We agree that a review of the Green Belt review is an imperative element of the new Core Strategy. As referred to above, it is our view that the Green Belt review should be prioritised so it is prepared in good time to inform the Preferred Options Consultation Core Strategy that is expected to be published in September 2018. The extent of the Green Belt review should be wide reaching. The Green Belt review should not just be focused on Green Belt land within the Black Country and immediately adjacent to it. A wide range of housing sites in a variety of locations within the HMA will be required to meet the significant housing shortfall identified by the emerging plan. The Green Belt review should examine the role that the Green Belt plays around the principle settlements within the HMA. In this regard we fully support the recognition that the Green Belt review should explore potential sites suitable for Green Belt land release within South Staffordshire. This should include the land surrounding the South Staffordshire's main settlements.

It is also our view that the Green Belt review should extend beyond the current plan period. Paragraph 83 of the Framework advises that once established Green Belt boundaries should only be altered in exceptional circumstances. When undertaking Green Belt reviews local authorities should consider revised Green Belt boundaries having regard to their intended permanence in the long term so they are capable of enduring beyond the plan period. When defining boundaries, Local Planning Authorities should, where necessary, identify areas of safeguarded land between the urban area and the Green Belt in order to meet long term development needs.

It is unlikely that significant new urban capacity will be found in the Black Country going ahead. Subsequent versions of the BCCS are likely to have to continue to rely upon Green Belt land release to meet the overall housing requirement. The Green Belt review and emerging plan should, therefore, look to identify land that can be removed from the Green Belt and safeguarded for development to meet development needs beyond the current plan period.