Comment

Representation ID: 17182

Received: 29/09/2021

Respondent: Walsall Arboretum User Group

Our objections are in two parts, firstly the need to protect the Green Belt per se, and secondly the
ability to mitigate biodiversity and habitat loss.

PART ONE General protection of the Green Belt
This long document lays some emphasis upon protecting the Green Belt, and upon exceptional
circumstances;
• Policy CSP 1 Development strategy
Para 2 e: Protecting the openness, integrity and function of the Black Country's designated and
retained Green Belt by resisting inappropriate development.
Para 3:13 and 3:16: The Black Country Authorities (The four local authorities of Dudley Council,
Sandwell Council, Walsall Council and City of Wolverhampton Council) attach great importance to
the ongoing protection of the Black Country Green Belt; however, the green belt boundary is drawn
tightly around the urban edges. In order to help meet objectively assessed needs for housing and
employment land development, exceptional circumstances to alter green belt boundaries need to be
demonstrated.

The Black Country Authorities have undertaken an extensive Green Belt and landscape sensitivity
assessment to identify land that, if developed, would cause the least harm to the purposes of the
Green Belt and to landscape character, is suitable and available for development and that could
create long-term and defensible Green Belt boundaries.
The Site Assessment Report sets out the
details, and the results of that assessment process.
We cannot find a definition or description of exceptional circumstances, and the document
references the "black country green belt study" to give results of the assessment.

Black Country Green Belt Study (2019), Landscape Sensitivity Council/ Borough Walsall
Metropolitan Borough

Area Bu31 defined as between high and moderate. High sensitivity means the landscape has strong
character and qualities with notable features which are highly sensitive to change as a result of
introducing built development. Moderate means the landscape has some distinctive characteristics
and valued qualities, with some sensitivity to change as a result of introducing built development.
Page 20)

This document further states: The larger areas of open land to the south east of Walsall are generally
considered to have moderate-high sensitivity. Despite their location within the urban conurbation,
these areas have some sense of rural character with a frequent occurrence of valued natural
habitats and significant recreational value. It must be reasonable to conclude that the area denoted
as Walsall BL31, is not included in the description of land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, Is suitable and available for
development.
Previous consultations on the Black Country Plan
(Page 13)
1.18 The consultation demonstrated that there was support for housing to be built in sustainable
locations and a desire to protect the environment of the Black Country.
1.19 A summary of the
issues and options responses and how they have been addressed in the Draft Plan are detailed
within this document, under the relevant policy themes.
These concerns have been noted before and indeed addressed in an entirely separate document.
Black Country Core Strategy Preferred Options (March 2008) Summary of Comments and How They
Have Been Addressed Core Spatial Policies CSP3 - CSP 5. The 'Brownfield First' sustainability principle
within the Core Strategy has a commitment to prioritising development on brownfield land over
greenfield land. Policy HOU1 states that 95% of all new housing developments will be on brownfield
land. Furthermore, previous consultation on the overall strategy showed broad support for this
approach. The release of green belt land to accommodate additional development in the Black
Country would be contrary to RSS policy and the overall strategy of achieving urban renaissance
via a sustainable settlement pattern.

In 2014 a planning application for 14 houses on this site was refused, the planning department
giving the following rationale:
"The development due to its location and layout would result in significant harm to the openness of
the Green Belt being visually prominent from the arboretum extension, a popular visitor attraction
in Walsall to which very special circumstances have not been justified to outweigh any harm to the
openness of the Green Belt"
The document quotes ten policies that would be contravened by this application; and that it would
contravene the black country core policy CSP2. The refusal did however mention that access to
building land might require reassessment in 2021.
It is a little astounding that 14 houses in 2014 was unconscionable, while 442 houses are currently
proposed.

We say that the concerns raised" result In significant harm to the openness of the Green Belt being
visually prominent from the arboretum extension, a popular visitor attraction in Walsall to which
very special circumstances have not been justified to outweigh any harm to the openness of the
Green Belt" remain completely valid, and ask for cogent reasons for any change.