Object

Draft Black Country Plan

Representation ID: 15789

Received: 11/10/2021

Respondent: Mr David Benton

Representation Summary:

Thank you for the opportunity afforded to me, to be able to comment on the Black Country
Draft Plan Regulation 18 Consultation (August 2021)

My comments are specifically addressed to the proposal to build 363 houses, on Green Belt farmland, to the rear of my property, defined in the Plan, as Site ref WAH 237.

Background History

You will appreciate that this site has history, clearly documented, as far back as 1981

"Wood A. A. (1981) Aldridge/Brownhills District Plan. Draft Written Statement (West Midlands County
Council).

Wood A. A. (1983) Aldridge/Brownhills Local Plan. Revised Policies and Proposals (West Midlands
County Council).
Wood A. A. (1984) Aldridge/Brownhills Local Plan (West Midlands County Council), Written
Statement."

I contend that the criterion for rejecting proposals to build houses on this Site at that time,
and within other subsequent revised plans, one assumes, were based upon good and sound planning considerations, and the grounds for rejecting development at the Site previously therefore still apply.

Whilst I appreciate that there is tremendous pressure from central government for local authorities to increase the available number of houses within their conurbation, it should not, in my opinion, be at the cost of ignoring previous sound strategic planning decisions to reject development at this Site, and therefore to follow the easy option of building on further Green Belt.

Having had substantial interaction with major house builders within my past career, it is fact that house builders, in general, are sitting upon large parcels of land for which they have existing permissions to develop and are not doing so, because it is in their financial interest to release them slowly, thus maintaining the "market price" for the units that they build (the scarcity principle applies)

Planning Governance and Sustainability criteria

My understanding of good planning governance is to assess that there is adequate infrastructure in place to support a development of this magnitude.

It is not unreasonable to assume that 363 houses, (which seems a very precise number) with an average of 4 persons per dwelling, would attract an additional 1400 inhabitants into the area and it may be more.

Currently there are three schools within walking distance of the proposed site and my understanding is that all are oversubscribed, and I am aware that people with young families, have moved from other areas, into Aldridge, to be within the catchment area of those
schools because they are highly rated by Ofsted.

Additionally, the medical facilities and GP Services etc. in the immediate vicinity of the proposed site, are all currently under pressure from the existing residents of the area, as Aldridge has an aging demographic and this is well documented, as being the case and has probably been exacerbated by previous planning decisions to allow multiple care home facilities and the attraction of retirement living into the area.

Having read officers recommendations pertinent, to development at this Site, and noting that, funding for new road infrastructure, schools, medical and GP services, which have been identified by officers , as being required, to support such a development of this
magnitude, how is it envisaged that funding for adequate new school(s) and medical and GP Services, will be funded from revenue generated, from the development of the Site and moreover has the land for those school(s) and medical and GP Services been identified, given the scarcity of land that officers have identified and my understanding that primary
level pupils have to be schooled within walking distance of the proposed Site?

Past performance of developers in my experience, has shown that it may well be in their interest to fund the road infrastructure, but not all the other infrastructure that has been identified by officers, pertinent to this site, as being required.
Therefore, is there the likelihood that those other infrastructure requirements, will not be
provided by the developer(s) of this proposed site and will consequently add additional pressure, to the over stretched resources which are currently provided to residents of the area?

Section 92 of the Town and Country Planning Act 1990 ( as amended), gives little power to local authorities to place obligations ,or conditions, pre development, upon the developers of sites and therefore in my opinion, it is very unlikely that Walsall Metropolitan Borough
Council will be able to enforce conditions upon a developer or developers of the proposed
Site to fund the adequate infrastructure such as ,new school(s) ,medical and GP services and given this observation, the proposal to include the proposed Site in the Black Country Plan should be discounted, as it lacks credibility.

