Object

Representation ID: 23367

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CSP1

Housing Land
West Midlands CPRE object to the proposed level of housing in Para 1 (a). In particular, we do not consider the removal of land from the Green Belt on the scale proposed for 7,720 houses is justified. While there is a shortfall identified in the plan, the attached report (which we commissioned) on the Updated Urban Capacity Report casts doubt both on the need and supply side of the housing assessment, something we address in more detail in relation to Policy HOU1.
A policy which provided 40,117 houses in line with the capacities identified from other sources would perhaps be appropriate but would fail to account for the additional housing sources identified in that report as likely to come forwards, notably from windfalls (perhaps as many as 6,000 additional homes). In our view the potential for housing development on existing retail, leisure and employment sites which are underused, or likely to come on the market for redevelopment, is still not being adequately explored.
Moreover, the 35% uplift of housing in Wolverhampton was not intended to result in additional greenfield housing, as is made clear in the Government Statement of 16 Dec 2020, whether in the Black Country or in surrounding area, so the Plan should identify that housing (5130 units) as specifically to be met from additional brownfield land (a position being taken by Bradford Council, for example).

Employment Land
In terms of Employment Land, we generally support the allocations but have specific concerns about the Allocations at WAE 409 and 410, close to the Sandhills NGA, (which amount to some 14.33 hectares). These are two parcels of land where the impact on Green Belt is considered by LUC to be either Moderate-High or High, although they are bounded by roads and so have a defensible boundary.
Taking them out would reduce the total Employment Land allocated to 340 hectares in CSP1.
However, we would urge ABCA to review this amount. The BEAR Study appears to be biased towards retaining employment land. While this may be the right approach there may well be sites where the balance still favours change of use to housing, and/or where the sites will become available because demand is suppressed. On both these counts the total; figure of 355 hectares should be reviewed prior to submission of the Final Draft (Regulation 19 stage)Green Belt

We also object to Para 2 (a) and (d) of CSP1. We believe most, if not all, reasonable development should be accommodated within the Black Country conurbation itself, and only very limited Green Belt releases accepted. We do not support the proposal for ‘Neighbourhood Growth Areas’ (NGAs), which are in effect Urban Housing Extensions into the Green Belt. In many cases they are on sites which, in the LUC Green Belt Study are considered to have a high impact on the Green Belt.
We agree with Para 2 (e) which seeks to support the integrity of the West Midlands Green Belt. However, this policy wording assumes that the NGAs have already been removed, causing damage to the Green Belt as it is now.

Climate Change
We also support Para 2 (g). However, the plan lacks a clear policy to mitigate climate change and the location of development on sites such as the NGAs is not clearly tested against its impact on Climate Change. A policy is needed which specifically elucidates the target the Black Country has for Net Zero Carbon Emissions and how that will be achieved in terms of the spatial location of development.

Table 2 (Development Strategy)
We also, therefore, object to Table 2. We would remove the NGAs, and instead include housing identified from the sources of supply identified in our report, including larger wind- falls and additional town centre housing.
We would also reduce the overall total. We believe there is a strong case for the Black Country arguing to adopt the 2016-based ONS Projections which would amount to 55,993 dwellings in the Plan Period (60,059 if the 35% uplift for Wolverhampton is included). That 35% uplift should be specifically aimed at Urban Regeneration sites and would (in general terms) be equivalent to and so numerically replace the Neighbourhood Growth Areas.
As a result of such a calculation the potential overspill to be dealt with through any duty to cooperate arrangement would be reduced by approximately 15,000 to approximately 13,000.
Since there will be an opportunity to review the numbers prior to the Submission Draft stage, these approximate figures are a sound basis to review the provisional allocations and remove those allocations which impact on the countryside, undermine urban regeneration and would impact on the integrity of the Green Belt

Para 3.15-3.16 (Green Belt)
We object to Paragraph 3.15-3.16 of the Plan. This section of the Plan identifies the Green Belt assessment that has been undertaken and claims the impact of the chosen sites would ‘cause the least harm to the purposes of the Green Belt and to landscape character’.
However, the LUC Green Belt Study makes clear that many of the proposed development sites, particularly in Walsall are identified as having a High, even Very High impact on the role of the Green Belt. Most are also in sensitive locations at the edge of Urban Areas with a high impact on the amenity of the Public. A particular example is the open land adjacent to Walsall Arboretum. A fault of the LUC Green Belt Study is that its choice of settlements to include in its analysis specifically excludes small sites at smaller settlements such as Rushall and Pelsall, creating a bias in favour of sites adjacent to those areas next to large urban areas - which are the sites now included in Plan.
Moreover, Para 3.16 of the Plan refers to defensible Green Belt boundaries. This would normally mean a road or other development. Yet there are sites which are poorly defined in that way. The Sutton Road site, for example, has no boundary to stop development further between the canal and Longwood Lane, The Sandhills site has no clear boundary towards Lichfield. The Bushbury site is adjacent to open land.
[table identifying green belt sites and the assessment in the LUC report – can be viewed in attachment]

Para 3.20-3.27 (Duty to Cooperate)
CPRE objects to the approach to Duty to Cooperate. The Government has signaled that it will seek to abolish this mechanism but has not said what will replace it. However, even if it stays the text is misleading in our view. It refers in Para 3.20 to land in the Black Country being ‘finite’. In practice there is likely to be considerable change during the Plan period to the urban core freeing up land for different purposes.
Coupled with the questions we raise regarding to housing numbers, our view is that the genuine requirement for housing in other local authority areas to meet the Black Country’s needs is likely to be considerably lower than anticipated.
We are aware that several local planning authorities, notably South Staffordshire and Shropshire, have offered to include significant amounts of housing in their plans to accommodate Black Country growth as the table below shows (reproduced from ABCA evidence to the Solihull Plan Inquiry.)
[table including details of adjacent local plans – can be viewed in attachment]

In the case of Shropshire, the location remains unclear but is likely to be the M54 corridor which is poorly served by Public Transport and where large-scale housing is likely to exacerbate commuting into the conurbation, adding to congestion on the M54 and M6, and to carbon emissions.
In the case of South Staffordshire, the sites are near the conurbation but many have high environmental and Green Belt impact, for example the site at Little Penn. While these sites are outside the Black Country boundary, in many cases they will have similar effect to those within the conurbation.
CPRE Shropshire and CPRE Staffordshire are responding separately to those Local Plans.
Moreover, the assumptions about on-going shortfalls in both the Black Country and Birmingham seem to us flawed. In the case of Birmingham, the approved Local Plan (2014) seriously under-estimated windfall housing delivery, as shown by the actual level of windfall development since. It may well be the case that this is repeated in the Black Country, albeit from potentially different sources.
We certainly do not consider other local planning authorities, such as Solihull, should be required to contribute to a claimed Back County ‘unmet need’ when the data and assumptions and data base for on which the Black Country Plan is based have yet to be fully tested.