Object
Black Country Core Strategy Issue and Option Report
Representation ID: 3008
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
We do not support Option 1B. We believe it places an over reliance on brownfield/windfall sites and there is no real certainty that further employment land can be released over the plan period to provide housing opportunities. Indeed, current evidence already suggests that the reliance on occupied employment sites is failing to secure the delivery of a sufficient number of houses in order to meet the current annualised target which is well below what will be needed following the review.
In this context, we consider that Option 1B would not meet the objectives of the housing policies of the Framework, particularly those that require the planning system to "boost significantly" the supply of housing land and to ensure that the allocations are deliverable and developable in the context of the requirements of paragraph 47 of the Framework.
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.