Support

Representation ID: 22372

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

RSL also fully support the approach adopted by Policy GB1 – The Black Country Green Belt. Part 2 of the policy confirms that sites are to be removed from the Green Belt and allocated to meet housing, employment, or other needs. It continues by stating such proposals will be designed to ensure new green belt boundaries are defined in a readily recognisable and permanent way, and that compensatory improvements of the remaining green belt will be secured to offset the impact.

The extensive and up to date evidence base which has informed the Plan-making process to date has fully demonstrated that the exceptional circumstances necessary to amend Green Belt boundaries exist. This is most evident in view of the fact that even with the removal of some, lower performing and less sensitive Green Belt land, there remains a significant shortfall in both the future housing and employment land requirements over the plan period.

Paragraph 140 of the NPPF confirms that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 141 continues that before concluding that exceptional circumstances exist, the relevant authority should demonstrate it has examined fully all other reasonable options for meeting its identified needs, including making the best use of brownfield land, optimising densities in towns and cities and other locations well served by public transport, and informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need.

The BCA’s evidence base includes the Urban Capacity Review Update 2021, a recent update to on-going studies to assess and quantify the potential capacity of land within urban areas, including brownfield land. The Review confirms that capacity within the urban area could deliver 39,257 homes and 205 hectares of employment land to 2039. This update has also incorporated assumptions about increasing densities where local character allows. This clearly demonstrates that all other reasonable options for accommodating the full housing and employment needs within the Plan area have been investigated, prior to considering Green Belt release.

On the basis of an identified shortfall of 36,819 homes and 360 hectares of employment land, Paragraph 3.24 of the BCP confirms that the BCA have worked constructively with neighbouring authorities to explore the ability for these shortfalls to be located elsewhere outside the Plan area. Notwithstanding, it is clear that whilst this will be an on-going exercise, the BCA recognise that this may only address a proportion of the shortfalls. Whilst the exact level of BCA unmet need is not confirmed within the BCP and will no doubt continue to be an evolving issue, the accompanying BCP Summary document indicates that at present, offers from neighbouring authorities suggest that between 8,000 to 9,500 homes and 102-173 hectares of employment land could be accommodated, albeit this will need to be tested by their respective Local Plan reviews.

In the circumstances, RSL consider the BCP and its associated evidence base clearly indicate there are exceptional circumstances justifying the release of Green Belt land within the BCP area. Associated Green Belt and Landscape Sensitivity Assessments have been undertaken and as confirmed at paragraph 3.16 of the BCP, have identified land that if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Grebe Belt boundaries. In respect of housing, even taking account of existing urban capacity, proposed Green Belt release and the current best-case scenario regarding the export of unmet needs to neighboring authorities, there is still a potential shortfall of some 18,739 homes. A similar scenario is likely in respect of employment land.