We respond to the identified key issues as follows:

* We agree the existing evidence base for the adopted BCCS is outdated. The adopted BCCS was based upon the requirements of the now revoked West Midlands Regional Spatial Strategy and is a pre Framework document. It was prepared in the middle of the economic downturn and its evidence base reflects these circumstances. There has been a fundamental change in the economy and significant changes to national and regional planning policies since the adoption of the Core Strategy. A selective review of the evidence base is not, therefore, appropriate. A comprehensive review of the evidence base is required.

* We agree that there is a need to continue to plan for a growing population. However, the SHMA underestimates the housing requirement as it does not taken into account affordable housing needs. Furthermore, the emerging plans housing requirement needs to take into account the fact that not all housing allocations deliver as expected. As a consequence the housing requirement will need to be significantly above the objectively assessed housing needs figure within the SHMA. The suggested "gap" between supply and requirement for housing 22,000 dwellings is, therefore, less than that actually required.

* We note that evidence suggest that the economy is forecast to grow. This should be actively encouraged by the plan. The adopted BCCS relies upon significant new housing development on employment sites. Whilst these employment sites may have been largely vacant at the time and the preparation of the adopted BCCS, this situation has now changed. As demonstrated by the EDNA a number of these sites are now flourishing. The sites should, therefore, be protected for employment purposes and residential development directed elsewhere.

* We agree that the Green Belt review is essential to the emerging Core Strategy given the lack of urban capacity. We fully support the preparation of the Green Belt review. The Green Belt review should assess suitable development locations within the HMA generally in order to inform the emerging Core Strategy.