The BCCS has served to constrain development coming forward at the Brierley Hill Strategic Centre; and has failed to effectively control out-of-centre development from coming forward over the same timeframe. The first priority of policy must be to positively plan for development in the Strategic Centres as this would be the most effective way of controlling out-of-centre development.

The BCCS was adopted in 2011 and therefore pre-dates the National Planning Policy Framework (NPPF). Section 2 of the NPPF sets out policy for ensuring development is focused within town centres, where it will enhance the vitality and viability of centres and encourage sustainable shopping. The NPPF requires LPA's to meet the needs for retail, leisure, office and other main town centre uses in full, adopting a town centre first approach. Only when suitable and viable town centre sites are not available, should edge of centre or out of centre sites be considered. Paragraph 24 states that local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing town centre and are not in accordance with an up-to-date Local Plan.

Planning policy as it stands has not controlled out of centre development, with the majority of retail floorspace permitted in the Borough being an out-of-centre open A1 retail park type offer. Revised planning policy should therefore positively promote and encourage town centre development to allow it to be delivered, in accordance with the NPPF. As far as Brierley Hill Strategic Centre is concerned, future planning policy must avoid the imposition of pre-conditions which undermine the underlying growth objectives and constrain development from coming forward.