Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2952
Received: 08/09/2017
Respondent: Barratt Homes and David Wilson Homes
Agent: Turley Associates
2.41 In Q1 we make the case for a full review of the BCCS. This would also necessitate a review of the vision and sustainability principles underpinning the Plan. This is particularly relevant as to date the current vision has not delivered the necessary housing growth required by the BCCS. 2.42 The adopted BCCS vision and sustainability principles reflect the area's need at that time (i.e. February 2011). Since then the NPPF has been published and the WMRSS revoked. A new vision is therefore necessary to reflect the area's needs now, which are much higher than at the time the BCCS was adopted, which is demonstrated by the admission that Green Belt land will be necessary. In contrast, no Green Belt was released by the adopted BCCS (indeed the boundaries have not been altered for over 30 years). 2.43 Furthermore, the adopted BCCS' vision is underpinned by three 'major directions of change', none of which specifically refer to meeting the Black Country's housing needs. The BCCS Review vision would be more robust if it was underpinned by the nine key issues set out at Part 3 of the I&O Report and made direct reference to the supply of new homes.
2.33 We discuss the strategy to meeting housing needs in the Green Belt in response to Q12a and Q13a.
2.34 The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land that does not serve the five purposes of the Green Belt.
2.35 As part of this the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
2.36 The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.