Object

Representation ID: 21333

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

[unallocated site - Bromwich Lane]

The BCP also sets out that, in identifying suitable Green Belt sites, “land should therefore be fully assessed not just against its suitability for Green Belt status but also with regard to the sustainability of the development it might accommodate relative to various issues important to the BCP or the wider area” and that the BCAs will release land that “if developed, would cause the least harm to the purposes of Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries.” As such, the BCP states that the approach taken to allocating Green Belt land is the “rounding-off” of the built form.

Whilst WDH are of the view that this approach is justified and sensible in principle, it is demonstrated in response to Policy HOU1 that it has not been implemented consistently when assessing promoted sites, which has resulted in the BCP failing to allocate sites that could be developed with limited harm to the purposes of the Green Belt and landscape character subject to mitigation, and that would contribute to the creation of a “sustainable pattern of development” in accordance with NPPF paragraph 142. That is demonstrated in WDH’s response to Policy HOU1 in relation to WDH’s site at Bromwich Lane, Pedmore (SA Site Ref. SA-0016-DUD), and indeed it is critical that the BCP allocates such sites so as to ensure that it meets as much of its own housing needs as possible through substantial changes to the plan within the forthcoming Regulation 19 document.

Bromwich Lane
Bromwich Lane, Pedmore is one such example of an entirely suitable site in a sustainable location that the BCP has failed to allocate. The merits of that site, as well as WDH’s concerns with the application of the site assessment methodology when assessing the site, are outlined in further detail in WDH’s response to Policy HOU1.

That response highlights that, on the basis of the technical and environmental assessments of the site that have been carried out by WDH, there are no insurmountable development constraints that cannot be mitigated through the development of a sensitive scheme that includes suitable mitigation measures.

Those assessments find that the site is well-located at the edge of the Black Country conurbation and adjacent to the inherently sustainable settlement of Pedmore (as above), and that site access can be achieved in a manner that would achieve unrestricted two-way vehicular movements along Bromwich Lane. Relevant assessments have also found that the site is not subject to any nature conservation designations and that, whilst some protected species may be present, they can be accommodated through sensitive design to enhance the ecological value of the site, that the majority of trees will not be impacted by the proposals (save for the small scale removal required to accommodate access) and rather will be incorporated into generous landscape buffers that will be enhanced through new tree planting, and that the site is unlikely to have a detrimental impact upon surrounding heritage assets. The site is also not located within the floodplain, sustainable drainage can be accommodated within the development to provide surface water attenuation, and there is capacity within the existing foul sewerage network.

Given that Bromwich Lane, Pedmore is demonstrably an unconstrained and suitable development site yet has not been allocated by the BCAs, WDH’s response to Policy HOU1 highlights the inconsistencies in the site’s assessment within the BCP’s SA. In particular, that response demonstrates that the SA’s approach towards the site’s Green Belt and landscape considerations is unjustified, and that the development of the site would be entirely in accordance with the BCP’s approach to allocating Green Belt sites that round-off the built form, and can be developed with the least harm to the purposes of the Green Belt and landscape character.