Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3002
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
We respond to the identified key issues as follows:
We agree the existing evidence base for the adopted BCCS is dated; however, for the reasons identified above, we do not consider that a selective review of the evidence base is appropriate. A comprehensive review of the evidence base is required. We agree that there is a need to continue to plan for a growing population. However, the volume of housing as identified by the Council that will need to be developed in the Green Belt is too great to say that brownfield sites will be prioritised. This is before our concerns with regard to the delivery of these brownfield sites are taken into account, which would serve to put further reliance on sites outside the urban area. In terms of the identification of employment land, this should also make reference to the 'right type' of land. It is not just about the quantum of land, but making sure that sites meet the needs identified in the Economic Development Needs Assessment ("EDNA"). We agree that the Green Belt review is essential to the emerging Core Strategy given the lack of urban capacity.
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.