No, a complete new Plan is required rather than a partial review of the existing Black Country Core Strategy (BCCS). The consultation document confirms that the delivery approach outlined by the adopted BCCS is proving problematic with limited residential development being delivered in the Regional Corridors. The development requirements and the distribution of development in of the BCCS are based upon the revoked West Midlands Regional Spatial Strategy. The BCCS was produced prior to the adoption of the Framework. The emerging BCCS is also being prepared in a significantly different economic climate to the adopted document. Furthermore, there have been a significant shift in the amount of housing and employment land informed by a new evidence base that is required that the revised BCCS needs to respond to. These factors clearly indicate that a new approach should be taken to the development through the Core Strategy review.

The adopted BCCS seeks to deliver development by focusing the majority of the housing and employment land requirement in the Growth Network and a series of Regeneration Corridors. It is, however, advised in the "Delivery" section of the emerging Core Strategy (paragraphs 2.5 to 2.11) that the level of residential in the Regional Corridors is "less than anticipated". Housing delivery in the Black Country has been boosted by the windfall sites.

The Growth Network and Regeneration Corridor approach in the adopted Core Strategy is based upon the delivery of a significant quantum of housing on surplus employment land. The emerging plan advises in paragraph 2.5 that it has transpired that there is "not as much surplus employment land suitable for housing as anticipated". This is partly because the economy has strengthened and local firms are more robust than expected and partly because the sites are more affected by constraints than expected.

Indeed, it is specifically advised that the higher than anticipated levels of windfall development do "conceal a delivery challenge". There is a large number of major housing sites currently concentrated the Growth Network. However, many of these sites have multiple constraints and financial assistance is required for them to come forward (paragraph 2.10). This includes 300 hectares of occupied employment land which has been allocated for housing. This approach brings issues of viability due to the cost of land assembly, business relocation and land remediation. Significant amounts of external funding are required to deliver these housing sites. Whilst some funding is available, it is not sufficient to cover the costs of compulsory purchase, which may be necessary on many sites. The sites are clearly not "deliverable" or "developable" in the context of the housing allocation tests put in place by paragraph 47 of the Framework. To be considered deliverable, sites should be available for development now and there should be a realistic prospect that housing will be delivered on the sites. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. This is not the case with a significant number of the employment allocations within the adopted BCCS; by the emerging Core Strategies own omission.

It is, therefore, our view that the approach of the adopted BCCS in seeking to focus new residential development on poor quality employment land will not deliver the housing numbers required. In addition, as referred to in response to Question 4, new evidence identifies a significant requirement for additional employment land. As a consequence, the emerging BCCS should adopt an approach that places less reliance on the delivery of housing on employment land.

A new strategy is 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. These allocations should be made within the Housing Market Area generally, not just the Black Country, in order to provide a variety of housing sites in sustainable locations.

The Strategy should also be focused on identifying development sites that are deliverable within the plan period. It is, therefore, our view that the emerging plan should not place an overreliance on delivery from large scale urban extensions that have the potential not to be built out during the course of the plan period.

This approach is entirely consistent with the requirement of the Framework. The Framework 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 advocated by the Representator is a Framework compliant approach.