Previous Strategic Plans

Consideration of the inclusion of this Site in previous strategic plans were deemed not suitable for housing development given a variety of grounds: •
• lack of adequate infrastructure being in place to support such a development
• it's encroachment into Green Belt, which would provide precedent for other Green
Belt development to go ahead, in the vicinity of the proposed Site
• sterilisation of strategic mineral reserves and which were of economic importance to the wider development of the West Midlands conurbation
• its proximity to an already permitted waste processing site for Green Waste
• its impact on the uninterrupted view from Lichfield along the Vale of Lichfield, as the
proposed Site, given its topography, sits on a high point of a ridge, which is the
highest point in the surrounding area and currently affords spectacular uninterrupted views, both down the Vale of Lichfield towards Lichfield Cathedral and beyond, and across to Little Aston Park/Four Oaks and beyond
• sterilisation of productive arable farmland

Feed Back

Following my discussion with officers at the open consultation session at the Aldridge Compass Suites on Friday the 1October 2021 ,where I raised many of the points, which I have detailed, I understand that to mitigate the Site from being obtrusive, in respect of damage to the views along the Vale of Lichfield, it would be proposed to set the development back from the ridge and the Proposed Site's topography, flowing downward from the ridge would afford screening along the sight line.

However, having reviewed this point, following a walkover of the Proposed Site, this (the officers) hypothesis is flawed, unless the Northerly end of the Proposed Site (approximately 30%) was designated as low rise, one storey development, like that condition, imposed upon
KR Hardy Estates, when they developed land off Greenwood Road.
Given the need for generation of maximum revenues from the development of the Proposed Site, to fund the necessary infrastructure, to support its development, I contend would cast doubt on the viability of the Proposed Site upon economic cost grounds, if such low-rise restrictions were placed upon its development. However, I do accept that my point could be ignored, and two-story development allowed across the whole Proposed Site and to deal
with the consequences of such actions, after the houses were built and the subsequent effect upon the sight line.
In support of the point concerning the erosion of the view, the Proposed Development would
cause, to the view down the Vale of Lichfield, I refer to a letter on House of Commons headed paper, dated in July 2005 written by Richard Sheppard, the member of parliament for Aldridge -Brownhills that "looking from Aldridge across open country towards Lichfield. On a clear day the cathedral spire can be seen. The land forms a ridge at this point before falling away to Stonnall and the Vale of Lichfield and it is not presently cultivated with few trees.
I would suggest that this site is of great scenic importance in that it commands a strategic view from the ridge across Staffordshire. Other than Barr Beacon I do not think there is such a view which links the community to its wider context, I personally think it is the finest uncontaminated elevated long view of Lichfield and the Staffordshire plain.
I therefore believe that development contravenes PPG2 and Policies ENV2 and 3 of
Walsall's Unitary Development Plan"
Whilst Richard Sheppard's reference to Walsall's Unitary Development Plan may have been superseded, his fundamental sentiments, expressed in the letter remain.

Reference to a specific number of houses (363) assumes that a detailed plan and feasibility study for the Proposed Site was made, at the stage when there was a call for sites.
For the consultation process to be open and transparent, may I suggest that the plan
submitted at the stage were there was a call for sites, be made available to the residents, in the vicinity of the proposed Site, for them to see what is proposed, and how the initial layout for the Proposed Site, relates to the existing properties around the curtilage of the Site, and
in relation to their property. This, I believe would assist in making an informed decision about the proposal

No information has been provided concerning where any new school(s), or medical and GP Services are to be located, to support the Proposed Development, therefore, is it envisaged that further Green Belt land will be required and if that is the case, has that parcel, or parcels of land required to support the Proposed Development been identified?
If, as part of the Council's feasibility study, the land has been identified, can its location be provided to residents, again to make an informed decision concerning the Proposed Development

Thank you for the opportunity to comment and copies of my representations concerning the
Proposed Site have been circulated to:•

Wendy Morton
Member of Parliament for Aldridge Brownhills
Councillor Keith Sears
Aldridge North & Walsall Wood