Object

Representation ID: 16445

Received: 11/10/2021

Respondent: Mrs & Mr Elaine & Bryan Bird

Number of people: 2

[Site Ref: WAH242]

To whom it may concern
I wish to object to the Black Country Development Plan 2039 for the following reasons:
I. Section 13 of the National Planning Policy Framework (NPPF) was specifically
created to protect the greenbelt.
a. Section 138 states that, "Green Belt serves five purposes: a) to check the
unrestricted sprawl of large built-up areas; b) to prevent neighbouring
towns merging into one another; c) to assist in safeguarding the
countryside from encroachment; d) to preserve the setting and special
character of historic towns; and e) to assist in urban regeneration, by
encouraging the recycling of derelict and other urban land."
b. Section 140 states that, "Once established, Green Belt boundaries should
only be altered where exceptional circumstances are fully evidenced and
justified..."
2. The need for building on the green belt is completely unjustified across the Black
Country. The Development Plan does not adequately explain why development
on this land is justified, especially considering the many brown field sites across
the region that are not only better suited to development, but should be fully
exhausted for new homes before building on our limited and precious green belt
is even considered. The underutilisation of premises by retail outlets in Walsall
town centre means there are numerous units that must be converted into
residential properties before development on green belt land is even considered.
It's needs to be realised that shopping attitudes and behaviours are changing and
becoming online dependant; the need for a high street with shops, banks, and
other facilities is decreasing, and this space must now be considered for
residential purposes. This will help to meet housing needs, whilst also preventing
the area from becoming derelict and unused.
3. The NPPF urges developers proposing to build on green belt sites to "set out ways
in which the impact of removing land from the green belt can be offset through
compensatory improvements to the environmental quality and accessibility of
remaining green belt land." There is no detail of how this be achieved in the
Development Plan.
4. The Development Plan states, "The proposed Neighbourhood Growth Areas are
located in highly sustainable locations and will provide 250 homes or more on the
edge of the urban area where there are existing pedestrian and public transport
routes and high levels of access to local services (such as schools or health
services). In some cases, new services may need to be provided as part of a new
development."
a. In relation to this, and specifically for the 442 new homes on the
Calderfields, Aldridge Road site, it is not explained anywhere in the
document how this site has been determined as having 'high levels of
access to local services (such as schools or health services)," or whether
new schools, health services and other services will need to be built in
addition to the 442 new homes being proposed.
5. The NPPF also states:
a. Proposals affecting the Green Belt
i. 147. Inappropriate development is, by definition, harmful to the Green Belt and should
not be approved except in very special circumstances.
I. There is nothing in the Development Plan that articulates
what these 'very special circumstances are,' and therefore the
proposal to build on green belt land is unjustified.
ii. 148. When considering any planning application, local planning authorities should
ensure that substantial weight is given to any harm to the Green
Belt. 'Very special circumstances' will not exist unless the
potential harm to the Green Belt by reason of
inappropriateness, and any other harm resulting from the
proposal, is clearly outweighed by other considerations.
I. What are these 'considerations?'
iii. 149. A local planning authority should regard the construction of new buildings as
inappropriate in the Green Belt. Exceptions to this are:
a) buildings for agriculture and forestry;
b) the provision of appropriate facilities (in connection
with the existing use of land or a change of use) for
outdoor sport, outdoor recreation, cemeteries and
burial grounds and allotments; as long as the facilities
preserve the openness of the Green Belt and do not
conflict with the purposes of including land within it;
c) the extension or alteration of a building provided that
it does not result in disproportionate additions over and
above the size of the original building;
d) the replacement of a building, provided the new
building is in the same use and not materially larger
than the one it replaces;
e) limited infilling in villages;
f) limited affordable housing for local community needs
under policies set out in the development plan
(including policies for rural exception sites); and 44
g) limited infilling or the partial or complete
redevelopment of previously developed land, whether
redundant or in continuing use (excluding temporary
buildings), which would: — not have a greater impact on
the openness of the Green Belt than the existing
development; or — not cause substantial harm to the
openness of the Green Belt, where the development
would re-use previously developed land and contribute
to meeting an identified affordable housing need within
the area of the local planning authority.
I. The development of 442 new homes on the Calderfields,
Aldridge Road site does not meet any of this criteria.
6. The environmental impact has not been considered, and the Calderfields,
Aldridge Road site is home to many different forms of wildlife, which will be killed,
or impacted by the proposed development.
7. The impact on the local road network has not been considered. There are an
average of 1.2 cars per house household in the UK, so the development of 442
new homes will mean an additional 530 cars on the road. What assessment has
been done to ensure the surrounding road network has the capacity to
accommodate all of these additional daily trips?