Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2973
Received: 08/09/2017
Respondent: Barratt Homes and David Wilson Homes
Agent: Turley Associates
2.107 The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1. As set out in our response to Q1 a full review of the Plan is necessary given there are now greater housing needs, the NPPF has been published and the WMRSS has been revoked, and the adopted BCCS has not been delivering the required level of growth. As such the approach to housing land supply should be reviewed in full also. 2.108 Given there is a shortfall of 3,039 dwellings against the targets set in the adopted BCCS (a shortfall of 1,396 in Wolverhampton), largely as a result of brownfield sites not being developed due to viability issues, the Review should include a 10% lapse rate should be applied to the requirement to ensure flexibility in deliverability should sites in the supply not come forward.
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.