Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2995
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
The BCCS Review proposes at paragraph 6.30 to 'update' Policy HOU1, which in our view is considered necessary. There are now greater housing needs, the NPPF has been published and the WMRSS has been revoked, and the adopted BCCS has not been delivering the required level of growth.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. Given there is a shortfall of 3,039 dwellings against the targets set in the adopted BCCS, largely as a result of brownfield sites not being developed due to viability issues, the BCCS 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.
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.