Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2988
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
It is considered that the spatial objectives need to be revisited to ensure they are up to date and are a sound basis for meeting the emerging housing needs. It is therefore imperative that these needs are reflected in the objectives, which will be used to measure the success of the Plan. The objectives must also be more robust than those of the current BCCS owing to the admission that the BCCS Review will test the deliverability of sites in the Green Belt, some of which will lie in South Staffordshire. In addition, there must be reference made to the duty to cooperate and the requirement for the Black Country Authorities to work collaboratively on planning issues that cross administrative boundaries, such as the Green Belt Review and the delivery of new homes.
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.