Comment

Draft Black Country Plan

Representation ID: 21259

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Representation Summary:

Policy GB1 – The Black Country Green Belt
Alterations to the Green Belt require exceptional circumstances in accordance with National Planning Policy Framework (‘NPPF’) paragraph 140. Given the scale of housing need and an identified shortage of brownfield land to meet the need (Urban Capacity Report 2021), we agree with the Black County Authorities (‘BCA’) that there are exceptional circumstances to justify the release of Green Belt.

The policy states that compensatory improvements will be required to offset the impact of removing land from the Green Belt. The Viability and Deliverability Study (May 2021) has allowed for a compensatory contribution of £1,000 per dwelling. No details have been provided on the projects this contribution will fund nor whether improvements could be made on site or on other land within the same ownership/control in lieu of paying the contribution. We request further information and justification for this proposed contribution before commenting further.