Black Country Core Strategy Issue and Option Report
Search representations
Results for St Philips search
New searchComment
Black Country Core Strategy Issue and Option Report
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you
Representation ID: 2858
Received: 08/09/2017
Respondent: St Philips
Given the evidence on which the current Core Strategy is based is now very out of date, St Philips considers that a full review of the Core Strategy should be carried out. The BCCS was prepared and adopted before the National Planning Policy Framework (NPPF) came to force in March 2012. Paragraph 47 of the NPPF requires that Development Plans are based on a full, objectively assessed need for housing, but this is not the case for the current BCCS. The entire Core Strategy should therefore be reviewed to ensure that it aligns with national guidance. The policies within the BCCS which relate to the Growth Network, particularly policies CSP1 and CSP2 will require radical change through the Core Strategy Review to refer to the need for housing development beyond the Growth Network within the Green Belt.
Comment
Black Country Core Strategy Issue and Option Report
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there
Representation ID: 2859
Received: 08/09/2017
Respondent: St Philips
The evidence set out in Table 1 should be sufficient to support the Core Strategy Review. However, the Government is currently proposing changes to the NPPF and Planning Practice Guidance (established through the Housing White Paper) in relation to the evidence base needed for Local Plans. Therefore further work could become necessary if and when these changes take place. St Philips supports the two stage approach proposed to interrogate options for strategic growth in the Green Belt through the Greater Birmingham and Black Country HMA Strategic Growth Study and the Black Country Green Belt Review. The Green Belt Review should be undertaken in line with the NPPF and have regard to paragraphs 83 to 85, particularly the need to promote sustainable patterns of development when drawing up or reviewing Green Belt boundaries.
Comment
Black Country Core Strategy Issue and Option Report
Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national gu
Representation ID: 2860
Received: 08/09/2017
Respondent: St Philips
St Philips has not interrogated the findings of the SHMA but understands it to be the most recent housing need evidence underpinning the BCCS Review. The SHMA concludes that the objectively assessed housing need for the Black Country for the BCCS Review period is 78,190 homes, or 3,554 dwellings per annum (dpa).
In accordance with the Duty to Co-operate, the Black Country has agreed to attempt to accommodate an extra 3,000 homes to help address the shortfall in the wider HMA. St Philips understands that the Black Country Authorities are undertaking work to confirm how many houses can be accommodated from existing planning permissions and windfall sites. Further evidence on housing needs will be developed through the BCCS Review process and St Philips hopes that all such work is made available to interested parties in a transparent manner. It is clear from the SHMA findings that a substantial number of new homes will need to be accommodated in the Green Belt and St Philips therefore wishes to highlight the opportunity provided by the identified land which is suitable for residential development.
Comment
Black Country Core Strategy Issue and Option Report
Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
Representation ID: 2862
Received: 08/09/2017
Respondent: St Philips
St Philips has already commented on the approach to the Green Belt Review in our response to question 2. As previously stated, the Green Belt Review should be undertaken in line with the NPPF and have regard to paragraphs 83 to 85, particularly the need to promote sustainable patterns of development when drawing up or reviewing Green Belt boundaries. Paragraph 80 of the NPPF sets out that a Green Belt Review will assess the extent to which land designated as Green Belt performs against the purposes of Green Belt. The identified land in Aldridge is considered to have limited Green Belt purpose and St Philips expects the Green Belt Review will come to the same conclusions when it is undertaken.
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: 2863
Received: 08/09/2017
Respondent: St Philips
St Philips is content that the key issues facing the Black Country are covered within the Core Strategy Review, especially the need to identify sites for housing within the designated Green Belt. As set out in our response to question 1, there is a critical need to look beyond the Growth Network to account for the Black Country's long term development needs.
Comment
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: 2864
Received: 08/09/2017
Respondent: St Philips
The Core Strategy vision is considered by St Philips to remain appropriate because it accords with the three dimensions of sustainable development outlined in the NPPF which stems from social, economic and environmental roles.
The Core Strategy sustainability principles are considered to remain largely appropriate, although it is St Philips view that sustainability principle 4 "putting brownfield first" is no longer as relevant. This sustainability principle focuses on "ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised for development over greenfield sites" but St Philips wishes to highlight that, in the context of a substantial unmet housing need, it is not appropriate to use brownfield land over deliverable greenfield options. This is especially apparent given that the level of growth that has been accommodated on brownfield land within the Growth Network (around Strategic Centres and Regeneration Corridors) over the current Core Strategy plan period has been less than anticipated. Sustainability principle 5 of the Core Strategy states that "the vast majority of new housing will be built on brownfield land", and similar to our view on sustainability principle 4, this approach is not appropriate in the context of the unmet housing need.
Comment
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: 2865
Received: 08/09/2017
Respondent: St Philips
Most of the spatial objectives are considered by St Philips to remain appropriate, with the exception of spatial objective 3 which aims to "model sustainable communities on redundant employment land in Regeneration Corridors". In line with our responses to question 7, it is not appropriate to rely on brownfield land as a source of future housing sites within the Black Country, and Green Belt land offers the only realistic prospect for bridging the gap between housing need and supply.
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: 2866
Received: 08/09/2017
Respondent: St Philips
St Philips believes that Policies CSP1 and CSP2 need to be drastically revised based on the changing circumstances affecting the Black Country. The figures in Policy CSP1 and Table 1 within the Core Strategy will need to be updated and rolled forward to 2036 in line with the new evidence. The approach to development outside of the Growth Network, as set out in Policy CSP2, will need to be amended to reflect the need to deliver new housing within the Green Belt.
Comment
Black Country Core Strategy Issue and Option Report
Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
Representation ID: 2867
Received: 08/09/2017
Respondent: St Philips
Both Strategic Option 1A and Strategic Option 1B recognise the need for housing in the Green Belt which St Philips supports.
There are opportunities and challenges presented by both Strategic Options, but Strategic Option 1A appears to be more suitable for accommodating the growth needs of the Black Country over the BCCS Review plan period There are various opportunities provided by Strategic Option 1A, especially the provision of a sustainable pattern of development, close to the urban edge of existing settlements where need arises in the Black Country. Importantly Strategic Option 1A would significantly boost the supply of housing land and help to meet full, objectively assessed need identified in the SHMA.
Comment
Black Country Core Strategy Issue and Option Report
Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re
Representation ID: 2868
Received: 08/09/2017
Respondent: St Philips
St Philips supports Spatial Option H1 which is based on 'rounding off' the Green Belt edge by identifying small to medium sized sites in the Green Belt. There are many opportunities provided by Spatial Option H1, particularly the provision of a sustainable pattern of development. It will be important the Black Country Authorities select suitable sites in accordance with Spatial Option H1 and the identified land at Aldridge is one such opportunity. Please refer to our response to question 12b for further details.
