Object

Representation ID: 45863

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

Comments on: Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt


Nature of comment: Objection


2.14 As discussed in comments in relation to Policy CSP1 the BCP acknowledges the requirement for Green Belt release to help meet development needs including (as currently formulated, noting that for reasons expressed elsewhere in these representations the extent of release required is disputed) to accommodate 7,720 homes and 48ha of employment land. For the reasons set out there it is considered that the failure of the Development Strategy policy to make this release explicit is a shortcoming of the Plan, that should be remedied.
DRAFT BLACK COUNTRY PLAN REGULATION 18 CONSULTATION 6

2.15 A similar issue arises in relation to Policy CSP3 which purports to set out the strategic approach for towns, neighbourhood areas and the Green Belt. It makes reference to, “a defensible green belt” but makes no reference to the contribution Green Belt release will make to accommodate development needs.

2.16 Where, as it does here, the strategy for a plan acknowledges, justifies and allows for Green Belt release for development, that should be expressed clearly and explicitly in strategic policies. That is absent from Policy CSP3, as it is from Policy CSP1. It is implicit through the reference to growth areas on the edge of the urban area but should be confirmed and expressed specifically in the wording of the policy.

2.17 The prospect of removing land from the Green Belt for allocations to meet development needs is not made explicit or quantified in the BCP Spatial Strategy as set out in Policies CSP1, CSP2, CSP3 and CSP4, nor the Key Spatial Diagram (Figure 2), which provide the overarching basis for the Plan’s proposals for growth and infrastructure improvements. It is not given specific mention in policy until Policy GB1 some 51 pages into the document. A reader of the BCP having reviewed the Development Strategy where it does not properly feature might reasonably be surprised to see it first attended to at this point.

2.18 To remedy this deficiency, in addition to the points raised elsewhere in relation to Policy CSP1, part 1b) of Policy CSP3 should make explicit reference to the extent to which Green Belt land will contribute to meeting development needs.