Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 3025

Received: 07/09/2017

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Representation Summary:

Whilst we appreciate the need to have regard to new standards regarding SuDS provision, the implications on site layout and viability do need to be considered. A flexible approach is required from the Local Authorities in assessing individual schemes taking into account matters such as viability and the impact on density. In particular, a joint approach is needed by statutory undertakers to ensure that SuDS areas can be adopted if they are provided as part of wider open space areas.

Full text:

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.

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