Policy CSP3 – Towns and Neighbourhood Areas and the green belt

Comment

Representation ID: 21488

Received: 11/10/2021

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

2.10. The evidence supporting the emerging Black Country Plan has identified that within the urban area is insufficient capacity to meet the Plan’s housing needs, even when taking into account potential opportunities for redevelopment of brownfield sites and increasing densities for new development. As a result, it has been concluded that there is sufficient justification to release land from the Green Belt through this Plan.

2.11. Whilst the need to release the Green Belt is not disputed given the scale of housing need and shortfall identified, it is a concern that the Authorities have proceeded to do so despite not exhausting all opportunities within the urban area. As a result, in order for the Plan to be justified and consistent with national policy regarding the Green Belt, the authorities need to demonstrate that all other reasonable options to meet its identified needs have been examined fully. This should include consideration of available sites within the urban area, such as the Land at Corbett Hospital, which represents underutilised land in a sustainable location within the urban area.

2.12. Therefore, in order for the Council to proceed with Green Belt release through this Plan and included within Policy CSP3, the Plan must be supported by a robust evidence base that justifies this approach. This should include identifying how all opportunities within the urban area such as the Land at the Corbett Hospital have been assessed, in order to ensure that the Plan accords with the Framework’s tests of soundness.

Object

Representation ID: 22119

Received: 21/09/2021

Respondent: Michael Garbett

I have ALREADY used your online portal
Main points of objection
1. new places at doctors for new residents - imposable
2. new places at schools for new children - imposable
3. extra traffic to Ridgeway, Holloway, Moden Hill
[details of wildlife redacted]
5. more green belt land to be lost
6. voters around this area will REMEMBER councillors names who vote for this plan for Veiwfield Crescent to be passed and who NOT TO VOTE FOR at next local elections.
STRONGLY OBJECTNG

Comment

Representation ID: 22188

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

We support the recognition in Policy CSP3 that exceptional circumstances exist to release land from the Green Belt and allocated it for development. It is clear that the housing requirement cannot be met without significant Green Belt release. Hoin response to Policy CSP2, it is our view that all suitable and sustainable sites within the Green Belt should be allocated for development given the significant housing shortfall. This includes the surplus land in the Club’s control.

Comment

Representation ID: 22232

Received: 11/10/2021

Respondent: Steve Crutchley

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

We support the recognition in Policy CSP3 that exceptional circumstances exist to release land from the Green Belt and allocated it for development. It is clear that the housing requirement cannot be met without significant Green Belt release. However, as detailed in response to Policy CSP2 above, it is our view that all suitable and sustainable sites within the Green Belt should be allocated for development given the significant housing shortfall. This includes our client’s site at Barr Beacon.

Support

Representation ID: 22371

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

In terms of Policies CSP2 and CSP3, RSL fully supports their approach to the distribution of strategic growth to the most sustainable locations which are accessible to jobs and a range of services and facilities, whilst providing housing choice, underpinning the areas’ economic competitiveness and supporting the working population.

Comment

Representation ID: 22506

Received: 11/10/2021

Respondent: Environment Agency

Policy CSP3 – Towns and Neighbourhood Areas and the green belt Neighbourhood
Growth

We suggest that the coordination of the phasing of Neighbourhood Growth Areas and other strategic developments, so that surplus bulk excavation spoil can be managed to offer ‘Mass-neutral’ construction of building platforms, and minimise the need for waste disposal. This would also help avoid stimulating illegal waste activity, especially where this can present a threat to the Green Belt or Amenity/Habitat areas. In the absence of a national Site Waste Management Plan regime, it would be positive to see a requirement for an equivalent system. The Environment Bill is also exploring how to reduce waste from the Construction sector.

Support

Representation ID: 23055

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

A network of new Neighbourhood Growth Areas are proposed to provide 6,792 dwellings in highly sustainable locations on the edge of the Urban Area. We support the allocation of St Philips’ site as part of strategic allocation WSA9.

Paragraph 3.48 states that it is important that “Neighbourhood Growth Areas are master-planned together, regardless of ownership” and phasing plans will be required to set out triggers for the provision of required infrastructure. St Philips are supportive of this requirement and are willing to work with adjacent willing landowners to bring Site WSA9 forward comprehensively.

