Object

Representation ID: 43854

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.11 Policy CSP3 subsequently deals with the Towns and Neighbourhood Growth Areas and the Green Belt. As set out above, the Neighbourhood Growth Areas in particular, along with the appropriateness of Green Belt release to deliver them, should be given equal status with the development priorities set out in CSP2. This would both support the Spatial Strategy of the Plan but also make clear that it is a fundamental element of the sustainable approach to meeting housing and employment needs.
4.12 Amongst other things, Policy CSP3 refers to providing 'strong and seamless' links to regenerated areas in the Core Regeneration Areas and Strategic Centres. Whilst it is appreciated this is a high level strategic policy, it is difficult to envisage how these linkages could be delivered in practical terms, given the geographical distances separating these areas.
4.13 In addition, Policy CSP3 ought to refer to the sustainable advantages resulting from the new Neighbourhood Growth Areas providing choice in the housing market. This is particularly important given the continued reliance on brownfield land as is set out in the current Development Plan. Reference to the need to widen the identification of sites, to not just rely solely on previously developed employment land, is an important facet of the Local Plan strategy and should be reflected in any policy relating to Neighbourhood Growth Areas and the release of Green Belt land.
4.14 Policy CSP3 and its supporting text should also provide greater justification for the benefits of bringing forward Green Belt release, which is based not only on evidence supporting specific release of the sites identified, but also by widening the availability of housing land in differing locations to that traditionally being promoted in the Black Country. Similarly, the supporting justification for Policy CSP3 refers to the benefits of delivering a constant supply of new housing development. This again points to the need to have a range of sites in differing locations, some of which are not reliant on remediating poor quality and degraded brownfield land.