Support

Representation ID: 1787

Received: 08/09/2017

Respondent: Jay Farm Homes Limited and Lawnswood Homes Limited

Agent: SLR Consulting

Answer: Yes

Detail: It is identified within paragraph 3.41 that there has not been a Strategic Green Belt Review in the BlackCountry since the designation of the existing green belt in 1970. Furthermore, given that not all of the housing needs identified can be accommodated within the Black Country area, there is a need to accommodate a proportion of the Black Country housing needs within the wider HMA. As such, SLR welcomes the approach to reviewing the Green Belt along the urban fringe within South Staffordshire as there are likely to be a number of sites along this authoritative boundary which could be more suitable, available and deliverable than sites located within the Black Country itself.


As highlighted in the Issues and Options document, the NPPF identifies that Green Belt boundaries should only be reviewed whilst conducting a Local Plan review and in exceptional circumstances. It is considered that the need 'to accommodate unmet housing needs', especially given the backlog experienced between 2011-2014 and the likely findings of the Greater Birmingham and Black Country HMA Strategic Growth Study, such a Green
Belt Review is now entirely appropriate within both the Black Country and the wider HMA.
As outlined above, SLR duly requests that the Black Country Core Strategy Review consider our Client's site for suitability for release from the Green Belt and either allocation in the short term or a longer term safeguarding.
Given that the site can either be brought forward as a smaller independent site or, if the adjoining County Council land is released, as a strategic allocation which could go toward meeting the housing need for the HMA, this location affords flexibility in the scale of release.
With regard to any Green Belt Review, this should be comprehensive in its remit, covering both the Black Country area and Green Belt areas immediately adjoining the settlement boundaries. On this point, it should be noted that the NPPF states that when local authorities are reviewing established Green Belt boundaries they should take account of the need to promote sustainable patterns of development, channelling development towards urban areas inside the Green Belt boundary (NPPF paragraph 84). Indeed, paragraph 85 of the NPPF identifies that when defining boundaries, local planning authorities should:
ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
not include land which it is unnecessary to keep permanently open;
where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the
Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;
make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a
Local Plan review which proposes the development;
satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and
define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We would encourage any comprehensive Green Belt Review to accord with the thrust of these criteria defined within paragraph 85 of the NPPF.
South Staffordshire District Council have, to date, excluded urban/conurbation edge sites from consideration for release through their Partial Green Belt Review. We consider that the Black Country area should be encouraging/requiring the need for these sites to be included for consideration within a more comprehensive
Green Belt Review as they could be more located in closer proximity to infrastructure and more sustainable than other sites further afield.

4.5 Key Issue 9- Working Effectively with Neighbours
SLR supports the use of collaborative working with adjoining local authorities, especially in meeting the housing needs of the wider HMA and the completion of a suitable and comprehensive Green Belt Review. The strategic priorities must be dealt with across local authority boundaries given the constrained nature of the Black
Country and the significant levels of potentially suitable, available and deliverable Green Belt sites that could be released along the settlement edge of Wolverhampton.