Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2864

Received: 08/09/2017

Respondent: St Philips

Representation Summary:

The Core Strategy vision is considered by St Philips to remain appropriate because it accords with the three dimensions of sustainable development outlined in the NPPF which stems from social, economic and environmental roles.

The Core Strategy sustainability principles are considered to remain largely appropriate, although it is St Philips view that sustainability principle 4 "putting brownfield first" is no longer as relevant. This sustainability principle focuses on "ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised for development over greenfield sites" but St Philips wishes to highlight that, in the context of a substantial unmet housing need, it is not appropriate to use brownfield land over deliverable greenfield options. This is especially apparent given that the level of growth that has been accommodated on brownfield land within the Growth Network (around Strategic Centres and Regeneration Corridors) over the current Core Strategy plan period has been less than anticipated. Sustainability principle 5 of the Core Strategy states that "the vast majority of new housing will be built on brownfield land", and similar to our view on sustainability principle 4, this approach is not appropriate in the context of the unmet housing need.