Support

Representation ID: 43930

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy GB1: The Black Country Green Belt
3.22 As identified at paragraph3.14-17, 3.75, the draft BCP has identified exceptional
circumstances for the removal of land from the Black Country Green Belt such as land
at Queslett Road, Walsall (draft policy WSA8), in order to meet housing and
employment land needs. The Council summarise their exceptional circumstances case
further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).
3.23 Following national planning policy, the authorities are therefore justified in proposing
to amend the Green Belt boundary through the associated policies map.
3.24 The policy however could do with refinement. As currently drafted part 2 applies to
sites to be removed from the Green Belt (so at the point the plan is adopted will no
longer be in the Green Belt), and the balance of the policy is to be applied to land
remaining in the Green Belt. The policy would benefit from part 2 being deleted to
provide greater clarity. Part 2)a. (the need for a defensible Green Belt boundary) is
covered in draft policy CSP3, it may be that policy should also include reference to part
2)b. and the need for compensatory measures. Another solution could be making
Part2)b. part of any site specific allocation for sites removed from the Green Belt.
3.25 In evolving the next version of the plan the Councils should provide further information
in a single document (perhaps as a topic paper) summarising the Green Belt
compensatory measures on a Black Country wide basis to ensure there is clarity on
how NPPF paragraph 142 is satisfied.