Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2986
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
The nine key issues identified at Part 3 of the I&O Report represent the matters which will be integral to the BCCS Review achieving its ambitious plans for growth. Mindful of the ambitious levels of growth proposed for the Black Country, the three key issues relate to housing need, the need for a review of the Green Belt, and the importance of working effectively with neighbours are the most important to take account through the BCCS Review. The need to review the role and extent of the Green Belt in order to meet the housing needs of the area should be seen as a critical thread throughout the BCCS Review, reflecting issues specific to the Black Country. The key to unlocking this significant level of growth will be meeting the duty to cooperate on the homes needed in the Greater Birmingham and Black Country Housing Market Area.
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 which it is unnecessary to be kept permanently open.
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.
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.
The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the Black Country Green Belt Review to conclude which land is suitable for Green Belt release.
The Green Belt Review should be carried out in conjunction with assessing sustainable locations for residential development in neighbouring authorities such as SSDC, which falls within the same strategic housing market area and maintains strong economic links.