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Representation ID: 23583

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

3.1 Government planning policy on Green Belts can be found in the National Planning Policy Framework (NPPF). Paragraph 138 explains that the Green Belt serves five purposes. These are:
“a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”
3.2 The NPPF continues at Paragraph 139 that:

“The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions.”
3.3 Paragraph 140 then states:
“Once established, Green Belt boundaries should 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, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non-strategic policies, including neighbourhood plans.”
3.4 WDL note that that Council’s Local Plan evidence base shows that based on land availability ‘Exceptional Circumstances’ do exist to release land from the Green Belt for development and that it has carried out a full ‘Green Belt Assessment’ to find the most appropriate releases.
3.5 Site WSA6 is proposed to be removed from the Green Belt. WLD support that approach.
3.6 Previously P&DG prepared a ‘Call for Sites’ submission for site on behalf of WLD. The submission included our own Green Belt Assessment of site WAS6. We have also responded on behalf of WDL to the Black Country Green Belt Study. In relation to the 5 purposes of Green Belt (NPPF Paragraph 138 above), we made the following comments regarding site WAS6:
Purpose 1 -Check the Unrestricted Sprawl of large built-up areas
3.7 The site is bordered by urban development on the majority of its eastern and southern boundaries and is strongly contained by both this and the landscaped edge of the Rushall Canal to the west. The site is also compartmentalized by integral landscaping and sub-parcels denoting field boundaries, limiting its openness significantly. The site therefore has a predominant relationship with the urban fringe of Walsall as opposed to the countryside.
Purpose 2: Preventing the Merging of Neighbouring Towns
3.8 The development of the site would have a minimal impact in terms of coalescence. The development site lies on the edge of Daisy Bank, an existing part of Walsall. There is consequently no danger of this development leading to the merging with any adjacent separate urban area. The physical housing development will not protrude any further north beyond the existing ribbon development that fronts onto Sutton Road; it will in fact be situated behind it. As a result, there would be no cumulative extension of residential development northwards into the Green Belt that would ordinarily result in a reduction in the gap between Daisy Bank and Aldridge. The development would result in built form extending westwards towards the Rushall Canal but would not diminish the function of the area of Green Belt that extends in from the surrounding countryside towards the Walsall Arboretum.
3.9 This site performs no distinct role in contributing towards the gap between Walsall and Aldridge and the development limits would be contained in parallel with existing development without any further encroachment northwards towards Aldridge.

Purpose 3: Safeguarding the countryside from encroachment

3.10 The site’s eastern and southern boundaries are urbanised by residential development along Sutton Road. On the horizon to the west are notable urban structures forming the settlement of Walsall including urban development, including high rise housing. The sites’ location and surrounding uses can be described as urban fringe. We consider that the location and wider context would suggest that it possesses a stronger physical and visual connection with the existing urban form in Walsall, not limited solely to the neighbourhood of Daisy Bank but also the urban form further afield towards the central part of the town and at the western extent of the Walsall Arboretum.

3.11 It is accepted that the development would result in some encroachment into the defined countryside, but its contribution to this purpose is low as the site has a stronger relationship with the urban area than the countryside.

Purposes 4 is not applicable to this site

Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

3.12 The release of Green Belt in this location would place no harm upon the premise that is held in the development plan to allocate brownfield sites on a preferential basis, since from all of the evidence available there is simply not enough suitable brownfield land, either in the Green Belt or not, to meet the required housing needs across Walsall. As such, it is an acknowledged reality, that derelict urban land will not meet housing requirements and is not a significant element of the land supply.
3.13 The above analysis ratifies the Council’s decision to remove site WSA6 from the Green Belt, and this is fully supported by WDL.
3.14 In respect of the requirements set out in Policy GB1, criterion 2) a. requires the design of the development to include physical features that define the new Green Belt boundary in a readily recognisable and permanent way. WDL confirm that WSA6 can be developed in such a way. The canal already defines the boundary to the west and existing housing forms a boundary to the south and east. Therefore, it is only the northern boundary that will require consideration.
3.15 WDL does not support criterion 2) b. which requires compensatory improvements to the environmental quality, biodiversity and accessibility of remaining Green Belt to offset the impact of removing the land from the Green Belt. Compensatory improvements to environmental quality and biodiversity are covered by other policies within the Plan. Moreover, Green Belt is a planning designation and not one that is based on a site’s ecological value. It is also unclear how compensatory improvements to remaining Green Belt would be delivered. WDL therefore recommend this criterion should be removed from the policy.