Black Country Core Strategy Issue and Option Report

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Comment

Black Country Core Strategy Issue and Option Report

Question 6 - 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? Yes/No; If not, what other key issues should be

Representation ID: 3059

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.

Object

Black Country Core Strategy Issue and Option Report

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?

Representation ID: 3060

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, with exception to the principle of 'brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. There is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is therefore suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.

Object

Black Country Core Strategy Issue and Option Report

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate

Representation ID: 3061

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPFs main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.

Comment

Black Country Core Strategy Issue and Option Report

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think

Representation ID: 3062

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.

Comment

Black Country Core Strategy Issue and Option Report

Question 11c - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.

Representation ID: 3063

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.8 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.9 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.

Comment

Black Country Core Strategy Issue and Option Report

Question 13a - Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibi

Representation ID: 3064

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.12 The Palmers Cross Consortium considers that land West of Codsall Road, Palmers Cross, should be considered as a new SUE. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability. This site would represent sustainable options for meeting housing needs arising from within the Black Country.
5.13 However, given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.

Comment

Black Country Core Strategy Issue and Option Report

Question 13b - What infrastructure do you think would be needed for different sizes of SUEs?

Representation ID: 3065

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.14 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.

Comment

Black Country Core Strategy Issue and Option Report

Question 13c - 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?

Representation ID: 3066

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.15 As stated previously, The Palmers Cross Consortium considers that land west of Codsall Road, Palmers Cross, should be considered as a new SUE. A call for sites submission has been undertaken in respect of this site to demonstrate availability, suitability and deliverability.

Object

Black Country Core Strategy Issue and Option Report

Question 13d - 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

Representation ID: 3067

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.16 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.

Comment

Black Country Core Strategy Issue and Option Report

Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details.

Representation ID: 3068

Received: 08/09/2017

Respondent: Palmers Cross Consortium

Agent: Pegasus Group

Representation Summary:

5.17 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.

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