Support

Representation ID: 43926

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Vision for the Black Country and objectives
3.2 IM Land support the overall Vision for the Black Country and its central aim of
“…creating a prosperous, stronger and sustainable Black Country”, which needs to be
flexible to allow the authorities to respond to future challenges. In achieving this the
strategic priorities however need some further consideration.

3.3 As we explore further in these representations, the remaining unmet need for the
Black Country could be a significant issue. Strategic Priority 3 under the ‘housing that
meets all our needs’ objective should therefore place greater emphasis on this matter
and that all options will be explored to ensure the Black Country’s needs are met in full.
We discuss the policies relevant to the strategic priority further below in terms of draft
policies HOU1 and HOU2.
3.4 We note that Strategic Priority 7 under the ‘enabling a strong, stable and inclusive
economy’ objective seeks to provide a balanced portfolio of employment sites, as well
to protect and enhance existing sustainable employment areas. It must be reflected on
as to whether the plan’s current strategy of proposing to allocate active employment
sites for new homes and a lack of policy protection for employment sites being lost to
other uses would deliver this strategic priority, which we discuss further below in terms
of draft policies HOU1 and DEL2.
3.5 We welcome Strategic Priority 15 under the ‘meeting our resource and infrastructure
needs’ objective as it seeks to ensure the necessary infrastructure is in place to support
its existing and future growth. However, at this stage of the BCP preparation, the
Evidence Base which underpins the emerging BCP is incomplete. This needs to be
updated to inform any infrastructure identified for proposed allocations.