Object

Representation ID: 21345

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY HOU1 – DELIVERING SUSTAINABLE HOUSING GROWTH: OBJECT
Policy HOU1 sets out that “sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020-2039.” WDH’s response to Policy CSP1 above sets out their objection to this scale of growth as follows:
• Housing Needs: Whilst WDH recognises that the BCAs’ housing need over the plan period is 76,076 dwellings when calculated in accordance with the Government’s Standard Method, a further uplift should be incorporated to reflect the anticipated economic activity relating to the arrival of HS2 in the wider area.
• Scale of Growth / Housing Requirement: The BCAs should seek to maximise the delivery of housing within their jurisdiction before exporting any unmet need, given the BCAs’ own substantial housing needs and the context in the wider HMA of a significant housing need. Given that there are a number of suitable and available development sites that have not been included as proposed allocations (see below), the BCAs have failed to provide sufficient justification for their proposed approach of limiting growth to 47,837 dwellings. The BCAs should therefore revisit their audit of promoted sites to ensure that their purported housing capacity is accurate and maximises the potential of sites in the area. Alongside that, the plan’s SA should be revisited to fully consider the maximum level of housing that could be accommodated before additional significant adverse impacts arise.
• Housing Supply: In addition to the concerns in relation to providing a level of housing supply that is well below the overall housing needs of the BCAs, WDH also has concerns as to whether the BCP would deliver the quantum of housing that the BCAs are expecting.
WDH’s response to Policy CSP1 highlights the particular dependence on a number of brownfield sites that can often be constrained, resulting in sites being delayed or failing to deliver. That matter, when combined with the BCAs’ unreasonable approach to the windfall allowance, is likely to result in a scenario where actual delivery in the plan period does not reach 47,837 dwellings, which itself falls a long way short of the BCAs’ housing needs. WDH’s response therefore outlines the importance of allocating small-medium sized greenfield sites (including Green Belt sites) both to increase the proportion of the BCAs’ housing needs that are met, and to provide further delivery early in the plan period.
• Spatial Strategy: The lack of a spatial strategy that is informed by an audit of settlements is concerning, and raises queries in relation to the justification for the BCP’s focussing of growth to particular settlements. Notwithstanding that, however, a spatial strategy should be prepared based on an audit of the housing needs of settlements and their suitability to accommodate growth. That spatial strategy should direct additional growth to sustainable settlements so as to meet a higher proportion of the BCAs’ housing needs. The suitability of Pedmore should be reflected in that, given its location adjacent to the Black Country conurbation, the presence of numerous services and facilities within the settlement, and its excellent connectivity to nearby settlements and the services and facilities therein.
• Green Belt release: In principle, the BCAs’ justification of Green Belt release is sound and justified in accordance with the NPPF. That said, given that the BCAs should seek to meet more of their own housing needs for the reasons set out above, the BCP should maximise delivery from Green Belt sites where there are suitable sites in sustainable locations that have not yet been allocated for development. The suitability of WDH’s site at Bromwich Lane, Pedmore is set out below in that regard.


Bromwich Lane, Pedmore
As set out above and in detail in response to Policy CSP1, Pedmore is an inherently sustainable location for growth. In that context, Bromwich Lane, Pedmore (SA Site Assessment Ref. SA-0016-DUD, the location of which is shown in the Vision Document that has been submitted alongside these representations) is a suitable development site that accords with the BCPs’ approach to releasing Green Belt sites that would ‘round-off’ the existing built form (see BCP paragraph 3.17) in a manner that would result in “the least harm to the purposes of Green Belt and to landscape character” (see BCP paragraph 3.16).

As such, the site’s development would accord entirely with the BCP’s proposed approach. The failure of the BCAs to allocate the site, therefore, reflects WDH’s concerns regarding the assessment of sites and application of the assessment methodology, as set out below.
A series of technical and environmental assessments have been undertaken in relation to Bromwich Lane, Pedmore that have highlighted that the site has no insurmountable development constraints that cannot be mitigated. Those site assessments are summarised in the Vision Document that has been submitted alongside these representations.

Principally, an appropriate vehicular access with achievable visibility splays can be provided via a new junction with Bromwich Lane, with a new footpath along the southern edge to be provided within the site as well as a small section to the north of Bromwich Lane to connect with the existing footpath on the southern side. The opportunity to widen Bromwich Lane along the site frontage would be taken where feasible to accommodate the additional traffic generated by the proposed development, which would include removing the west priority-controlled section of road to achieve unrestricted two-way vehicular movements along Bromwich Lane.

