We have commented previously that the new BCCS will need to shift the emphasis away from urban regeneration towards a more balanced provision of brownfield and greenfield sites. Part of the problem with the delivery of brownfield sites in the urban area are that they are returning to an active employment use. The adopted Core Strategy sought to direct new residential development to what was, at the time of its preparation, redundant employment land. These employment sites are now being given a new lease of life. As such, the capacity for residential development on brownfield land is highly limited and these areas are self regenerating into active employment sites.

We should add that in our experience of working of the Black Country Local Authorities do need to understand the constraints to developing in the Black Country, particularly in respect of highways and urban design standards. Many of the existing allocations are difficult to develop and the Council will need to apply development management considerations flexibly in order to ensure the site can come forward. Many brownfield sites present physical and topographical challenges which can influence the formation of layout and design solutions. All of these are factors which should be taken into account when identifying sites for development and determining subsequent planning applications.