the Black Country (excluding South Staffordshire) would see an additional 80,000 jobs. The SHMA concludes that no additional housing would be required to support this significant additional growth in employment. The SHMA identifies that this may well appear 'counter-intuitive' and indeed the level of detail presented in the appendix fails to provide robust justification that this significant additional employment growth would not generate further housing pressures, noting that this almost doubles the level of job growth forecast under the baseline Experian forecasts referenced in the SHMA. In the case of the latter, it is noted that these are predicated on a level of population and housing growth which are closely aligned with the OAN. 2.28 It is understood that the Greater Birmingham HMA authorities have commissioned a fourth stage report which builds on the three preceding stages of work examining OAN and the distribution of unmet needs. The 'Strategic Growth Study' is due to be completed in Winter 2017, and it is understood that its scope of works includes analysis of the scale of housing need associated with supporting the SEP target of 504,000 new jobs as a 'policy-on' scenario. The implications of this work and its alignment with the
Department for Business, Energy and Industrial Strategy (2017) Building our Industrial Strategy HM Government (March 2017) Midlands Engine Strategy

conclusions of the SHMA in this regard will form an important consideration for the BCCS Review to ensure that it supports the wider agreed economic objectives. Responding to Worsening Market Signals 2.29 As set out above, for the four Black Country authorities the SHMA concludes that no uplift to respond to worsening market signals is justified. This sits in contrast to the application of a 25% adjustment to South Staffordshire within the SHMA. It is recognised that the Black Country authorities remain comparatively affordable when set in a national context. However, the conclusion that no adjustment is required is not considered to be adequately justified, particularly when set in the context of the conclusion to apply no adjustments relating to any of the other methodological stages. Future Changes to the Guidance for Calculating OAN 2.30 As the I&O Report alludes, it is recognised that the Government intends to consult on a new standardised approach to the calculation of OAN. It is understood that this consultation 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. The SHMA's OAN has evidently been calculated based upon the existing PPG, and the implications of the new methodology will therefore need to be taken into account in the future development of the BCCS Review. 2.31 In the context of supporting the economic objectives of the area, it is of note that the Housing White Paper confirms in its commitment to adopting a more standardised approach to calculating housing need the importance of ensuring its consistency with the Modern Industrial Strategy. This will therefore form an important context for the 5 development of subsequent iterations of the BCCS Review . 2.32 We reserve the right to comment further on the OAN where the standardised methodology has been published, and used to calculate the Black Country's needs.

Comment

Representation ID: 2950

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.33 We discuss the strategy to meeting housing needs in the Green Belt in response to Q12a and Q13a. 2.34 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 that does not serve the five purposes of the Green Belt. 2.35 As part of this the methodology for the Green Belt 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. 2.36 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.

2.37 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

Comment

Representation ID: 2951

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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. 2.39 Mindful of the ambitious levels of growth proposed for the Black Country, the three key issues relating to housing needs, and reviewing the Green Belt, are the most important to take account through the BCCS Review. 2.40 The need to review the role and extent of the Green Belt in order to meet the housing needs of the area should be seen as a critical 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 and recreation).

Comment

Representation ID: 2952

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.41 In Q1 we make the case for a full review of the BCCS. This would also necessitate a review of the vision and sustainability principles underpinning the Plan. This is particularly relevant as to date the current vision has not delivered the necessary housing growth required by the BCCS. 2.42 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). 2.43 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 and made direct reference to the supply of new homes.

Comment

Representation ID: 2953

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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 8 completely different national, regional and local planning context to that of the adopted BCCS. In particular the existing objectives will not form a sound basis to deliver the anticipated levels of growth of the Black Country, let alone the current levels proposed by the BCCS. 2.45 Meeting the emerging housing 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.

Comment

Representation ID: 2954

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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

Comment

Representation ID: 2955

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

At the current time there is an established need 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. 2.48 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 low 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 and size. 2.49 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. 2.50 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. 2.51 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. 2.52 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.

Comment

Representation ID: 2956

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.54 BDW support the broad Housing Spatial Option H2 - Sustainable Urban Extensions. 2.55 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). 2.56 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. 2.57 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 of the Black Country's outstanding housing growth. 2.58 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. 2.59 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.

2.60 Turley is a member of the Home Builders Federation and regularly advises national and local housebuilders. It is unlikely there will be significant market interest in sites of less than 50-100 dwellings. Housebuilders require certainty in their own supply. A site of less than 50-100 dwellings would provide one or two years supply maximum, whereas an SUE site would offer between three and five years supply, depending on the size of the site. 2.61 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 housebuilders. This could significantly compromise the potential delivery of the Black Country's housing needs. 2.62 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. 2.63 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. 2.64 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. 2.65 Given the critical mass of SUEs, they have the potential to sustain significant on-site services. It must be noted that Pennwood is capable of sustaining on site leisure and retail facilities and all associated infrastructure should its full capacity be allocated.

2.66 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.