Comment

Representation ID: 21477

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

2.10. The evidence supporting the emerging Black Country Plan has identified that within the urban area is insufficient capacity to meet the Plan’s housing needs, even when taking into account potential opportunities for redevelopment of brownfield sites and increasing densities for new development. As a result, it has been concluded that there is sufficient justification to release land from the Green Belt through this Plan.

2.11. Whilst the need to release the Green Belt is not disputed given the scale of housing need and shortfall identified, it is a concern that the Authorities have proceeded to do so despite not exhausting all opportunities within the urban area. As a result, in order for the Plan to be justified and consistent with national policy regarding the Green Belt, the authorities need to demonstrate that all other reasonable options to meet its identified needs have been examined fully. This should include consideration of available sites within the urban area, such as the Land at Corbett Hospital, which represents underutilised land in a sustainable location within the urban area.

2.12. Therefore, in order for the Council to proceed with Green Belt release through this Plan and included within Policy CSP3, the Plan must be supported by a robust evidence base that justifies this approach. This should include identifying how all opportunities within the urban area such as the Land at the Corbett Hospital have been assessed, in order to ensure that the Plan accords with the Framework’s tests of soundness.