In general terms the proposed approach follows both national policy and the approach set out in the 2017 Housing White Paper. However, we are concerned on two points.

Firstly, the review should address whether the changes to the green belt that would be required are such that they would restrain the ability of both the Black Country Authorities and the neighbouring authorities to meet the full extent of the assessed housing need. DCLG has recognised this as a possibility in its October 2014 statement, "Councils must protect our precious Green Belt land". This statement has been incorporated into National Planning Practice Guidance (ID 3-045-20141006, https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment) and is reiterated in the House of Commons Briefing Paper 'Green Belt' published in January 2016 (http://researchbriefings.parliament.uk/ResearchBriefing/Summary/SN00934)

Secondly, the review should integrate consideration of compensatory improvements to the environmental quality or accessibility of remaining Green Belt land that should be associated with the release of Green Belt land for development, as set out in paragraph 1.39 of the Housing White Paper.