An ecological assessment of the site has confirmed that the site is not subject to any nature conservation designations, that the majority of the site is of low ecological value, and that, whilst some protected species are likely to be present in the area, they can be accommodated and the ecological value of the site as a whole can be enhanced through the proposed development. Indeed, whilst the hedgerows and areas of scrub along the boundaries provide suitable habitat for foraging and commuting bats and black poplar with moderate potential to support roosting bats is present in the site’s south-west, those areas will be retained as open space with an appropriate development offset and enhanced through planting, landscaping and the creation of an attenuation pond. Similarly, the site’s hedgerows that are of ecological value at a local level will be retained and enhanced where possible in accordance with the recommendations of the ecological assessment. , the site has been found to offer limited foraging habitat. As such, there are no ecological constraints to the site’s development, and indeed the development scheme can realise ecological enhancements through its sensitive landscape scheme.

Given their location, the majority of the trees at the site’s boundary will not be impacted by proposals and instead will be retained and incorporated into areas of public open space that will reinforce the site’s green infrastructure connections. An arboricultural assessment has considered the unavoidable removal of trees from a tree group of moderate arboricultural and landscape value at the site’s access, and has confirmed that the loss of this small section of the tree group would not diminish the group’s overall amenity value and that appropriate mitigation for the loss can be provided.

An archaeological desk-based assessment and a consideration of the site’s heritage impact has established that there are no designated or recorded heritage assets within the site or listed buildings within its vicinity, and that the site is not visible from the Hagley Conservation Area and thus that the site will not impact on its setting and character. Whilst Wychbury Ring is located c. 1km from the site, it is shrouded by woodland and separated from the site by the busy Hagley Road and the residential development alongside it. That is also the case for Hagley Hall Park and Garden and its listed buildings and structures that are located to the south and south-east of the site. As such, the proposed development is unlikely to have a detrimental impact upon the site’s surrounding heritage assets.

In relation to drainage, the site is located in flood zone 1 and is therefore at low risk of flooding. In addition, whilst there are small areas of the site that are at low and medium risk of surface water flooding, they are contained to the site’s western boundaries and therefore can be accommodated within the proposed open space corridor in that location. It is intended that surface water is attenuated within the site within the proposed attenuation basins at the site’s south-west corner before being discharged via an existing surface water sewer at Redlake Drive. There is also capacity within the existing foul sewerage network to accommodate the proposed development.

A landscape and visual assessment of the site has also been carried out. That assessment outlines that the site is designated by Dudley MBC’s Urban Historic Landscape Characterisation Study as falling within an ‘Area of High Historic Landscape Value’ that largely relates to the landscape relating to Wychbury Hill and Hillfort, and Hagley Park and Garden. The assessment of the site finds that there is a clear physical and visual break between the more valued landscape to the east and south-east of Hagley Road by virtue of the presence of the busy Hagley Road and the development along it, and that the site shares limited visual interconnectivity with those landscape / heritage features as a result. Rather, the landscape character of the site itself is undoubtedly affected by its relationship with the adjacent built form that encloses the site on two sides and gives significant visual containment.

The assessment therefore finds that the site’s development would have only minimal impact on landscape character, and would not at all appear incongruous given that it would be contained on 2 of its 3 sides by existing residential development. Moreover, it found that the key landscape features defining the site can be retained, enhanced, and supplemented to provide a softer transition to the countryside to the south and the area of higher value landscape. A visual appraisal has also highlighted that distant views of the site are limited by the visual containment that the site benefits from by virtue of the surrounding topography and the existing built form, and that any views of the site are seen in the context of the existing built form, which is often more prominent than the development would be (by virtue of its robust landscape framework and proposed boundary planting). Thus, any residential development would be integrated in its context, and the impact on visual amenity would be minimal.

A Green Belt appraisal has also been undertaken to ascertain the harm associated with the release of the site. That appraisal highlights that the site’s location and aspect mean that it does not form a particularly sensitive part of the Green Belt. Indeed, the site is already bordered to the west, north and east by well-established development, and the proposed development would not encroach south as far as the existing built form that borders it to the east and west. As such, the site’s development would consolidate the existing built form (rather than resulting in urban sprawl), would have minimal impact in terms of the coalescence of settlements given that the development would sit in front of and below the existing settlement and therefore would not impact on the perception of the separate identity of Pedmore and Hagley, and would result in limited countryside encroachment (further negated by the site’s strong landscape structure). The appraisal therefore outlines that the location of the site and its strong landscape structure mean that the degree of harm resulting from its release would be limited and that, rather, the site’s development offers an opportunity to round-off the built form and create a clear, robust and defensible boundary.

As such, it is clear from the assessments of the site that it is an inherently suitable development site that is not subject to any insurmountable constraints.

The BCP’s assessment of Bromwich Lane, Pedmore
The site’s inherent suitability for development as demonstrated through that suite of technical and environmental assessments has not, however, been reflected in the BCP’s evidence base and its approach to the site’s assessment, thus raising serious concerns in relation to the suitability and consistent application of the BCAs’ site assessment methodology. Indeed, WDH have previously written to the BCAs to express those concerns, and that letter has been submitted alongside these representations (Ref. 332 MR 160620 DMBC).
The unsuitability of the site assessment methodology and its inconsistent application is reflected both within the assessment of the site within the BCP’s Sustainability Appraisal (SA) and the Site Assessment Report (SAR), both of which assess the site under Site Reference SA-0016-DUD. When interrogating the justification for the site’s performance against the criteria of those assessments, it is clear that the assessment of the site has failed to consider the site’s true context, the ability for site’s development to readily and easily incorporate suitable mitigation to reduce any impacts, and the potential benefits that the site’s development could bring.

However, the BCAs’ assessments of other promoted sites did take into account those matters, for example in the assessment of the site(s) between the railway line and Worcester Lane that are proposed to be allocated in the BCP, which themselves are assessed under Site Refs. SA-0010-DUD-A, SA-0010-DUD-B, and SA-0018-DUD-C. The unsuitability and inconsistencies in the BCAs’ assessment of each site is set out below with reference to the SAR, highlighting that the site assessment would have identified Bromwich Lane, Pedmore as a suitable allocation site had the methodology been justified and applied consistently.

WDH’s principal objection to the site assessment methodology relates to the approach taken when assessing Green Belt harm and landscape impact, with the SAR registering a Green Belt harm rating of ‘Very high’ and a landscape sensitivity rating of ‘moderate to high’ for the site. Those conclusions are informed directly by the Black Country Green Belt Study (BCGBS) and Black Country Landscape Sensitivity Assessment (BCLSA), and indeed the letter submitted to the BCAs by WDH (as above) set out concerns in relation to the methodologies of both of those assessments; highlighting the manner in which an unsuitable methodology can result in inaccurate conclusions being attributed to a promoted site, which has clearly now directly resulted in the failure of the BCPs to allocate the site.

In relation to the BCGBS, WDH notes that the site is assessed as part of the broader Green Belt parcel of B60, which is a parcel of 181.3 hectares (of which the site is 4.2ha) that covers an area with significant variations both in terms of its character and contribution to the purposes of the Green Belt. That parcel varies from areas in urban fringe locations that are influenced largely by the adjacent urban environment (such as the site) to overwhelmingly open, vast and rural elements of the countryside (such as the land at the parcel’s west), and as such is clearly an incorrect scale upon which to assess the site and its Green Belt contribution. That resulted in a Stage 1 assessment that found strong contribution towards purposes 1, 2, 3 and 5. That clearly, as set out above, does not reflect the reality of the site itself and its contribution towards Green Belt purposes. Rather WDH’s previous comments highlighted that a contribution at the lower end of moderate would be more appropriate for purposes 1, 2 and 3 given the site’s context as set out in the above analysis.

As such it is clear that the Stage 1 assessment of Parcel B60, which was then attributed to the site and informed the assessment of the harm attributed to the release of any land within the parcel, was directly informed by an unsuitable methodology that sought to assess a very large and varied Green Belt parcel, rather than breaking the parcel down into smaller parcels that more accurately reflect the clear variations in character and Green Belt contribution. That Stage 1 assessment then fed into the Stage 2 assessment of the release of ‘any uncontained land’ within Parcel B60 (under Scenario B60s1). Notwithstanding that the site cannot be considered ‘uncontained’ given that it is clearly contained by the built form, that approach was itself inconsistent in comparison to the assessment of other promoted sites, some of which were assessed as part of their own ‘scenarios’ whilst others were included in broader release scenarios such as that seen in scenario B60s1. As a result of that flawed methodology, the release of B60As1 was attributed ‘very high’ harm. An accurate assessment that took into account the site’s context and characteristics would have found low-moderate harm associated with the release of the site from the Green Belt.

