Object

Representation ID: 23570

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

BROWN FIELD AND DERELICT LAND SITES FIRST (Policy DEL2 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group considers that the changing evidence and absolute scale of Brownfield and Derelict Land sites development for housing purposes and needs has to be monitored thoroughly and plotted to understand the dynamics at play in the sub-region and neighbourhoods.

With few reservation, mostly relating to the characteristics and locality of specific sites, the Save the Seven Cornfields Campaign Group supports Housing Development on Brownfield and Derelict Land sites. The Save the Seven Cornfields Campaign Group opposes development on the Seven Cornfields Green Belt and other important Green Belt zones.

There is ample Brownfield and Derelict Land sites within the Black Country sub-region to service its needs for several years into the next decade and further. Incentives can assist developers to make the right decision.

When Derelict Land grant, sometime ago, was available to Local Authorities for tackling Dereliction, many sites where annually transformed into productive use including housing across the sub-region.

Taxation relief is another method to ensure a faster rate of transformation of Derelict and Brownfield sites. Governments should be lobbied to provide such assistance.

The failure to develop Brownfield sites has much to do with margins of profitability and economies of scale. This a private sector consideration and not necessarily an economic concept applicable to the public who instinctively know what is known as a Public Good in Economic Theory.

It is easier and more profitable to develop on most Green Belt and Green field sites than on Derelict and Brown Field sites. It is not, however, always easier and more profitable to develop on most Green Belt and Green Field sites when the infrastructure costs of over-intensification of use of services are taken into consideration.

In addition, Housing Developers and Speculators favour the acquisition and land banking of Greenfield sites to control the price of land already held by them and can be classed in their accounts as an investment. In the same manner, the most famous Diamond monopoly merchant buys and then withholds diamonds to ensure a higher price than would be naturally be the case if these diamonds where released on the open market. Artificial scarcity is created for Housing land (and diamonds).

Notwithstanding these facts, there is no logical reason for a Local Authority to release Greenfield sites or extinguish Green Belt status when there are many Brown Field and Derelict Land sites to develop first.

Allowing easy access to Green Belt development means the unsightly Brownfield and Derelict Land sites will remain for longer than necessary were the natural market mechanisms not distorted by Land Banking. They will not be transformed into useful use when they could have been.

Anybody with an eye to sustainable Land Use policy and environmental conservation in its largest sense would ensure the future Housing Demand was met by a policy of Brownfields first.

On 17th March 2017, West Midlands Combined Authority (WMCA) Board received a Report entitled Land Fund: Black Country Strategic Brownfield Land Programme. The Report noted:

“The Brown Field Strategic Brownfield Land Programme has identified a robust and deliverable pipeline of £342m of schemes, leveraging total investment of over £1.4b within three Priority Propositions of Delivering Black Country Garden City, Establishing High Value Manufacturing (HVM) Capital City and Strategic Population Centres.”

With investment from the WMCA Board, the Report made it clear that remediation would deliver 1600 houses. What higher levels of reclamation could be achieved over the Local Plan period with a more targeted approach? Enough to not need development of the Green Belt (or the additional 4,000 pledged by South Staffordshire Council).

Given the rising vacancy trends in retail, office and industrial property and the diminishing demand, the annual growth of the supply rate of unwanted commercial and Derelict Land and Brownfield sites will increase and the net result will be a year-on-year incremental growth and, therefore, a much higher total availability of such sites -unless of course there is a consequential turnover of reclamation for productive use like Housing. (This then suggests that less of the South Staffordshire Housing requirement -either normal (4,000) or exaggerated target (8,000) - will have to come from Green sites or the Green Belt.)

TRIPLE LOCK - PREVENTION OF PLANNING BLIGHT (policy Del 2 in the Black Country Plan 2039)

If the prospect of additional houses as planned and formally agreed in the Black Country Plan 2039 moves to that reality then measures must be in place to prevent the problems, recently witnessed, when retailers acquired land or development rights in cities to prevent expansion of their competitors. In Wolverhampton City Centre this created long standing problems.

If developers or builders were to start but not complete work on all the Green Belt sites then the worst of all worlds would have arrived; lost Green Belt but not completed sites with a few houses but no amenities.

Planning Blight is where the reduction of economic activity or property values in a particular area result from expected or possible development.

The Save the Seven Cornfields Campaign Group proposes that there should be a Triple Lock applied to Green Belts. There should be proper monitoring of housing development in Black Country (& South Staffordshire) and Green Belts at risk and other important Green Sites should not be released at once but a phasing should be operable.

The release of individual sites should then only occur when it is obvious that the available non-Green Belt sites in the Black Country (& South Staffordshire) and the Brownfield and Derelict Land sites in the districts within the Black Country have been developed, that the Black Country Housing figures have not been met year-on-year and the lowest graded Green Belt sites with the fewest constraints get released first.

This Triple Lock should be written within the Black Country 2039 Plan’s Objective and Planning and Development Briefs and it must form the basis of future agreements with developers and builders.