Comment

Draft Black Country Plan

Representation ID: 16331

Received: 11/10/2021

Respondent: Frazer Powell

Representation Summary:

Please see below my comments on the Walsall MBC section of the above Plan.

In making my comments on the Plan, I have had regard to the following documents:

Black Country Plan: Draft Plan Consultation 16 August – 11 October 2021- Walsall Borough
Summary
Black Country Plan: Green Belt Assessment Summary
Black Country Landscape Sensitivity Assessment Final Report prepared by LUC -September
2019
Black Country Green Belt Study Stage 1 and 2 Report prepared by LUC – September 2019
Walsall Landscape Sensitivity Assessment (Copy attached)

I am particularly concerned regarding the green belt proposals in respect of Calderfields West, Land at Aldridge Road, Walsall and Land off Sutton Road/ Longwood Lane, Walsall. This would involve the development of 794 houses across the two sites if approved.

Before detailing my particular concerns regarding the above two sites, I think it relevant to comment about the consultation arrangements in general.
Walsall MBC has approximately 37% of its land classified as green belt. It is relevant and I would suggest legally crucial to the decision making of both the Planning Committee, Planning Inspector and the Secretary of State that it is explained clearly and transparently how it is decided which sites in Walsall could be removed from the green belt, ie setting out the “exceptional circumstances” test for the amendment of Green Belt boundaries. As I am sure you are aware, the five point criteria used to assess “Exceptional Circumstances is set out in the judgment of Jay J in Calverton Parish Council v Greater Nottingham Council and others (2015).

[Redacted-GDPR]
This e mail has taken me a deal of time and effort to prepare. However, I think it necessary and important that comments be submitted on the planning proposals.
The Councils Planning Committee and the Planning Inspector have a difficult and complex task before them in balancing the various competing interests in a manner which is both lawful and demonstrably fair.