Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2967
Received: 08/09/2017
Respondent: Barratt Homes and David Wilson Homes
Agent: Turley Associates
2.95 As set out in response to Q2, the infrastructure assessment work to be undertaken by the authorities will be critical to informing what infrastructure will be necessary to unlock new development. 2.96 Since the BCCS was adopted it is apparent that it is unviable for some brownfield sites to deliver the necessary infrastructure to assist their delivery (as much is acknowledged at Section 2 of the I&O Report). The four authorities should therefore satisfy themselves that it is viable for new development to contribute towards providing infrastructure to meet their needs, including through Section 106 contributions or the Community Infrastructure Levy, and that any onerous policy requirements in relation to matters such as housing mix or sustainable design features does not comprise viability.
2.97 Other tools and interventions should not be relied upon if they have not been confirmed as available to improve infrastructure before the BCCS Review is adopted.
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.