Comment

Representation ID: 23598

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

5.5
Policy GB1 - The Black Country Green Belt
The BCP identifies at paragraph 3.15 that exceptional circumstances exist to justify changes to
the Green Belt boundaries. However, the amount of Green Belt release proposed is contested.
TO summarise Our representations on the housing policies:
• The should seek to meet identified development needs in full. There is no justification
for reducing the housing and employment land requirements.
• The BC? should also seek to meet the unmet needs of Birmingham.
• The housing land supply position has been over-stated.
The result is that additional viable sites need to be allocated to address the identified shortfalls in
land supply. The supply in the urban area has been exhausted, to the extent that it has been
significantly over-estimated. The only logical solution is for the plan to release further land from
the Green Belt.
Such an approach would be entirely consistent with the Framework. Paragraph 142 requires that
when drawing up or reviewing Green Belt boundaries, local planning authorities should take
account of the need to promote sustainable patterns of development. It also requires local
planning authorities to consider the consequences for sustainable development Of channelling
development towards urban areas inside the Green Belt boundary, towards towns and villages
inset within the Green Belt or towards locations beyond the outer Green Belt boundary. In the
case of the Black Country, there would be very significant adverse social and economic
consequences Of not providing sufficient land to meet the Objectively assessed needs.
Our client proposes an omission site for development in Section 10 of this statement. The land
should be released from the Green Belt and allocated for a residential or mixed-use
development.
Safeguarded land
Paragraph 137 of the Framework identifies that "the essential characteristics of Green Belts are
their openness and their permanence'
5.9
Paragraph
requires strategic policies to "estab
the need for any changes to Green Belt
boundaries, hqvinq reqqrq to their intended oermanence in the long term. so thev can endure
bevond the o/an oeriod"
Paragraph 143 states that when defining Green Belt boundaries, plans should (amongst other
requirements):
"c) where necessarv. identifv areas of safeguarded land between the urban area and
the Green Belt. in order to meet longer-term develooment needs stretching well bevond
the plan period'
e) be able to demonstrate that Green Belt boundaries will not need to be altered at the
end of the olan period" (our emphasis)
Therefore, national policy is clear on the need to ensure that Green Belt boundaries will not need
to be altered at the end Of the plan period (currently 2039). This is a critical aspect to achieving
the intended permanence in the long term. The appropriate mechanism for achieving this
through the provision of safeguarded land. However, the BC? does not propose to designate
any safeguarded land. Other sources of land for future development needs beyond the Green
Belt are extremely limited.
There is no justification for not providing sufficient safeguarded land in the Black Country. The
permanence of the Green Belt would not be maintained, as it would be inevitable that Green
Belt boundaries will need to be reviewed again before the end of the plan period to meet needs
beyond 2039.
5.10 How much safeguarded land is needed in practice was considered in detail at the Cheshire East
Local Plan Strategy examination. In that case it was determined that sufficient safeguarded land
should be made available for another full plan period following the end Of the current plan
period. Paragraph 99 of the Cheshire East Local Plan Strategy Inspector's report states:
"The overall amount of proposed Safeguarded Land is intended to meet
longer-term development needs stretching well beyond the end of the current
plan period; in fact, taking account of other sources of land, it should be
sufficient for another full 15-year period beyond 2030, so that the Green Belt
boundary defined in the CELPS-PC will not need to be amended until at least
5.12
The Further Interim Views of the Inspector (Appendix 2 to the Inspector's report) refer to this
conclusion being based upon examples Of best practice from around the country. Paragraph
50 of the Further Interim Views states:
"There is little guidance available on defining the appropriate amount of
Safeguarded Land, but after considering best practice, an approach which
considers a IO- 15 year period beyond the end of the current plan period seems
reasonable in the context Of Cheshire East: it strikes a reasonable balance
between avoiding the need to review the Green Belt at the end of the current
plan period and avoiding unnecessary releases of Green Belt land at this time. "
Therefore, in summary, sufficient safeguarded land should be provided to ensure that the current
requirement could be carried forward to the next 15-year plan period without the need for Green
Belt release. In practice the minimum requirement is to provide a similar amount Of safeguard
land to the amount of Green Belt being released for development in this plan period. Ideally
more should be provided, to allow flexibility for potential higher growth in the future and to
increase the permanence of the Green Belt.