Support

Representation ID: 22485

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site delivery in Walsall
Notwithstanding our concerns regarding Dudley’s site selection process, we support the Black
Country’s efforts to identify housing growth within the Green Belt. Across the Black Country, the
Draft Plan appears to release land capable of delivering 7,720 dwellings within the Green Belt up to
2039. The vast majority of this supply arises from Walsall, which is proposing 5,418 dwellings up to
2039 on Neighbourhood Growth Areas identified within the local authority’s Green Belt.

South Staffordshire does not object to the sites selected in the Walsall area, subject to cross-
boundary working to understand and mitigate any cross-boundary infrastructure impacts.
However, we do have concerns that the figures given in the Draft Plan for the selected sites under-
represent their true contribution to housing supply within the plan period (i.e. up to 2039). Having
reviewed the sites in Tables 30 and 31 of the Draft Plan, we consider that the true capacity of the
selected Neighbourhood Growth Areas identified in Walsall is likely to be around 1,715 dwellings
higher than the figure given in the consultation document. This is due to what appear to be overly
conservative estimates of larger site delivery affecting five housing sites allocated in the Walsall
area. The site-specific reasoning behind this is given in Appendix 2 of this response, but in
summary assumptions used to estimate site delivery up to 2039 appear to be contrary to the
assumptions given in paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study
(May 2021).

We would request this matter is revisited to ensure that the true capacity of Green Belt release in
Walsall is reflected in the submitted plan. Failing to do so will put unnecessary pressure on Green
Belt elsewhere in the Black Country and in other neighbouring authorities.