No, we consider that a more in depth analysis needs to be undertaken of brownfield land take up rates, particularly on the employment sites that are expected to deliver housing to ensure that they are a credible source of supply. It is not clear that the development industry will bring these sites forward as anticipated. The existing SHLAA fails to provide sufficient information on the suitability of these sites for development and their availability and viability to properly inform whether they are a realistic source of housing land supply.

We are also of a view that the Black Country Green Belt review should prioritised. It is noted that it is suggested that the Green Belt review will not be completed until mid 2018. It is, however, anticipated that the Preferred Options consultation will be undertaken in September 2018. There is going to be a clear reliance on Green Belt sites in delivering the emerging housing requirement. We are concerned that there is insufficient time for the Authorities to properly digest the findings of the Green Belt review and identify a strategy for new development based upon Green Belt land release in and around the Authority area in the time allowed between the completion of a Green Belt study and the publication of a consultation document.