Comment

Representation ID: 2534

Received: 04/09/2017

Respondent: Hawksmoor

We agree with the majority of the principles, in particular the requirement for sustainable development and also a comprehensive approach to development. However, we contend that the 'brownfield first' principle will become outdated during the course of the new Plan period, and therefore this principle should be augmented to reflect such.

At Paragraph 3.11 of the Issues and Options document, the Strategic Housing Needs Study (2015) is referenced. The study concluded that the supply of brownfield land across the HMA is insufficient to accommodate this shortfall, and that the majority of that shortfall will have to be met on greenfield sites, including those in the Green Belt. Furthermore, many brownfield housing sites within the Black Country are unviable due to the substantial costs required to bring them forward for development such as remediation and access infrastructure.

Therefore, we would welcome reference in the vision and sustainability principles to the need to accommodate the majority of housing need on greenfield sites to ensure a sustainable supply of housing and therefore supporting economic growth.