Comment

Representation ID: 47033

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

As identified at paragraphs 3.14-17 and 3.75, the draft BCP has identified exceptional circumstances for the removal of land from the Black Country Green Belt. The Council summarise their exceptional circumstances case further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).

Following national planning policy, the authorities are therefore justified in proposing to amend the Green Belt boundary through the associated policies map. Indeed further land will be necessary to be released from the Green Belt if the Councils are to deliver the scale of supply proposed in the plan, let alone reducing the overall shortfall being exported to neighbouring authorities (as we discuss further in response to draft policy HOU1 below).

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.

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.

NPPF paragraphs 140 and 143 are clear that Green Belt boundaries should be permanent and endure beyond the plan period. Where necessary safeguarded land should be identified when defining Green Belt boundaries in order to meet longer term needs. Despite this the draft BCP makes no attempt to safeguard land for its needs beyond 2039. This is particularly relevant for authorities such as Sandwell, safeguarded land can also contribute to maintaining the area’s housing land supply. Indeed Sandwell has consistently not been able to demonstrate a five year housing land supply2 in recent years given under delivery on brownfield land, a strategy it proposes to continue through the BCP. The plan should therefore identify safeguarded land to satisfy national planning policy.