The manner in which the inconsistent application of the BCGBS’ methodology has directly influenced its findings and, ultimately, the fortunes of promoted sites when the BCAs came to identify allocation sites is highlighted further when that methodology is compared to the Worcester Lane site(s), where more suitable assessment parcels resulted in a more favourable conclusion. For example, the northernmost parcel (SA-0010-DUD-A) was assessed as its own assessment parcel (B63) of just 1.1ha (compared to the 181.3ha parcel that Bromwich Lane was included in) for all stages, which lead to favourable outcomes early on that then, in turn, fed into the conclusion that there would only be low to moderate harm. That is despite that element of the site having similar characteristics to WDH’s site at Bromwich Lane (albeit on a slightly smaller scale) in that it is surrounded on its east and west sides by existing development that protrudes further into the open countryside than the site itself, with an open southern boundary. The approach of including Bromwich Lane as its own Green Belt parcel would have been more suitable, therefore. Had that not been the case, Bromwich Lane should at the very least have been afforded its own ‘release scenario’ at Stage 3, which was the approach taken to the central parcel at Worcester Lane (SA-0010-DUD-B) despite the fact that that parcel was less contained than the Bromwich Lane site (with built development covering only half of its western boundary and the proposed allocation building further south than its adjacent urban form to the west).

The matter of Green Belt appraisal methodology was recently considered in an appeal in St Albans District (Appeal Ref. 3265926), whereby the Inspector found that, as a result of the inclusion of a more discrete Green Belt site within a much larger Green Belt assessment parcel that included more significant Green Belt parcels, that the characteristics of the wider assessment parcels “bear little or no relationship to the appeal site.” The Inspector therefore concluded that there was “only very limited correlation between the conclusions drawn here in relation to the function of the land or assessment of its function relative to the purposes of the Green belt when compared to the appeal site” in allowing the release of that Green Belt site.

WDH also has similar concerns to the methodology and findings of the BCLSA, which acts as ‘Stage 3’ of the BCGBS. Again, the site is attributed to Parcel BL15 that is a 223.8ha parcel which again includes more urbanised land such as the site, as well as open, clearly more sensitive landscape to the west. Even when considered at the smaller scale of BL15s2, the site is assessed alongside land that would clearly represent a considerable visual extension into the countryside beyond the well-contained site and into the landscape that separates Pedmore and Hagley, and is therefore inherently more sensitive in landscape terms. The result of the assessment was therefore naturally weighted in light of this.

Indeed, and as set out in the attached letter to the BCAs, the conclusions found were often not relevant to the site; given its context as the least sensitive location within both Parcels BL15 and BL15s2. Principally, the assessment of those parcels found their ‘moderate to high’ sensitivity arose as a result to its “additional role in providing a perceived gap” between Pedmore and Hagley. Clearly, that is not the case for a development site that would not extend development any further south beyond the already established built form. As set out in the letter to the BCAs, a more accurate judgement of the site would be that is has low-moderate sensitivity to built development.
Given that, as set out above, there are no technical or environmental constraints relating to the site, it can only be seen that the unevidenced and inaccurate assessment of the impact of the site’s development on the Green Belt and landscape has significantly weighted the BCAs decision not to allocate the site. Had the site been assessed correctly therefore, by considering the opportunity for the site’s development to actually bring a benefit to the integrity of the retained Green Belt through the provision of development that rounds off the built form and delivers a clear and robust new Green Belt boundary, the site would have been identified for its clear suitability and would have been allocated.

Notwithstanding that, it is also noted that other elements of the site’s assessment are inaccurate, and do not reflect the site’s credentials. The ‘red’ rating in relation to heritage assets suggests that the site’s capacity is “significantly limited unless harm is caused to asset(s) which cannot be wholly mitigated.” As set out above, the site’s development is unlikely to have any detrimental impact upon designated assets, and moreover the provision of an enhanced southern boundary would create a clearer transition between the redefined built form and the surrounding historic landscape. It would be more accurate for the site to be attributed a green rating, given that there are no assets on the site and that assets in its surrounds would have a “negligible impact on site capacity.”

Similarly, the site is incorrectly attributed a ‘red’ rating in relation to ‘visual amenity and character of the area’, which is applied to sites where the capacity would be “significantly limited unless harm is caused to visual amenity / local character which cannot be wholly mitigated.” As set out above, the site should have been assessed to have only low-moderate landscape sensitivity, and therefore development could be accommodated within the site without reducing the site’s capacity. Rather, a green result should have been attributed.

