Comment

Representation ID: 23462

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

The impact on the Black Country’s Green Belt.
The Black Country Green belt is unusual insofar as it comprises a network of green wedges
which separate induvial settlements within the Black Country communities. Unlike the
London Metropolitan or Birmingham Green Belts it does not simply surround the
conurbation.
The BCP makes the controversial proposal to remove areas of green belt to provide room for
some 7,720 dwellings across the Black Country. This comprises land for:
1,117 homes in Dudley,
171 homes in Sandwell,
5,418 homes in Walsall, and
1,103 homes in Wolverhampton
Understandably, these proposals have proved unpopular with local people and with local
politicians to the point where public statements have been made challenging the loss of
green belt and it is doubtful whether the Black Country Local Plan will ultimately receive
members’ support. The West Midlands Mayor (who doesn’t have strategic planning powers)
but does seem to have a wider influence, has also declared himself resistant to green belt
development within the boundaries of the conurbation.
Under Paragraph 140 of the NPPF Government guidance stresses that ‘green belt boundaries
can only be altered where exceptional circumstances are fully evidenced and justified,
through the preparation or updating of plans. Strategic policies should establish the need for
any changes to green belt boundaries…’
Whilst in circumstances such as these it is likely to be feasible to meet the criteria for some
green belt releases through the Local Plan process, but it is important to recognise that
paragraph 141 stresses that ‘Before concluding that exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to
demonstrate that it has examined fully all other reasonable options for meeting its identified
need for development. This will be assessed through the examination of its strategic policies’.
In this particular case, it is important to note that other opportunities to develop beyond the
green belt in and around Telford do exist without affecting green belt land in the Black
Country. Indeed, in years gone by, Telford New Town served as a formal overspill function
and provided just such a ‘safety valve’ to enable people to move elsewhere in the sub-region
to enjoy new opportunities, whilst not encroaching on the West Midlands green belt.
(Those formal overspill arrangements have long since expired, but the new town of Telford
has still not reached its original target population of 225,000 and yet still enjoys the benefit
of extensive infrastructure provided by the Exchequer to service the overspill population).
Furthermore, arguably, in a post-covid world, the Black Country now badly needs to protect
its landscape, environmental and ecological assets (as well as its recreational green space)
rather than gradually encroaching on its green belt and filling in the network of gaps
between established settlements which makes the Black Country so unique. At the same
time, it is entirely feasible that many people may relish the prospect of moving to a new
sustainable waterside development in Telford – against the background where many people
now appreciate the value of better space standards and greater open space which a new site
at Telford – or indeed at Codsall can offer. These opportunities need to be explored.