Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3014
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
We have commented previously that the new BCCS will need a change of emphasis in light of the significant amount of development that will need to be delivered outside of the existing urban area. This conclusion followed a review of the urban capacity and so the focus on urban regeneration has already been secured by ensuring that the capacity of the urban area is maximised. It is only because it has been maximised that Green Belt can be justified.
We should add that, in our experience, the Black Country Local Authorities do need to understand the constraints to developing in the Black Country, particularly in respect of highways and urban design standards. Many of the existing allocations are difficult to develop and the Council will need to apply development management considerations flexibly in order to ensure the site can come forward. Many brownfield sites present physical and topographical challenges which can influence the formation of layout and design solutions. All of these are factors which should be taken into account when identifying sites for development and determining subsequent planning applications.
We understand that consideration is being given to a phasing policy for the greenfield sites. Such a policy would be wholly inappropriate and contrary to the Framework and PPG. The amount of development that will need to be delivered outside the existing urban area is far too great for such a policy to be considered and greenfield sites will be a key component to ensuring that a rolling 5 year supply of sites can be maintained across the plan period as required by 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.