Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3016
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
We do not favour the prioritisation of brownfield land over greenfield land. This is not a Framework compliant approach. Given the considerable amount of housing required across the plan area it is necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market, given their geographical detachment in the large parts of the Growth Network and will provide a different type of development sites.
In terms of a discount rate it is now evident that the Growth Network has not delivered houses as expected. It is, therefore, our clear view that there should be an increase in the discount rate that should result in the overall housing requirement being increased relatively significantly. An alternative would be to over allocate and provide reserve sites in line with the LPEG report. This would see a 20% increase in allocations through the identification of reserved sites that could be drawn upon where a 5 year supply cannot be demonstrated.
We make no comment at this stage about proposals for high density allocations within the strategic centres other than to say that market research should be carried out to ensure there is both demand and an appetite from the housebuilding industry to provide this type of product.
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.