These representations are made on behalf of Heyford Homes Ltd which has various land interests in the West Midlands and beyond. The representations do not address in any detail the scale or nature of the need for new housing in the Black Country though the right to do so at later stages of the BCJCS Review process is reserved.

However the published evidence & other material which informs the Issues & Options consultation demonstrates that there is a clear need to allocate a substantial amount of additional land for new housing; and that this need cannot be met without releasing for development a significant amount of land that is currently within the Green Belt.

The BCJCS Review's approach to addressing this challenge needs to consider all options available and the potential of releasing land in the Green Belt which is of little functional value or strategic landscape importance should be seriously explored, especially where land is visually enclosed and so where development would have little or no impact on the charactor or openness of the wider landscape and so where development would not prejudice the purposes for which Green Belt is designated.

It should also recognise that new housing in such areas can help sustain currently less than sustainable patterns of development, for example by extending in an organic way existing enclaves of development to enhance their security & conviviality and by making public transport serving the existing network of settlements more viable.

Further, the Review should note that development which meets the above criteria can also contribute to meeting the immediate need to address the shortfall in the supply of new, high quality housing essential to attracting & retaining high skilled workers, as acknowledged by BCJCS Policy HOU 2 (esp para 3.2) and Policy
PL3 Housing of the Black Country Strategic Economic Plan. Such development at a relatively modest scale would not detract from the thrust of whatever overarching spatial strategy is pursued and should be supported as making a positive contribution to achieving wider policy objectives as well as meeting local and
Black Country wide housing needs.

The BCJCS Review process is urged to give positive consideration to taking such an approach in its review of the Green Belt; and also to giving positive consideration to facilitating the grant of planning permissions now where such development can meet immediate needs.