Comment

Representation ID: 23602

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

9.5
Chapter 13 — Sub-Areas and Site Allocations
Need for additional site allocations
As set out in our representations to Policies CSPI, HOUI and CBI, there is a need to allocate
additional sites as part of an increased housing requirement to meet local housing need in full.
and to address the deficiencies in relation to housing land supply. Section 10 of this statement
proposes the allocation of the land at Greenwood Road, Aldridge which would contribute to
addressing the identified shortfall.
Site selection methodology
Our concerns with the site selection methodology relate to the application Of the methodology.
both generally and specifically in relation to our client's land. Under stage 3 of the methodology
for Green Belt sites, the criteria for filtering our sites include:
• Where development would cause very high harm to remaining Green Belt and
moderate-high or high harm to landscape sensitivity
With one or more significant planning constraints which cannot be mitigated
We have the following concerns with the approach and how it has been applied.
Firstly, the application of the methodology in the Site Assessments has significantly over-stated
harm in these categories, and/or fails to have regard to potential mitigation. The result is that
most Green Belt sites are assessed as causing very high harm to remaining Green Belt and
moderate-high or high harm to landscape sensitivity, and they are also identified as having other
insurmountable planning constraints. The assessments are unduly negative, and appear to be
part of a wider approach of over-stating harm to justify the failure to meet objectively assessed
needs within the Black Country.
Secondly, the assessments Of Green Belt and landscape sensitivity rely heavily upon the
assessments of wider land in the Green Belt Study and the Landscape Sensitivity Assessment (LSA).
However, these assess much wider parcels Of land and were not based on specific proposals.
Furthermore, at best they only provide a starting point of landscape sensitivity or Green Belt
contribution to a wider area. The findings Of those assessments cannot be applied to the
individual site assessments in the way that they have, as the sites put forward may be lesser in 9.6
9.7
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Thirdly, the BCA has applied the methodology inconsistently. For example, in Walsall:
• Several sites are proposed for allocation despite being categorised as causing very high
harm to remaining Green Belt and moderate-high or high harm to landscape sensitivity,
for example the land at (South Of) Stonnall Road, Aldridge (ref: SA-0309-WAL) and the .
For other sites this results in automatic filtering out.
• In some instances. the presence Of a SLINC across the entirety Of a site is not a constraint
to allocation, for example Oxley Park Golf Club (ref: WOH261 WTNA) and land off Sutton
Road, Longwood Lane, Walsall (ref: WHA231 / policy WSA.6). However, in other
instances the assessment claims that "mitigation and or compensation would also be
significant barriers to development" (see Land south Of Bosty Lane, Aldridge, ref: SA-
0047-WAL).
We highlight specific issues with the application of the site assessments in relation to our client's 10.