Comment
Draft Black Country Plan
Representation ID: 23217
Received: 11/10/2021
Respondent: Heyfield Development
Agent: Harris Lamb
Policy CSP1 (2)
The second part of CSP1 sets out eight criteria which explain how the spatial strategy seeks to deliver this growth and sustainable patterns of development. Most of these are well
considered and accord with national policy. However, we do have comments on two of the criteria:
• 1st criteria – it remains to be seen whether the “majority” of development can be delivered in the urban area within the plan period. This is already marginal when the overspill is accounted for and with the issues raised above it could well be that this balances switches. This is important, because it helps contextualise the importance that greenfield sites will play if the development needs identified are going to be met.
• 4th criteria – HD agrees that very special circumstances exist to release sites from the Green Belt, and whilst there it is questionable whether the BCA have taken the opportunity to release an appropriate level of sites within its administrative area, it is evident that the numbers are so large that the BCA will need to continue to work with the adjoining authorities to deliver the development needs identified.