Comment

Representation ID: 22300

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

Draft Policy GB1 (The Black Country Green Belt)
2.98 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.
2.99 As set out in its response to Draft Policies CSP1 and HOU1, Investin 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.
2.100 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.
2.101 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.
2.102 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).
2.103 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).
2.104 Investin 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.
2.105 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.”
2.106 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 South of Little Aston Road, Aldridge, Walsall
2.107 This issue is evident through the assessment of land south of Little Aston Road, Aldridge, Walsall (Call for Sites ID 332).
2.108 Investin is promoting land south of Little Aston Road, Aldridge, Walsall and submitted the site accordingly through the Call for Sites process. A Vision Document is submitted alongside these representations which demonstrates how up to 170 dwellings could be delivered at the site.
Stage 1 Contribution Assessment
2.109 Within the Stage 1 Contribution Assessment, the site forms part of Parcel Reference B93 (East of Walsall) with a parcel size of 1768.3 ha, as illustrated below.
Figure 2.4 Parcel B93 at Stage 1 Contribution Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
Figure 2.5 Parcel B93 at Stage 1 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.110 As can be seen, the parcel boundary incorporates a vast swathe of the east Walsall. Ultimately, it is considered that 1768.3 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 Walsall have been drawn significantly smaller at between 1-50 ha.
2.111 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 B93 being assessed as performing generally strong against the Green Belt purposes:
Table 2.5 Performance of parcel B93 against Green Belt purposes [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.112 This inaccurate scoring has consequently followed through into the Stage 2 Harm Assessment.
Stage 2 Harm Assessment
2.113 Within the Stage 2 Harm Assessment, the site form parts of Sub-Parcel Reference B93D (Little Aston Road) with a parcel size of 96.8 ha, as illustrated below.
Figure 2.6 Parcel B93D at Stage 2 Harm Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
Figure 2.7 Parcel B93D at Stage 2 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
2.114 Whilst the Stage 2 Harm Assessments has considered the sub-parcel at a smaller scale, it is not broadly aligned with promoted site reference #173 and fails to illustrate promoted site reference #332. Additionally, 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.
2.115 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 at Little Aston Road, Aldridge, which would have otherwise been selected for Green Belt removal, has been artificially omitted.
2.116 The Green Belt Study methodology should be reviewed and amended to address this issue, and the land at Little Aston Road should be proposed for removal from the Green Belt and allocated for housing accordingly.