Comment

Representation ID: 2824

Received: 13/09/2017

Respondent: ROSCONN STRATEGIC LAND

Agree / Support Spatial Option H1.
It is considered that the focus should be on Spatial Option H1 Rounding Off: the identification of small to medium sized Green Belt releases (up to 500 dwellings) on the edge of existing urban areas within the Black Country. Due to the potential impact on key purposes of the Green Belt, larger scale SUEs are far more likely to give rise to concerns such as urban sprawl, coalescence and encroachment into the countryside, all key issues for a heavily urbanised area.

We would question why the table at paragraph 4.30 in respect of Spatial Option H2 states that one of the benefits of SUEs would be to significantly boost the supply of housing and maximise the provision of affordable housing. Spatial Option H1 would also achieve this objective assuming a similar quantum of housing overall is allocated and that such allocations are of sufficient scale (i.e. greater than 10 / 15 dwellings) to deliver on-site affordable housing. If anything, Spatial Option H1 has the ability to deliver greater levels of affordable housing sooner in the plan period, due to the ability to bring forward housing in sustainable locations without the need for extensive infrastructure provision, whereas it is common for SUEs to seek a reduction in overall affordable housing provision based on the need to fund supporting infrastructure early on in the build out.

Clearly, the Green Belt Review will help further inform the strategy and it may well be that there is scope to identify some SUEs without creating significant harm to the purposes of the Green Belt. A mixed portfolio of sites may therefore be an appropriate strategy, but the likelihood is that the majority will be small to medium sized sites, which in any case are likely to provide a more reliable and deliverable supply of housing throughout the Plan period, as opposed to an overreliance on a small number of large scale SUEs.