Comment

Representation ID: 22171

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

The Club have previously submitted representations to the Black Country Call for Sites Consultation. These representations proposed the removal of a parcel of land at the entrance to Druids Heath Golf from the Green Belt and its allocation for residential development. The site has not, however, been identified as a proposed residential allocation in the Regulation 18 consultation document.

The land in the Club’s control that that was subject to the previous Call for Sites representations constitutes site SA-0063-WAL – Land at Druids Heath Golf Club, Stonnall Road, in the Black Country Plan Site Assessment Report (“BCSAR”). It is concluded that the site is unsuitable for development. In essence, and incorrectly, the BCSAR concludes that the vehicle movements and activities associated with a golf club are incompatible with residential development. It is suggested that the development would have an “awkward” relationship with the clubhouse and its associated carparking. As detailed in these representations this is clearly not the case, as golf clubs adjoining residential development are commonplace. Indeed, vehicles traveling to the Club have to pass along residential roads to gain access to the site. Furthermore, the emerging Plan is proposing residential development in this location on land immediately adjacent to this site (proposed allocations WAH253). This allocation has an almost identical relationship to the clubhouse and its car park. This approach is clearly inconsistent

In addition to site SA-0063-WAL the Club are requesting that additional land is allocated for development. The full extent of the land in the Club’s control that is being promoted for development is shown on the Plan attached at Appendix 1. It is suggested that site SA-0063-WAL should be extended to include the area of car parking to the east. This results in this site becoming part brownfield and part greenfield. If the car park is allocated for development the parking will be replaced elsewhere within the Golf Club. The construction of a new car park would constitute an “engineering operation” and would, therefore, fall within “certain other forms of development” that are not inappropriate development in the Green Belt as defined by paragraph 150 of the Framework. The second parcel of land is located to the east of the Stonnall Road, immediately to the north of proposed allocation WAH 253.

It should be noted that the Club are promoting the development of these sites in order to help generate funds that will be ploughed directly back into the Club. The Club have identified a range of projects that cannot currently be afforded. The sale of this land for residential development will generate funds that can be invested to improve club facilities and help retain and attract new members. Nationally golf club membership levels have fallen over the last 10 years with a large number of clubs closing. Additional investment in the Club will help ensure its long term future.

We have reviewed the draft plan in detail and give our observations and representations below. It is clear to us that, notwithstanding the undoubted work which has gone into preparing the plan, it is extremely unlikely that the plan as currently drafted will achieve the objectives for housing in the Black Country and further sites are required. The land owned by the golf club can only help in this regard and, for the reasons set out below, is more appropriate than the adjoining land which is in the draft plan. Also the provisional reasons for its non inclusion are not supportable when analysed in more detail.”