Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 3023
Received: 07/09/2017
Respondent: Dr Baljit Bhandal
Agent: Harris Lamb
The use of the term is misleading and for many will invoke tree line streets, low density development, etc., rather than the underlying principle of creating new planned settlements where people can live, work and play. It is also misleading because no new towns are being proposed. A review of the TCPA website reveals that a number of the principles identified are things that fall within current planning guidance (e.g. Promotion of sustainable transport methods, the relationship between jobs, services and homes, etc.) It would be more appropriate to draw out the principles that are relevant to the Black Country and that acknowledge that the Black Country is an established urban area of a large number of interlinked settlements.
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.