Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3003
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
We are content with four of the five Core Strategy provisions and sustainability principles, but the fourth bullet point "brownfield first" is no longer appropriate. By necessity the reliance on brownfield development will need to be significantly reduced and it is already acknowledged that at least 22,000 to 25,000 new dwellings and 300 hectares of employment land may have to be allocated on greenfield/Green Belt sites. As referred to in above, we are of a view that the number of dwellings should actually be higher than this, which would further emphasise the role of greenfield sites.
The brownfield first requirement is also not in accordance with the guidance in the Framework. The Framework identifies 12 Core Planning Principles at paragraph 17. Here the Framework seeks to "encourage" the effective use of brownfield land. It does not, however, make it sequentially preferable to greenfield sites. The Framework acknowledges that there are instances where the development of greenfield land is preferable to brownfield sites for a variety of different reasons. This should be reflected in the emerging Plan.
It is also important to draw a distinction between the concept of 'brownfield first' approach when considering whether urban capacity exists to meet the development needs identified, and an attempt to rank brownfield and greenfield sites when it has been identified that a significant volume of greenfield sites are needed to meet the development needs. It was suggested at the public consultation event I attended that phasing of greenfield sites was being considered. This would be wholly inappropriate. Greenfield sites will represent such a large number of dwellings that leaving them to be considered for another day would undermine their delivery. The role of greenfield sites is also not only important in terms of overall numbers, but also providing more certainty in delivery in the short term. Currently we think the 5 year housing land supply positions presented for the BCAs are overly optimistic and greenfield sites will be needed if sufficient delivery is going to be achieved in the early years of the plan to address the existing backlog and more generally the increased annual requirement.
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.