Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 35 - Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why.
Representation ID: 2879
Received: 08/09/2017
Respondent: St Philips
St Philips has not undertaken a detailed assessment of any evidence on which the housing land supply within the BCCS Review is based. The Issues and Options consultation document outlines various sources of potential housing land supply and notes that if these sources prove to be of strategic significance, they will form a part of the housing land supply within the new Core Strategy. The potential sources of supply referred to in the Issues and Options consultation report are not disputed by St Philips; however, such sources of supply should not be relied upon in the future given some of these have failed to deliver in the past. Green Belt land is definitely required as a source of future housing land supply.
Comment
Black Country Core Strategy Issue and Option Report
Question 38 - Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and
Representation ID: 2880
Received: 08/09/2017
Respondent: St Philips
St Philips supports the proposal in the Issues and Options consultation document to remove the final paragraph of policy HOU2. St Philips would object to accessibility standards applied to all residential allocations as this could threaten the viability and deliverability of sites. It would also conflict with recent information set out in the Housing White Paper.
The wording of Policy HOU2 should be changed to refer to accessibility and density standards being determined by local factors. The current accessibility standards set out in policy HOU2 may not be appropriate for Green Belt release sites and should be fully tested in relation to emerging residential allocations on the basis of viability.
Comment
Black Country Core Strategy Issue and Option Report
Question 40 - Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
Representation ID: 2881
Received: 08/09/2017
Respondent: St Philips
The SHMA may be appropriate for setting general house type targets for the plan period; however, a flexible approach should be adopted by the Black Country Authorities to allow for changing local circumstances. The Issues and Options consultation document refers to the need for sheltered and extra care houses, and there should also be a flexible approach to these tenures so as not to preclude the viability and deliverability of sites (particularly Green belt release locations).
Comment
Black Country Core Strategy Issue and Option Report
Question 42 - Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
Representation ID: 2882
Received: 08/09/2017
Respondent: St Philips
Whilst St Philips appreciates the importance of affordable housing and the role of the Black Country Authorities in ensuring that all housing development of a reasonable scale contributes, the prescriptions within Policy HOU3 should be flexible and refer to the requirements being subject to viability considerations.
Comment
Black Country Core Strategy Issue and Option Report
Question 44a - Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any Further comments.
Representation ID: 2883
Received: 08/09/2017
Respondent: St Philips
The requirement for 25% affordable homes on eligible sites should only be kept at this level if it does not threaten the viability and deliverability of housing sites. The wording of Policy HOU3 should make this clear.
Comment
Black Country Core Strategy Issue and Option Report
Question 45 - Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
Representation ID: 2884
Received: 08/09/2017
Respondent: St Philips
The affordable housing requirement for Green Belt release sites should not be increased as this will jeopardise the viability and deliverability of these sites. As such, this proposal is strongly opposed by St Philips.
Comment
Black Country Core Strategy Issue and Option Report
Question 47 - Do you think that Policy HOU5 should be expanded to cover other types of built social infrastructure and to set out standards for built social infrastructure to serve major housing devel
Representation ID: 2885
Received: 08/09/2017
Respondent: St Philips
The provision of social infrastructure is an important part of any development proposal, and particularly those of a large scale. However the requirements established in the new Core Strategy should be tested so that they do not threaten the deliverability or viability of small to medium sites. Major housing developments should be defined within Policy HOU5 so it is clear which sites the provision of social infrastructure would apply to.
Comment
Black Country Core Strategy Issue and Option Report
Question 95a - Do you think Garden City principles should be applied in the Black Country? Yes/No; If yes, how should they be applied?
Representation ID: 2886
Received: 08/09/2017
Respondent: St Philips
Garden City principles are considered by St Philips to be a sensible approach for new housing growth within the Black Country to ensure that development is sustainable, but if Garden City Principles are added to the new Core Strategy policies, these should be tested to ensure that they do not threaten the viability or deliverability of housing sites.
Comment
Black Country Core Strategy Issue and Option Report
Question 95b - Should the application of Garden City principles be different for brownfield and greenfield sites? Yes/No; If yes, please explain why.
Representation ID: 2887
Received: 08/09/2017
Respondent: St Philips
Different Garden City principles may be appropriate for brownfield and greenfield sites but this would need to be robustly tested if the distinction is proposed to be written on to policies within the new Core Strategy.
Comment
Black Country Core Strategy Issue and Option Report
Question 98 - Do you support the proposed changes relating to Design Quality? Yes/No; If you think that any other changes should be made to Policy ENV3 please provide details.
Representation ID: 2888
Received: 08/09/2017
Respondent: St Philips
The proposed changes to Policy ENV3 to delete reference to the Code for Sustainable Homes Level 3 is supported by St Philips, as this no longer aligns with national planning guidance and legislation.
