Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2998
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
No.
A more in depth analysis of brownfield land take up rates is needed, particularly in relation to employment sites that are expected to deliver housing to ensure that they are a credible source of supply. Allot of these sites are occupied and in multiple ownership and so this will need to include clear evidence about how land assembly will be achieved. We have reviewed the four authorities Annual Monitoring Reports (although the latest AMR for Wolverhampton dates back to 2013/14) and whilst delivery in the Regeneration Corridors is touched upon, it is clear that completions are limited and commitments are being used to divert attention. A much clearer analysis of this position with regard to delivery rates achieved and those predicted going forward is needed.
We support the inclusion of the Green Belt review, although we consider it is imperative that this is prioritised. This is an important document in defining the amount of the identified need that can be accommodated in the Black Country Authority administrative areas and the extent and will ultimately be a key piece of evidence in defining the strategy. Currently it is stated that the Green Belt review will not be completed until mid-2018, with the Preferred Options consultation being undertaken in September 2018. In this context, we are concerned that there is simply insufficient time for the Authorities to properly digest the findings of the Green Belt review and properly consider/action the matters identified above.
We agree that the evidence clearly demonstrates that a Green Belt review is needed to meet the development needs identified and that this is an essential component of the new Core Strategy.
However, it is also our view that the Green Belt review should extend beyond the current plan period in accordance with the Framework, which explains that when undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. In this context, it is highly likely that the need for housing and employment land will continue to grow and that capacity in the urban area will not exist to meet these needs. Consequently, safeguarded sites will also need to be identified. It is our view that the period up to 2051 should be considered. This is 15 years beyond the end of the existing plan period and links to the time period that local authorities are required to identified a supply of sites for (Paragraph 47).
Whilst the Green Belt review might be undertaken by the BCAs and South Staffordshire, it is important that the review is not just confined to their administrative area. Other authorities also directly adjoining the BCAs and an understanding of the function of the green belt along these boundaries is also important so that all the options available to deliver the housing need are considered.