Comment

Representation ID: 22486

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site selection in Dudley
We welcome the findings of the Site Assessment Report: August 2021 and consider this to be a
mostly robust piece of work to identify sites for selection. However, we do have some concerns
regarding the lack of weight/regard given to the GBHMA Strategic Growth Study 2018 in the final
site selection process, particularly in broad locations identified by the 2018 study in the Dudley
area (Appendix A of that document).

It currently appears that only 860 dwellings are proposed on Dudley’s Green Belt edge, in two sites
forming the Kingswinford Neighbourhood Growth Area. However, previous correspondence
received from the Black Country authorities in response to South Staffordshire’s 2019 Spatial
Housing Strategy and Infrastructure Delivery (SHSID) consultation indicated that there was
potential for up to 5,000 dwellings to be delivered in Green Belt areas surrounding Dudley2. Whilst
we appreciate this was only a high-level indication of capacity, it also appeared to be broadly
consistent with the more detailed findings of the GBHMA Strategic Growth Study 2018. This
recommended that the western edge of the Black Country (including Dudley) could accommodate
500-2,500 dwellings through dispersed housing development, whilst the southern edge of Dudley
(around Halesowen) had the potential to accommodate a 1,500-7,500 dwelling sustainable urban
extension based around garden village principles. Whilst neither option was without its potential
constraints, these two areas of search were still considered on balance to be more sustainable,
deliverable and less harmful to Green Belt purposes than other strategic development
opportunities elsewhere within the GBHMA.

Given the acuteness of the regional housing shortfalls, it is important that the GBHMA Strategic
Growth Study’s recommendations are fully explored. In light of this, we do not consider that the
Site Assessment Report: August 2021 has given sufficient weight to the findings of the GBHMA
Strategic Growth Study 2018 and do not consider it currently offers a robust basis for establishing
the upper end of Dudley’s potentially suitable Green Belt capacity. Specifically, it currently appears
that large numbers of site options have been discounted on Dudley’s Green Belt edge not because
they are truly undeliverable, but because they are not considered to be sufficiently suitable (e.g.
sufficiently free from policy constraints) and have not arisen from a wider GBHMA-wide evidence
base. This also affects many sites in broad areas recommended for growth by the GBHMA Strategic
Growth Study 2018. Common reasons given in the site assessment conclusions for rejected sites in
Dudley’s Green Belt include:

• Levels of sensitivity/harm identified in the 2019 Green Belt Study and Landscape Sensitivity
Assessments
• Additional local designations or officer judgements which duplicate factors already
considered through the cross-boundary 2019 Green Belt/landscape sensitivity evidence
• Comments regarding proximity to heritage assets which do not indicate whether heritage
impacts could be mitigated or are likely to be significant, which do not appear to reflect an
accepted Historic England methodology for understanding of the significance of a heritage
asset3
• Constraints that are likely to be capable of mitigation/compensation through site layout
(e.g. minor areas of Sites of Local Importance for Nature Conservation (SLINC)/Sites of
Importance for Nature Conservation (SINC) coverage within a site, slight overlap with Flood
Zones on a site’s boundary corner)

A list of the sites within Dudley’s Green Belt that appear to be capable of delivery but have been
discounted largely on the basis of the reasons given above are included in Appendix 1 of this
response. [see attachment]


We also note that many of the sites listed in Appendix 1 fall within areas of Very High harm Green
Belt and Moderate-High landscape sensitivity4, which the Black Country have previously indicated
would be considered a significant constraint on site options5. We agree with the general principle
of considering sites options’ relative suitability based upon local Green Belt/landscape evidence
and do not have any concerns with the threshold proposed. However, we do not believe it is
appropriate to use such a threshold to discount strategic recommendations of the GBHMA
Strategic Growth Study 2018, given the scale of the shortfall and knock-on impacts this will have
on shortfalls elsewhere in the GBHMA. Green Belt purposes, landscape character impacts,
sustainability and deliverability of such locations have already been considered at a GBHMA-wide
level through the GBHMA Strategic Growth Study 2018. Therefore, in lieu of better HMA-wide
evidence, it is imperative that the recommendations of the 2018 study are fully explored and
delivered as far as possible.

If the Black Country are of the view that the GBHMA Strategic Growth Study recommendations
cannot be accommodated in the specific areas of search proposed in that study (e.g. South of
Halesowen) then it is imperative that other site options around Dudley’s edge are explored fully to
offset the loss of housing delivery this implies. This is particularly important as Dudley’s
administrative area holds significantly more areas of potential Green Belt than other Black Country
authorities (aside from Walsall). To do otherwise risks shifting these pressures into less sustainable
locations within the GBHMA which are more remote from the source of unmet need (the Black
Country). We do not believe it would be sustainable or desirable for all Green Belt land in Dudley to be allocated without regard to suitability factors. However, the Site Assessment Report: August
2021 clearly shows there is a wide choice of land (as indicated in Appendix 1 of this response)
capable of accommodating a higher Green Belt housing supply figure in this area, consistent with
the figures given in the previous 2019 correspondence from the Association of Black Country
Authorities and the scale of locations identified for growth in the GBHMA Strategic Growth Study
2018. We would welcome further discussions with the Black Country authorities to ensure a
consistent cross-boundary approach to this issue.


2 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf
bases (e.g. Areas of High Historic Landscape Value, judgements regarding settlement
patterns, defensible boundaries and settlement gaps etc.)
3 See Historic England guidance available here: https://historicengland.org.uk/images-
books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-
local-plans/)
4 As set out in 2019 Black Country Green Belt Study and Landscape Sensitivity Assessment
5 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf