Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2815

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Representation Summary:

Disagree. In terms of sustainability principles, a sequential approach to the prioritisation of brownfield land is no longer a policy requirement within the NPPF, paragraph 111 merely requiring that planning policies should seek to make the most effective use of land by re-using brownfield land. In context, it is acknowledged that insufficient capacity is available to meet the areas full housing and employment needs to 2036 and greenfield/green belt land will need to be developed. The objective of prioritising brownfield land and no provision for development of Green Belt land within the current BCCS has resulted in a failure to fully keep up with the current housing requirements of the area and to continue such a policy has the potential to maintain/exacerbate the current problems.

Boosting the supply of housing is a fundamental Government objective and whilst delivering sustainable development should be inherent in all planning policy objectives, meeting the future housing and economic needs of the area are critical to the social and economic roles of sustainable development, as defined within paragraph 7 of the NPPF.