We consider that a more in depth analysis needs to be undertaken of the brownfield windfall sites which make up the housing supply and, in particular, their ability to be brought forward. It is not clear to the development industry, given the current rates of completions and the need for a significant step up in delivery rates, that the windfall sites will come forward at the rate required.

A study needs to be undertaken regarding the true capacity likely to be obtained from brownfield windfalls. This will help to identify an appropriate non completion allowance.

As noted in the response to Question 1, we also believe that the SHMA needs to be reviewed so that it follows the housing market area and not simply Local Authority boundaries.

We further support the intention identified at paragraph 3.11 that the Council intends to explore new means of providing housing beyond the housing market area used for the BCCS review where there are clear migration or commuting links with Local Authorities. This strengthens our view that the SHLLA may have to be reviewed because of the linkages with surrounding authorities.

We also note that there appears to be no acknowledgement that the current shortfall provision, identified at some 3,000 units, has been taken into account in the housing requirement figure.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the preferred options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Authorities to properly digest the findings of the Green Belt review and identify strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.

Finally, we believe that further research should be undertaken regarding the effect of Government grant regimes in bringing sites forward. Our experience to date has been that the programmes have been time consuming, costly and unwieldly and have had limited benefit in helping to increase the supply of housing land.