We have commented previously that the new BCCS will need a change of emphasis in light of the significant amount of development that will need to be delivered outside of the existing urban area. This conclusion followed a review of the urban capacity and so the focus on urban regeneration has already been secured by ensuring that the capacity of the urban area is maximised. It is only because it has been maximised that Green Belt can be justified.

We should add that, in our experience, the Black Country Local Authorities do need to understand the constraints to developing in the Black Country, particularly in respect of highways and urban design standards. Many of the existing allocations are difficult to develop and the Council will need to apply development management considerations flexibly in order to ensure the site can come forward. Many brownfield sites present physical and topographical challenges which can influence the formation of layout and design solutions. All of these are factors which should be taken into account when identifying sites for development and determining subsequent planning applications.

We understand that consideration is being given to a phasing policy for the greenfield sites. Such a policy would be wholly inappropriate and contrary to the Framework and PPG. The amount of development that will need to be delivered outside the existing urban area is far too great for such a policy to be considered and greenfield sites will be a key component to ensuring that a rolling 5 year supply of sites can be maintained across the plan period as required by Paragraph 47 of the Framework.