Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2993
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
For the purpose of demonstrating soundness, the Black Country Authorities will need to demonstrate the BCCS Review is effective i.e. it must be deliverable over its plan period and based on effective joint working on cross boundary strategic priorities, which includes the delivery of significant housing growth. If the Black Country Authorities conclude that the objectively assessed housing need cannot be met within its own administrative boundary then it must act in accordance with paragraph 178 of the NPPF which outlines public bodies (e.g. local authorities) have a duty to cooperate on planning issues that cross administrative boundaries. It is therefore expected that should the Black Country Authorities be unable to meet their objectively assessed housing needs joint working will be required with neighbouring authorities, such as SSDC, where there are sustainable opportunities for housing growth (i.e. land at Jones Lane, Great Wyrley) in proximity to the edge of an existing urban area; proximity to a rail station; available existing physical and social infrastructure; and easy access to jobs.
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.