A more in depth analysis of brownfield land take up rates is needed, particularly in relation to employment sites that are expected to deliver housing to ensure that they are a credible source of supply. Allot of these sites are occupied and in multiple ownership and so this will need to include clear evidence about how land assembly will be achieved. We have reviewed the four authorities Annual Monitoring Reports (although the latest AMR for Wolverhampton dates back to 2013/14) and whilst delivery in the Regeneration Corridors is touched upon, it is clear that completions are limited and commitments are being used to divert attention. A much clearer analysis of this position with regard to delivery rates achieved and those predicted going forward is needed.

We support the inclusion of the Green Belt review, although we consider it is imperative that this is prioritised. This is an important document in defining the amount of the identified need that can be accommodated in the Black Country Authority administrative areas and the extent and will ultimately be a key piece of evidence in defining the strategy. Currently it is stated that the Green Belt review will not be completed until mid-2018, with the Preferred Options consultation being undertaken in September 2018. In this context, we are concerned that there is simply insufficient time for the Authorities to properly digest the findings of the Green Belt review and properly consider/action the matters identified above.