Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3009
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
It is clear that a combination of Options H1 and H2 will be required to deliver the significant housing requirement of the Core Strategy review. To provide a realistic prospect of achieving the housing requirement a range of sites of a variety of different sizes and locations should be identified for development in sustainable locations within the HMA. Identifying a range of sites in a variety of different locations will help create the choice and competition of the market for land and ensure delivery. It must be ensured that any proposed urban extensions are deliverable within the plan period and that, if larger sites are identified, only the part that is deliverable in the plan period is included in the supply figures. It is, therefore, necessary to understand the infrastructure requirements, likely delivery rates and the ability of sites delivered quickly when making allocations.
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.