Object

Representation ID: 21763

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

Draft Policy GB1 (The Black Country Green Belt)

2.104 Draft Policy GB1 is unsound as it does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for housing.

2.105 As set out in its response to Draft Policies CSP1 and HOU1, St Philips objects to the BCP on the basis that it seeks to provide only 47,837 dwellings in the plan period, leaving a significant shortfall of 28,239 dwellings. The BCP has failed to provide sufficient land to meet the minimum housing needs, as per NPPF paragraph 11(b), and will need to ensure that additional housing land is provided through further Green Belt release.

2.106 As earlier indicated, there are several shortcomings in the Black Country Green Belt Study: Stage 1 and 2 Report (Land Use Consultants, September 2019), and it is considered that the omission of several sites submitted through the Call for Sites is unsound on the basis that the Green Belt Study has applied an inconsistent and flawed approach in the assessment of sites submitted through the Call for Sites.

2.107 This is because the Stage 1 Contribution Assessment has been prepared at such a strategic level as to render its findings on the extent of the potential harm to the Green Belt purposes, as a result of development, questionable when applied to smaller individual potential development sites adjacent to the urban areas.

2.108 By way of example, the geographical scale of some parcels is extremely vast (e.g. between 100-
500 ha) whilst others are of a much smaller scale (e.g. between 1-50 ha).

2.109 This varying scale will undoubtedly have a negative and inconsistent impact on the scoring identified in the Green Belt purposes ratings for each parcel, as set out at Table 5.1 within the Stage 1 Findings (page 44).

2.110 St Philips considers the larger Green Belt parcels are capable of logical sub-division based on defensible boundaries. It also recommends that all of the parcels should be of a similar size and that care should be taken to ensure that a consistent approach is taken in respect of the assessment of different parts of the Black Country. This could be achieved through the subdivision of some parcels to ensure that they are all more equally sized. Indeed, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale.

2.111 The approach taken in respect of generating the land parcels for assessment is set out at paragraph 4.29:

“By combining the lines marking variations in contribution to Green Belt purposes, a list of land parcels was generated, each of which has a reference number and a rating for contribution to each purpose. The parcels are the product of the assessment rather than a precursor to it. The reasoning behind this approach was to draw out variations in contribution to inform the site-specific assessments undertaken at Stage 2, avoiding broad variations in contribution within prematurely and more arbitrarily defined parcels. Avoiding significant variations in contribution within defined parcels prevents the need for ratings to be
generalised to reflect the strongest or average level of contribution within a defined area.”

2.112 Whilst the Stage 2 Harm Assessments consider the sub-parcels at a smaller scale, it is noted that not only are some of these sub-parcels still at a significantly large and inconsistent scale (some extend to <10ha whilst others are >100 ha), but that the assessment of harm is effectively an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.

Land west of Foxcote Farm, Oldnall Road, Stourbridge

2.113 This issue is evident through the assessment of land west of Foxcote Farm, Oldnall Road, Stourbridge (Call for Sites ID 178).

2.114 St Philips is promoting land west of Foxcote Farm, Oldnall Road, Stourbridge and submitted the site accordingly through the Call for Sites process. A Vision Document is submitted alongside these representations that demonstrates how approximately 180 dwellings could be delivered on site ID 178. This could come forward as an early phase as part of a wider future strategic
allocation on ID 295.
[see site specific representation]

2.121 This is a fundamental flaw in the methodology of the Green Belt Study which results in a failure to account for a more localised assessment of how sub-parcels and promoted sites perform against the Green Belt purposes. As a result of this shortcoming, the land west of Foxcote Farm, Oldnall Road, Stourbridge which would have otherwise been selected for Green Belt removal, has been artificially omitted.