The amber rating in relation to Tree Preservation Orders (TPOs) also suggests that the presence of TPO trees on the site would limit development capacity. Again, the Vision Document submitted alongside this document demonstrates that this is not the case. Indeed, previous arboricultural assessments of the site have highlighted that the loss of only a small section of the protected tree group would not diminish the group’s overall amenity value and that appropriate mitigation for the loss can be provided within the development. Therefore, the site can be delivered at full capacity without impacting upon TPO trees, and as such the site should have been attributed a green result for this criteria.

That is similarly the case in relation to the amber rating given to ‘Flood risk, drainage and ground water’ which would suggest that the site’s capacity would be ‘significantly’ reduced to allow for mitigation relating to drainage and flood risk issues. Again, that is not reflective of the nature of the site, which has a very limited area of low-moderate surface water flood risk at the site’s western boundary which could be incorporated within an open space corridor with no impact on the site’s capacity. Therefore, the site should also have been attributed a green result for this criteria. It is noted that the splitting of the allocated site(s) between the railway line and Worcester Lane, despite the fact that they will likely be developed comprehensively, has resulted in the surface water flooding issues relating to an area of high surface water flood risk at the site’s north being attributed only to one parcel, despite being a (more significant) constraint to the sites as a whole.

The SAR also attributes a red rating to the site in relation to ‘Highway Access and Transportation’ that suggests that the development has access constraints that cannot be viably overcome. As set out above, that is clearly inaccurate. Rather, access to the site is achievable and viably deliverable, and would also bring about limited improvements to the functionality of Bromwich Road by introducing unrestricted two-way travel. A green, or at least amber, rating should have been attributed for this criteria.

The approach taken in the SAR towards ‘opportunities’ also fails to take into account the benefits that the site’s development would deliver. Indeed, whilst the assessment of the proposed allocation sites (Site Refs. SA-0010-DUD-A, SA-0010-DUD-B, and SA-0018-DUD-C) gives a green rating by virtue of the perceived opportunity to deliver a defensible green belt boundary, that approach is not taken at SA-0016-DUD (Bromwich Lane) despite the clear benefits that the development would bring in that regard, as set out above. The opportunity to round off the built form and improve the functionality of Bromwich Lane through the delivery of unrestricted two-way travel is also overlooked. A green rating should have been attributed for this criteria therefore.

In contrast to the unjustifiably negative approach to Bromwich Lane, the BCAs appear to have come to more favourable conclusions for the proposed allocation site between Worcester Lane and the railway line (SA-0010-DUD-A, 0010-DUD-B, and 0018-DUD-C). Indeed, despite the presence of a number of Sites of Local Importance for Nature Conservation (SLINCs) at the site’s north, south and western boundaries, the sites are afforded an amber rating in relation to ‘biodiversity and geodiversity.’ However, it would be reasonable to expect a significant development offset from those boundaries to sensitively accommodate those designations, and as such that should arguably be ‘red.’

In addition, the sites are given only an ‘amber’ rating in relation to noise impact, despite the location of the railway line that runs adjacent to the western boundary of all parcels. To accommodate that and achieve required acoustic levels, it is reasonable to expect that a significant offset from the western boundary would be required. Given that the narrow nature of the site, it is reasonable to suggest that the requirement for an offset would “significantly limit” the development’s capacity; and that a ‘red’ rating should be attributed to all parcels.

Therefore, when making appropriate adjustments to reflect the true potential of the site, it would have performed more favourable than the sites between the railway line and Worcester Lane that are proposed to be allocated. The adjusted results for those sites in light of the above analysis are highlighted in bold, underlined and italicised below.

Implications
As such, it is clear that, had the SAR fully taken into account the site’s context and the merits of the proposed development, WDH’s site at Bromwich Lane, Pedmore (Site Ref. SA-0016-DUD) would have performed more favourably than the proposed allocation sites at Worcester Lane (SA-0010-DUD-A, SA-0010-DUD-B, and SA-0018-DUD-C), reflecting that the former is an inherently suitable development site with no insurmountable constraints.

That is not to say that the site at Worcester Lane should be removed in favour of WDH’s site at Bromwich Lane, but that Bromwich Lane should be allocated in addition to the proposed allocations to date given its inherent suitability and its more sustainable location near to Hagley Road (as correctly reflected in the SAR’s assessment of the site). Critically, the allocation of suitable sites such as Bromwich Lane, Pedmore would result in the BCAs meeting more of their housing needs within their own jurisdiction, thus reducing the amount of that need that must be exported and thus potentially may not be met.

