Vision, Principles, Spatial Objectives and Strategic Policies

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Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 1261

Received: 08/09/2017

Respondent: Stafford Borough Council

Representation Summary:

As Stafford Borough is a neighbouring authority to South Staffordshire District and Cannock Chase District a number of the Spatial Options within the Report could have development and infrastructure implications for the Borough, although it is worth noting that Stafford Borough is not within the Greater Birmingham and Black Country Housing Market Area, nor the Greater Birmingham & Solihull LEP or Black Country LEP areas. In particular the Habitat Regulations Assessment of future housing growth in the Black Country may need to be addressed in order to provide mitigation measures for the Cannock Chase Special Area of Conservation together with implications for the wider Cannock Chase Area of Outstanding Natural Beauty.

Full text:

Thank you for the opportunity to respond to the Black Country Core Strategy Issues and Options Report.

As Stafford Borough is a neighbouring authority to South Staffordshire District and Cannock Chase District a number of the Spatial Options within the Report could have development and infrastructure implications for the Borough, although it is worth noting that Stafford Borough is not within the Greater Birmingham and Black Country Housing Market Area, nor the Greater Birmingham & Solihull LEP or Black Country LEP areas. In particular the Habitat Regulations Assessment of future housing growth in the Black Country may need to be addressed in order to provide mitigation measures for the Cannock Chase Special Area of Conservation together with implications for the wider Cannock Chase Area of Outstanding Natural Beauty.

Based on the Strategic Challenges and Opportunities, the Borough Council is generally supportive of the vision, principles, spatial objectives and strategic policies within the Issues and Options document. However it is important to ensure that a balanced approach takes place between the development requirements of neighbouring areas and the focus for new infrastructure, housing and employment growth within the Black Country area. Clearly it is important that the local population needs within the Black Country are accommodated by the delivery of new developments to reduce out-migration and pressure on the strategic transport network.

In terms of the approach for accommodating growth it is noted that the Black Country are continuing the role of the Growth Network and Regeneration Corridors from the adopted Core Strategy. However this will require the delivery of brownfield sites across the Black Country which experience a range of infrastructure, historic contamination and viability constraints impeding the level of development achievable. Therefore it would appear that options associated with Stage 2 including Green Belt release within the Black Country, either through rounding off or Sustainable Urban Extensions will be required to meet housing and employment development requirements. The implications of these Stage 2 options could be a significant net outflow of residents and economic activity away from the Black Country's Strategic Centres towards other areas, putting additional pressure on transport links.

It is noted that within the Spatial Options is a section on 'meeting housing needs outside the Black Country', firstly in neighbouring authorities or secondly exported outside of the Housing Market Area. Notwithstanding the impact on the Black Country through the loss of economically active population, both of these 'export' options could have implications for Stafford Borough. If additional housing growth is accepted by South Staffordshire District there is the potential for non Green Belt areas south of Stafford, but in South Staffordshire District, being considered through a Local Plan Review process leading to infrastructure pressures on the County Town of Stafford. A recent example of this scenario has been highlighted by a planning application for 200 new homes immediately adjacent to Wildwood, Stafford but within South Staffordshire District. From the employment perspective the proposed Strategic Rail Freight Interchange development in South Staffordshire District is being promoted in order to provide for the Black Country's unmet logistic needs, which demonstrates the challenge of delivering suitable sites within the Black Country area and the outward movement of economically active people.

The adopted Plan for Stafford Borough (June 2014) focuses the majority of new housing and employment provision at Stafford Town, without releasing Green Belt areas, and a number of significant development sites are now being delivered. As you may be aware the Borough Council has recently initiated a Local Plan Review to set out the future development strategy beyond the adopted Plan period of 2031. Therefore if it is considered necessary to deliver development in other areas the Borough Council would welcome an opportunity to discuss the implications of this approach in more detail, to ensure the infrastructure implications are considered in balance with achieving housing and employment needs across a wider area.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Representation ID: 2304

Received: 13/09/2017

Respondent: Michael Beaumont

Representation Summary:

Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed in the representation provide.

Full text:

I write regarding the proposed Review of the Black Country Core Strategy 2017 as I strongly object to to Housing and Industrial Development in the Green Belt.

I oppose all development on designated Green Belt land, but my experience, and intimate knowledge, relates primarily to the Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'.

You do not ask for a detailed representation, but I list some pertinent issues:

1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.

2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.

3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.

4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.

6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.

7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.

8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

Attachments: