It is noted that there is a significant gap between the anticipated requirement for employment land and the supply of employment land. Approximately 300 hectares of new employment land is required during the plan period on unallocated sites. We have no particular concerns with the quantum of employment land identified and the recognition that it should be directed towards the Growth Network. Indeed, the emerging BCCS specifically advises that there are significant areas of employment land within the Black Country allocated for residential development that are now in an active and productive economic use. These locations should clearly be the preferred locations for employment land provision given that they are functioning and attractive employment sites.

This approach does, however, have clear implications for housing delivery. It is our view that the Black Country Authorities can no longer rely on significant new levels of residential development coming forward on employment sites. This further reinforces the Representor's view it is necessary for the emerging plan to look beyond the confines of the existing urban area and to deliver new residential development in sustainable locations on greenfield and Green Belt sites within the wider HMA.