It is our view that a comprehensive review of the existing Black Country Core Strategy ("BCCS") is required. The reason for this is that there have been significant changes to almost all of the factors relevant to the consideration of the Core Strategy. Consequently, anything less than a full review would fail to properly consider the implications of these and would not allow for a comprehensive strategy to be developed to ensure the sustainable delivery of the development needs now identified. These changes are summarised below:

* The position with regard to national and regional planning policy and guidance has changed considerably. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy and the BCCS was produced prior to the adoption of the Framework.
* There has been a significant shift in the amount of housing and employment land that needs to be delivered, which has been informed by a new evidence base. The identified increase in need has resulted in the urban capacity being saturated and we are now in a position where a large amount of development will need to be delivered outside the existing urban area. This is a significant change and brings with it new challenges and considerations that will need proper consideration.
* The current economic climate has changed significantly since the production of adopted Core Strategy. This has resulted in:
o sites identified for housing actually having a new lease of life as employment sites and not as much surplus employment land suitable for housing as anticipated as explained in paragraph 2.5 of the Issues and Option Document.
o The value of employment land rising, reducing the incentive for owners of employment sites to sell. This is particularly pertinent given the level of occupied sites that need to be made available just to meet the allocated / committed sites.
o Combined both of these factor call into question the amount of housing and timing of delivery on these sites and will require significant discounts to be applied to this source of supply.
* The delivery approach outlined by the adopted BCCS has proven to be problematic, with delivery levels in the Regeneration Corridors significantly below that planned for. Housing delivery has been heavily supplemented by unexpected high levels of windfall sites, which has served to mask the problem. But this level of windfalls cannot be relied upon to occur again and the issue with delivery in the Regeneration Corridors confirms the unpredictability of relying on occupied employment site that are often in multi-ownerships. It also confirms the uncertainty and problematic nature of delivering brownfield sites in an established urban area that was not originally designed to meet modern day standards. Furthermore, even with the high levels of windfalls, the delivery of housing at the end of the 2015/16 year was still 3010 below the lower annualised housing target of 2625 dwellings per annum. Given the annualised OAN is now shown to be between 3432 - 3551, something clearly needs to change if these numbers are going to be met, rather than continuing to focus on a failing strategy.
* We understand from our contacts that funding, although available, has proven to be time consuming and difficult to access. Given the significant amount of external funding that is likely to be needed to make the 300 hectares of occupied employment land come forward for housing (paragraph 2.10 of the I&O document), this will impact on deliverability or whether a site can be considered developable, which are the tests set in Paragraph 47 of the Framework for housing allocations.

A new strategy is, therefore, required which will provide a range of sites on both brownfield and greenfield (including Green Belt) land which are capable of being delivered in the plan period and are attractive to the market and viable. There are inevitably limitations as to how many dwellings can be delivered on one large site, when lead in times and build out rates are taken into account. So whilst larger sites will need, it is, therefore, our view that the emerging plan should seek to direct development to sites that are deliverable within the plan period.

This approach is entirely consistent with the requirement of the Framework, which requires Local Authorities to "boost significantly" the supply of housing land. In accordance with the requirements of footnotes 11 and 12 of the Framework, housing sites should be "deliverable" and "available" in order to be allocated. The employment land led Regeneration approach of the emerging Core Strategy has failed this test at least to some degree. A more flexible and dispersed approach is needed and compliant with the Framework.