Object

Representation ID: 45864

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

Comments on: Policy GB1 – The Black Country Green Belt


Nature of comment: Objection


2.19 The supporting text to this policy reflects the national policy position that inappropriate development in the Green Belt should only be approved where “very special circumstances” can be demonstrated. However, part 3) of the policy is inconsistent with national policy. It states that the Green Belt, “will be preserved from inappropriate development” without acknowledging that inappropriate development is acceptable where very special circumstances apply.

2.20 To remedy this inconsistency, part 3) of this policy should be amended to confirm that inappropriate development in the Green Belt will be allowed where very special circumstances have been demonstrated.

SUMMARY


2.21 It is important that the BCP strategy recognises and responds to shortcomings in the

BCCS, rather than simply seeking to continue an overly urban and brownfield approach
DRAFT BLACK COUNTRY PLAN REGULATION 18 CONSULTATION 7

which has only been partly successful. This point is amplified in the context of the pandemic.

2.22 The commentary in the BCP includes points around comprehensively meeting need, providing range and choice, and delivering improvement and diversification in housing provision, which are of crucial importance, should be encouraged, and must be supported by the policies of the Plan. It also acknowledges the requirement for Green Belt release and exporting significant development requirements. These points are not properly reflected in Policy CSP1, nor in Policy CSP3. This should be remedied.

2.23 The wording of Policy GB1 should be amended to make it consistent with national policy around the demonstration of very special circumstances to justify inappropriate development in the Green Belt.