Comment

Representation ID: 2806

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Disagree. We do not agree that the Black Country Core Strategy (BCCS) review should be a partial review, retaining / stretching the existing spatial strategy and updating existing policies. The existing Core Strategy was adopted in 2011 prior to the publication of the NPPF and is therefore not fully consistent with more up to date national planning guidance. Whilst it may well be that certain objectives, strategies and/or policies of the BCCS remain relevant, a full and comprehensive review is necessary to ensure it remains fit for purpose and fully reflects Government guidance, albeit reflecting up to date evidence and local circumstances. Indeed, notwithstanding changes to national policy, there are a whole series of new challenges facing the area as identified within the document, such as HS2, extension of the Midland Metro and the identified housing shortfall within Birmingham (and the wider HMA).

A significant change in circumstances since the current BCCS was prepared is the fact that there is an identified shortfall in capacity within the Black Country's existing urban areas to accommodate future housing and employment land. The document acknowledges that the scale of the shortfall will therefore require the release of Green Belt within the area, noting that there has been no strategic review of the Green Belt since its designation in the late 1970's. This issue alone requires a fundamental review of the spatial strategy on the premise that the current BCCS sought to fully maintain original Green Belt boundaries.

In reviewing the documents, it is also clear that the current spatial strategy has failed to deliver the level of pre-NPPF housing required during the period 2011-2016, with a shortfall of just over 3,000 dwellings against the housing trajectory. A review of the spatial strategy is therefore required in order to address this problem, ensuring that going forward, the objectives of the NPPF to boost significantly the supply of housing is achieved from the outset by meeting in full the objectively assessed housing need for the area, together with any shortfall within the area and those required to be met within the Black Country under the Duty to Cooperate.