Furthermore, the allocation of Bromwich Lane, Pedmore would be entirely in-keeping with the approach set out within the BCP of allocating those sites that would have the least impact in Green Belt and landscape terms and pursuing development opportunities that would round off the existing urban form. It would also reflect the sustainability of the settlement as a whole and as such the release of a Green Belt site in this area would be justified and appropriate, and would promote sustainable patterns of development in accordance with NPPF paragraph 142.

Thus, the allocation of Bromwich Lane would be an entirely justified and appropriate approach that should be incorporated alongside the wider significant modifications that are required to the future Regulation 19 publication (as set out in WDH’s comments to other policies).

The Proposed Scheme for Bromwich Lane, Pedmore (SA Site Assessment Reference SA-0016-DUD)
In that context, the emerging Masterplan for the site (as set out in the submitted Vision Document) provides for the delivery of c. 85 – 100 dwellings, and in doing so demonstrates how a well-designed scheme that integrates entirely with the existing built form will be delivered to provide much-needed housing in a sustainable location, with residents having direct access to, and providing support for, the range of local facilities within the settlement.

As set out above, access to the site will be provided via a new junction off Bromwich Lane, with a new footpath provided within the site along the southern edge of Bromwich Lane and a small section to the north of Bromwich Lane to connect to the existing footpath on the northern side. The opportunity to introduce unrestricted two-way movements along Bromwich Lane will also be considered by removing the west priority-controlled section of the road along Bromwich Lane.

The residential aspect of the scheme responds sensitively to surrounding uses, integrating well with the existing built form. In responding to the existing pattern of development to the west of Bromwich Lane, the existing western hedgerow and tree corridor adjacent to the site’s access will be retained and enhanced to reinforce the ‘leafy’ settlement character and filter views of the housing. Meanwhile, to respond positively to the dwellings along Hagley Road, dwellings that back onto the site’s eastern boundary incorporate generous rear gardens with enhanced buffer planting to prevent overlooking into the existing properties.

The site’s residential aspect will be designed in a perimeter block layout in order to promote activity and provide natural surveillance over streets and public spaces whilst also securing private boundaries (including the current existing exposed boundaries to the east). That built form will be served by a clear hierarchy of streets that establishes good legibility and also incorporates informal open spaces. That layout also includes a small residential square at the centre of the site, creating a focal / meeting space within the development.

To ensure that the site is well integrated into the wider landscape and reflect the leafy nature of surrounding residential areas, the residential aspect of the site will incorporate street trees and significant planting within gardens and open spaces to provide a green canopy effect to the development, within which residential properties will nestle. That planting will particularly increase at the site’s higher slopes (such as the eastern boundary) to limit any views of the development and soften the appearance of the settlement edge as it is viewed from the wider landscape.

The treatment of the site’s southern boundary also contributes to the development’s sensitive approach to landscape character. The site’s southern boundary will be reinforced through significant native tree and hedgerow planting that will offer further screening of the site from the surrounding landscape and create a clear and robust Green Belt boundary whilst rounding-off the built form. Beyond that southern boundary, the site’s south-western corner will be free of residential development to allow for the provision of attenuation features, whilst the built aspect along the southern boundary to the east will also be offset from the site’s boundary to accommodate an open space corridor. That open space corridor will also incorporate significant tree planting to provide an attractive setting for the open space, and border the proposed pedestrian link through the open space corridor that in turn links to the play space that is proposed near to the site’s southern boundary.

A further open space corridor will be provided at the site’s north-west, providing opportunities for habitat mitigation, informal recreation and also helping to assimilate the site with its surrounds. That open space area and the residential aspect adjacent to it will be well connected to the aforementioned more significant open space area to the site’s south via a footpath link that will travel along the site’s western boundary before heading towards its southern boundary. The footpath will then exit the site at its south-western corner, providing access to Bromwich Lane and Redlake Drive. That will provide a key pedestrian link towards the services and facilities available within Pedmore to the north.

As such, it is clear that a well-designed and sensitive development scheme can be delivered to maximise the potential of a suitable site in a sustainable location, in a manner that will promote the BCPs’ approach to development by focussing development to a site that will round off the built form and promote clear and have the least impact on the Green Belt and surrounding landscape. Indeed, the development of the site will establish a robust Green Belt boundary that will strengthen the integrity of the retained Green Belt.

In the context that the BCP should maximise delivery from within the jurisdiction of the BCAs so as to meet a higher proportion of their own needs, the site should clearly be allocated without delay as part of the significant modifications that should be made to the plan ahead of the publication of the Regulation 19 document.