Black Country Core Strategy Issue and Option Report

Comment

Representation ID: 2957

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.

Comment

Representation ID: 2958

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.67 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. 2.68 Furthermore, the Councils should be mindful of site specific evidence bases prepared by developers. Indeed BDW is exploring infrastructure requirements for Pennwood and intends to submit this assessment work during the plan-making process. 2.69 The Black County authorities should also liaise with the relevant statutory undertakers (such as Severn Trent and Western Power Distribution) to ensure the BCCS Review includes a robust Infrastructure Delivery Plan.

Comment

Representation ID: 2959

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.70 Pennwood represents a unique opportunity to create a new community, which could provide between 500 and 1,300 new homes, although it should be noted that up to 1,000 dwelling can be provided to meet Wolverhampton's needs, whilst the remaining 300 will meet future South Staffordshire housing needs. BDW'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. 2.71 For example, BDW secured an allocation for up to 2,000 dwellings at Overstone Leys in Northampton. This SUE will help to meet Northampton's housing need in the West Northamptonshire Joint Core Strategy. A subsequent and successful planning application secured significant residential development, a local centre, primary school and a new section of A43 dual carriageway. 2.72 BDW maintained a positive working relationship with both Daventry District Council and Northamptonshire County Council during the plan-making and decision-taking process. 2.73 We explore the infrastructure requirements of Pennwood further in the Call for Sites form (Appendix 2) and Vision Document (Appendix 3) enclosed with these representations. 2.74 Given Pennwood'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 2.75 Pennwood is bound by residential development to the north, east and south-east, whilst residential properties lie immediately adjacent to the western boundary separated from the site by a strip of agricultural land. As such Pennwood is enclosed by existing built form along three boundaries. At present the Green Belt boundary projects into the urban form of Wolverhampton, utilising the built form along Hornby Road / Park Hall Road, Wolverhampton Road East and Alderdale Avenue as the defensible boundaries. 2.76 The release of Pennwood 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.

2.77 Consequently, the enclosed nature of Pennwood results in the land making a low contribution to the Green Belt in relation to checking the unrestricted sprawl of Wolverhampton. It is anticipated that once Pennwood 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 2.78 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. 2.79 Pennwood currently presents a gap in the urban form of Wolverhampton and residential development is located in the immediate vicinity to the north, east, south east and west of the site. As illustrated on Wolverhampton's policies map, the existing Green Belt boundary protrudes to the north-east (to include the site). To release this site from the Green Belt in its full capacity would not result in any neighbouring towns merging into one another. This is illustrated by the Development Options in the enclosed Vision Document, which offer a generous amount of green infrastructure and open space to restrict Upper Penn and Sedgley from merging. In addition, a new defensible boundary could be formed to the south-western edge of development adjoining Penn Common. Purpose 3 - To assist in safeguarding the countryside from encroachment 2.80 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. 2.81 Pennwood adjoins the urban area of Wolverhampton and the Development Options contained with the enclosed Vision Document illustrates the preservation of a green corridor to the west and south-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. 2.82 In accordance with the guidance set out in the NPPF, Pennwood is located towards the urban area of Wolverhampton 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 Pennwood.

Purpose 4 - To preserve the setting and special character of historic towns 2.83 Pennwood is not located within close proximity to any historical town. In historic landscape character terms, the site is partly located in the Goldthorn / Lower Penn Green Wedge and was formerly a 'Special Landscape Area' both of which place emphasis on the retention of the 'attractive' landscape; whilst such land should provide recreation facilities and access to the countryside for the urban population can be available. 13 2.84 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 Upper Penn. Furthermore, Pennwood 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 2.85 The BCCS I&O Report sets out that there is a requirement for the Black Country Authorities to accommodate approximately 22-25,000 new homes. 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.

Comment

Representation ID: 2960

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

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 and be in line with paragraph 173 of the NPPF.

Comment

Representation ID: 2963

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.87 The NPPF is clear that local planning authorities should have fully explored all available options for delivering their housing needs within their own administrative 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. 2.88 It is also important to recognise that following the adoption of the Birmingham Development Plan there is an acknowledged shortfall of housing of approximately 38,000 homes across the Greater Birmingham HMA, the majority of which is a direct consequence of Birmingham's failure to accommodate its own needs in full. To date, whilst a number of emerging plans have confirmed the inclusion of additional provision to accommodate a proportion of this unmet needs the full scale of the unmet need has not been accounted for. The I&O Report references a commitment to test the accommodation of an extra 3,000 homes up to 2031 beyond local need to help address the wider HMA shortfall. Any attempt by the Black Country authorities to 'export' further unmet housing needs will compound the uncertainties associated with ensuring that needs are met in full across the HMA in the immediate term in particular. 2.89 In this context the Black Country should be seeking to accommodate all of its proposed growth within its own boundaries, and therefore should fully consider the prospect of delivering up to 1,000 new dwelling at Pennwood as illustrated in Development Option 2 of the enclosed Vision Document.

Comment

Representation ID: 2964

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.90 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. 2.91 Given the characteristics and viability matters which differ between brownfield and greenfield sites, the BCCS Review should have separate policies for each.

Comment

Representation ID: 2965

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.93 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. 2.94 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).

Comment

Representation ID: 2966

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.93 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. 2.94 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).

Comment

Representation ID: 2967

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.95 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. 2.96 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 or sustainable design features does not comprise viability.

2.97 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.

Comment

Representation ID: 2968

Received: 08/09/2017

Respondent: Barratt Homes and David Wilson Homes

Agent: Turley Associates

2.98 The recently published WMCA Land Delivery Action Plan identifies sources of funding and immediate priorities. Of the £200 million Land Remediation Fund, £53 million is already allocated to the Black Country and a further strategic package of £97 million is available to be drawn down by the LEP. However, the Action 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. 2.99 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.