Comment
Black Country Core Strategy Issue and Option Report
Representation ID: 2992
Received: 08/09/2017
Respondent: Hallam Land Management
Agent: Turley Associates
Any site selection criteria should reflect the NPPF, recognising that planning should actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable. For instance, we consider that Great Wyrley, which is located to the immediate north of the Black Country Authorities plan boundary, is a suitable settlement to direct additional housing growth towards. This is largely attributable to the excellent transport services in the form of Landywood railway station and an extensive local bus network. In addition, the settlement is located within close proximity of employment and leisure opportunities at Longford and Bridgtown, which can be accessed through sustainable transport modes. Furthermore, there are a number of education establishments within the Great Wyrley area including a secondary school and three primary schools. The BCCS Review should also not make assumptions that new development will have major impacts on Green Belt purposes and environmental assets. Firstly, any site's performance against the Green Belt purposes is separate to any site selection process. The Green Belt Review is a separate exercise to determining the sustainability of a site. Secondly, potential sites in the Green Belt can have many environmental benefits, including delivering significant public open space (it is widely recognised the Black Country Green Belt is largely inaccessible), as well as biodiversity enhancements. Therefore, it is considered that land at Jones Lane offers a suitable opportunity for residential development and it will be critical for the Black Country Authorities to work with neighbouring authorities, such as SSDC, to identify sustainable locations for release from the Green Belt.
The Green Belt Review should be a robust assessment, undertaken in accordance with national planning practice guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development and not including land which it is unnecessary to be kept permanently open.
As part of this the methodology for the Green Belt Review should be published for consultation prior to work commencing. This will be important to ensure the Review is robust and has the support of the development industry.
The I&O Report indicates the GBHMA Strategic Growth Study (renamed the 'Strategic Locations Study') will "inform and provide the basis" for the Black Country Green Belt Review.
The methodology for the Strategic Locations Study, made available in July 2017, is very broad; referring to the Green Belt will be assessed in 'five sections'. If the study is too broad, and the strategic areas identified too general, it will not form a sound basis for the Black Country Green Belt Review to conclude which land is suitable for Green Belt release.
The Green Belt Review should be carried out in conjunction with assessing sustainable locations for residential development in neighbouring authorities such as SSDC, which falls within the same strategic housing market area and maintains strong economic links.