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Black Country Core Strategy Issue and Option Report

Representation ID: 595

Received: 08/09/2017

Respondent: IM Properties

Agent: Harris Lamb

Representation Summary:

We consider that Option 1A is to be preferred to strategic Option 1B. That said, we believe there continues to be an over reliance upon brownfield/greenfield sites in the existing housing supply and there is also an over reliance on brownfield windfalls in estimating further housing supply. We consider that overall the greenfield requirement should be increased to ensure delivery. Greenfield sites are typically less constrained than their brownfield alternative and, unlike a significant number of its active employment sites allocated for housing by the adopted Core Strategy; they are available for development now.

Full text:

We consider that Option 1A is to be preferred to strategic Option 1B. That said, we believe there continues to be an over reliance upon brownfield/greenfield sites in the existing housing supply and there is also an over reliance on brownfield windfalls in estimating further housing supply. We consider that overall the greenfield requirement should be increased to ensure delivery. Greenfield sites are typically less constrained than their brownfield alternative and, unlike a significant number of its active employment sites allocated for housing by the adopted Core Strategy; they are available for development now.