Object

Representation ID: 21764

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

[Unallocated site - Land west of Foxcote Farm, Oldnall Road, Stourbridge CFS REF:178&295)


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.

Stage 1 Contribution Assessment

2.115 Within the Stage 1 Contribution Assessment, the site forms part of Parcel Reference B65 (Wychbury Hill, Foxcote and Lutley) with a parcel size of 302 ha, as illustrated below.
[see map in attachment]

.116 As can be seen, the parcel boundary incorporates a significantly large extent of Wychbury Hill, Foxcote and Lutley. Ultimately, it is considered that 302 ha is too large of a geographic area such that meaningful conclusions can be drawn as to the Green Belt Purposes of sub-parcels
within the wider parcel. By way of comparison, a large proportion of other parcels within Dudley
have been drawn significantly smaller at between 1-50 ha.

2.117 As earlier established, 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. This inconsistent approach has therefore unfairly resulted in parcel B65 being assessed as performing generally strong against the Green Belt purposes:
[See table in attachment]
118 This inaccurate scoring has consequently followed through into the Stage 2 Harm Assessment.

Stage 2 Harm Assessment

2.119 Within the Stage 2 Harm Assessment, the site form parts of Sub-Parcel Reference B65B (Foxcote) with a parcel size of 110.1 ha, as illustrated below.
[see maps in attachment]

2.120 Whilst the Stage 2 Harm Assessments has considered the sub-parcel at a smaller scale, and which is broadly aligned with the promoted site ID 295, the assessment of harm of ‘Very High’ has effectively been derived from an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.

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.