Object

Representation ID: 21336

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY GB1 – THE BLACK COUNTRY GREEN BELT: OBJECT
WDH recognises Policy GB1’s intention for sites that are released from the Green Belt to define new boundaries in a “readily recognisable and permanent way”, and in that regard notes that the development of Bromwich Lane, Pedmore would achieve that in a manner that would ‘round-off’ the existing built form whilst having minimal impact on the purposes of the Green Belt and the surrounding landscape. That is discussed in further detail in response to Policy HOU1, which demonstrates that development in this location would integrate effectively with the existing settlement.

WDH note that Policy GB1 as currently drafted seeks to preserve the Black Country Green Belt from ‘inappropriate development’, reflecting the provisions of NPPF paragraphs 148 and 149. However, in reflecting the guidance of the NPPF in relation to Green Belt, it is important that Policy GB1 makes allowances for ‘inappropriate development’ where ‘very special circumstances’ exist by virtue of the potential harm to the Green Belt being outweighed by other considerations. That should be made clear through the inclusion of an additional ‘clause’ to Policy GB1.

In addition to that, WDH note that, for sites that are removed from the Green Belt for development, “compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from green belt.”

Whilst WDH recognise the intention of that policy requirement, the BCP must clearly set out the amount, type and scale of compensation that is required to sufficiently offset the impact of the removal of such sites, which should be justified based on proportionate evidence. Until that information is provided, the policy is not “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals” in accordance with NPPF paragraph 16d. The relationship that those requirements would have on sites that also would be required to meet open space standards should also be considered by the BCAs, given the inevitable impact on development capacity.

Moreover, further information is required to set out how that compensation would be secured. Should that be through the mechanism of Section 106 contributions, the requirement must be evidence-based, justified, and directly applicable to the proposed development to ensure that it is CIL Regulation 122 compliant.