Comment

Representation ID: 23056

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy GB1 – The Black Country Green Belt
Alterations to the Green Belt require exceptional circumstances in accordance with National Planning Policy Framework (‘NPPF’) paragraph 140. Given the scale of housing need and an identified shortage of brownfield land to meet the need (Urban Capacity Report 2021), we agree with the BCA that there are exceptional circumstances to justify the release of Green Belt.
The policy states that compensatory improvements will be required to offset the impact of removing land from the Green Belt. The Viability and Deliverability Study (May 2021) has allowed for a compensatory contribution of £1,000 per dwelling. No details have been provided on the projects this contribution will fund nor whether improvements could be made on site or on other land within the same ownership/control in lieu of paying the contribution.
The BCA is currently not proposing to safeguard any land for future development within the plan. Paragraph 143 of the NPPF states that plans should “identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period” and “be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period” [Savills emphasis]. Given the BCA has determined that Green Belt release is already required to meet current housing needs and it is acknowledged that there is a significant housing shortfall arising from the BCA and wider HMA, it is accordingly expected that additional Green Belt release will be required to meet the development needs of the District beyond the plan period. It is also considered to be likely that additional Green Belt release will also be required within the plan period as well.
We therefore consider that in order to accord with NPPF paragraph 143, the BCA should be identifying additional land in sustainable locations which can be released from the Green Belt in the plan and safeguarded for future housing needs beyond the plan period. Our client’s land to the west of Chester Road (Call for Sites ID 107) is considered to be in a sustainable location and could be an appropriate addition to Strategic Allocation WSA9 within the plan or at the least, it could be safeguarded to assist the BCA in meeting future needs.