Comment

Representation ID: 23220

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

For the reasons stated in our comments to CSP1, we would question whether the area outside of the Strategic Centres and Regeneration Corridors is capable of delivering 27,068 dwellings.

We welcome the identification of Neighbourhood Growth Areas (NGA) and the acknowledgement that Green Belt land needs to be released if the development needs identified are to be met.

Support

Representation ID: 23307

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We support the recognition in Policy CSP3 that exceptional circumstances exist to release land from the Green Belt and allocated it for development. It is clear that the housing requirement cannot be met without significant Green Belt release. However, even with Green Belt land release is is apparent that the full housing requirement cannot be met.

Object

Representation ID: 23369

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CSP3
CPRE objects to the inclusion of the Neighbourhood Growth Areas (NGAs) in Policy CSP3 (b). They are identified as ‘highly’ sustainable. There is no definition of what highly sustainable means, nor can there be when there is no specific test to be applied to this term. In fact, their locations are in some cases in the least accessible areas of the Black Country.
Sandhills is at the very edge of the Black Country, as is the proposed Aldridge site. Accessibility by bus is limited because of their locations.

Object

Representation ID: 23408

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

We support CPS3 (g) in regards to Green Belt. However, the key role identified in CPS3 of promoting urban renaissance is undermined by the significant number of sites identified in Green Belt, which also (as we say about Para 3.16) cannot be considered to be locations with defensible barriers.

It is important that the Plan supports on-going work to improve the accessibility of the local countryside, including tree plantings, habitat renewal and footpath improvements, also taking advantage of the network of canals.

We note that while the LUC Green Belt Study graded sites on their impact on Green Belt, these also can have a high landscape impact, especially in areas visible to large numbers of people, such as the sites adjacent to the Arboretum and between the canal and Longwood Lane.

Comment

Representation ID: 23409

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

While Green Belt primarily serves a strategic function, we also welcome the emphasis on ‘heritage, recreation, agricultural and nature conservation value.’ For many people this represents their local countryside. Moreover, it contains areas of particular value for amenity, such as the Walsall Arboretum, Barr Beacon and Seven Cornfields. The landscape characteristics of the Green Belt are also important along with key areas of nature conservation and geological importance such as Cuckoo’s Nook in Walsall.

Support

Representation ID: 23413

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

4.8 The strategic approach for the Towns and Neighbourhoods Areas and the Green Belt is set out within Draft Policy CSP3. We are supportive of this policy, in particular Part B (i) which states that the areas outside the Strategic Centres and Core Regeneration Areas will provide 27,068 new homes through a network of new Neighbourhood Growth Areas providing 6,792 homes, in highly sustainable locations on the edge of the Urban Area. As noted above, the part of the Site within Walsall extends to 38.9 hectares and has the potential to deliver 978 new homes in Walsall alongside the provision of a primary school, local services and facilities and open space in a sustainable location.

4.9 Part G of Draft Policy CSP3 advises that a defensible Green Belt will be provided to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents; with the landscape safeguarded and enhanced where possible for its heritage, recreation, agricultural and nature conservation value. We are supportive of this policy, which aligns with NPPF Paragraph 137 on preventing urban sprawl.

4.12 As part of the justification to Draft Policy CSP3 provided within the Draft Black Country Plan, Paragraph 3.48 emphasises that it is important that the individual sites (as defined in Draft Policy CSP3) in each of the Neighbourhood Growth Areas are masterplanned together, regardless of ownership, owing to the fact that new development will generate the need for new infrastructure. Where appropriate, masterplans may be prepared through a collaborative process involving the landowner/developer(s) and the relevant Black Country Authority. We are supportive of the Neighbourhood Growth Areas being masterplanned together (per allocation)

Comment

Representation ID: 23560

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

2.4 Policy CSP3 considers in more detail the areas outside the Strategic Centres, including the Neighbourhood Growth Areas.
2.5 The justification states that the purpose of the Neighbourhood Growth Areas is to support the delivery of a constant supply of new housing development, to be able to bring forward these sites quickly and for several sites to be developed simultaneously. The justification also recommends that such sites regardless of ownership are masterplannned as one site to ensure any new infrastructure is planned for. In the case of WAS6 an initial masterplan has already been produced for the whole site, attached as Appendix 2, it therefore can meet these requirements.
2.6 The reasoned justification states that Neighbourhood Growth areas should provide for at least 250 new homes, however WDL suggest that this figure is reduced to 200 new homes to reflect the ability of the sites to be well designed, reflect the local vernacular and allow for appropriate open space and ecological enhancement as per the proposed development of WAS6.

Object

Representation ID: 43854

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.11 Policy CSP3 subsequently deals with the Towns and Neighbourhood Growth Areas and the Green Belt. As set out above, the Neighbourhood Growth Areas in particular, along with the appropriateness of Green Belt release to deliver them, should be given equal status with the development priorities set out in CSP2. This would both support the Spatial Strategy of the Plan but also make clear that it is a fundamental element of the sustainable approach to meeting housing and employment needs.
4.12 Amongst other things, Policy CSP3 refers to providing 'strong and seamless' links to regenerated areas in the Core Regeneration Areas and Strategic Centres. Whilst it is appreciated this is a high level strategic policy, it is difficult to envisage how these linkages could be delivered in practical terms, given the geographical distances separating these areas.
4.13 In addition, Policy CSP3 ought to refer to the sustainable advantages resulting from the new Neighbourhood Growth Areas providing choice in the housing market. This is particularly important given the continued reliance on brownfield land as is set out in the current Development Plan. Reference to the need to widen the identification of sites, to not just rely solely on previously developed employment land, is an important facet of the Local Plan strategy and should be reflected in any policy relating to Neighbourhood Growth Areas and the release of Green Belt land.
4.14 Policy CSP3 and its supporting text should also provide greater justification for the benefits of bringing forward Green Belt release, which is based not only on evidence supporting specific release of the sites identified, but also by widening the availability of housing land in differing locations to that traditionally being promoted in the Black Country. Similarly, the supporting justification for Policy CSP3 refers to the benefits of delivering a constant supply of new housing development. This again points to the need to have a range of sites in differing locations, some of which are not reliant on remediating poor quality and degraded brownfield land.

Support

Representation ID: 43910

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.14 Policy CSP3 1 recognises the importance of providing a mix of good quality residential areas where people choose to live and recognising the inherent sustainability of directing new development through the allocation of a network of new NGAs. This is why NGAs are crucial to the success of this plan – as traditionally certain types and sizes of housing are more readily delivered on urban brownfield sites due to factors such as viability and density. NGAs offer the opportunity to deliver a wider range of housing types to meet the area’s identified needs.
3.15 Barratt support that comprehensive masterplanning will be important to the success of the NGA’s. Paragraph 3.48 states that NGA’s should be master-planned together regardless of ownership. Land at Pennwood is under single ownership, enabling Barratt to take a streamlined master-planning process. In addition, it is stated that NGA’s generate need for new infrastructure, this is supported by Barratt as this provides an opportunity to deliver infrastructure for existing and new homes.
3.16 The allocation of NGAs allows for greater public access to the countryside which urban sites are not able to, so it is right parts e) and g) of the draft policy require integrated and where possible continuous networks of green infrastructure and easy access to the countryside. This would not be possible without NGAs and the need for this infrastructure is a central theme to the illustrative masterplan for land at Pennwood. As we will go onto demonstrate, land at Pennwood is a potential NGA offering significant benefits which can assist the Black Country authorities with reducing their unmet need further.

Support

Representation ID: 43928

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

CSP3 (towns and neighbourhood areas and the Green Belt)
3.13 Policy CSP3 1) recognises the importance of providing a mix of good quality residential
areas where people choose to live and recognising the inherent sustainability of
directing new development through the allocation of a network of new NGAs. This is
why NGAs are crucial to the success of this plan – as traditionally certain types and
sizes of housing are more readily delivered on urban brownfield sites due to factors
such as viability and density. NGAs offer the opportunity to deliver a wider range of
housing types to meet the area’s identified needs.




8

3.14 IM Land agree that it will be important to the success of the NGAs for the parcels of
land to be comprehensively master planned to maximise the efficiency, sustainability,
and integration across the sites, and this has been central to the development of the
illustrative masterplan for land at Queslett Road (Site Ref: WAH234) to date.
3.15 The allocation of NGAs allows for greater public access to the countryside which urban
sites are not able to, so it is right parts e) and g) of the draft policy require integrated
and where possible continuous networks of green infrastructure and easy access to the
countryside. This would not be possible without NGAs and the need for this
infrastructure is a central theme to the illustrative masterplan for IM Land’s site at
Queslett Road, Walsall.
3.16 This is set out at section 5 of the Vision Document enclosed at Appendix 1, which
identifies the key design principles which have been incorporated in the development
of the illustrative masterplan for the site. This includes the provision of a defensible
Green Belt boundary to the north.
3.17 On point e), as we discuss further at draft policy DEL1, it will be essential that the
Councils’ evidence base appropriately identifies necessary infrastructure to facilitate
and mitigate the proposed development to allow for NGAs to be appropriately phased
and delivered alongside any necessary infrastructure.

Comment

Representation ID: 44900

Received: 10/10/2021

Respondent: Cannock Chase Council

Sub para e) and g) paragraph 3.49 should recognise that some of the impacts or
opportunities may cross administrative boundaries.

Comment

Representation ID: 44918

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CSP3 - Towns and Neighbourhood
Areas and the Green Belt

3.1Taylor Wimpey strongly supports the Neighbourhood Growth Area that includes Strategic Allocation WSA.2 and will contribute to meeting the housing needs of the BCP.

3.2 However, for the reasons set out in these representations it is considered that additional housing land in sustainable locations on the edge of the urban area needs to be identified to meet housing need and this will require the release of additional Green Belt land. For the reasons set out in the previous sections of the report, the provision of 27,068 new homes is not justified as it fails to meet the minimum number of homes required. The figure should be significantly more.

3.3 In order to meet this need and support the delivery of sustainable development Taylor Wimpey considers that Land at Chester Road, Streetly and Land at Clent View Road Stourbridge should be released from the Green Belt and allocated for residential development. We provide further detail and the deliverability, sustainability and masterplan aspirations for these sites in these
representations.

Comment

Representation ID: 44964

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

3.0 Policy CSP3 - Towns and Neighbourhood
Areas and the Green Belt
3.1 Taylor Wimpey strongly supports the Neighbourhood Growth Area that includes Strategic
Allocation WSA.2 and will contribute to meeting the housing needs of the BCP.
3.2 However, for the reasons set out in these representations it is considered that additional
housing land in sustainable locations on the edge of the urban area needs to be identified to
meet housing need and this will require the release of additional Green Belt land. For the
reasons set out in the previous sections of the report, the provision of 27,068 new homes is not
justified as it fails to meet the minimum number of homes required. The figure should be
significantly more.
3.3 In order to meet this need and support the delivery of sustainable development Taylor Wimpey
considers that Land at Chester Road, Streetly and Land at Clent View Road Stourbridge should
be released from the Green Belt and allocated for residential development. We provide further
detail and the deliverability, sustainability and masterplan aspirations for these sites in these
representations.

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.

Comment

Representation ID: 47032

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Policy CSP3 1 recognises the importance of providing a mix of good quality residential areas where people choose to live and recognising the inherent sustainability of directing new development through the allocation of a network of new NGAs. This is why NGAs are crucial to the success of this plan – as traditionally certain types and sizes of housing are more readily delivered on urban brownfield sites due to factors

such as viability and density. Indeed table 2.2 of the Turley Technical Review of Housing Need and Supply in the Black Country (October 2021) (Appendix 7) demonstrates that, based on analysis of the Council’s housing need assessment and Valuation Office Agency data, two thirds (66%) of the overall needs for housing in the Black Country relates to houses, with a much smaller need for flats (27%) or bungalows (6%). In response NGAs offer the opportunity to deliver a wider range of housing types to meet the area’s identified needs.

HIMOR agrees that it will be important to the success of the NGAs for them to be masterplanned comprehensively. HIMOR own all the land promoted at Birmingham Road, Great Barr, so can deliver it comprehensively.

The allocation of NGAs allows for greater public access to the countryside which urban sites are not able to, so it is right parts e) and g) of the draft policy require integrated and where possible continuous networks of green infrastructure and easy access to the countryside. This would not be possible without NGAs and the need for this infrastructure is a central theme to the illustrative masterplan for the site.

This is set out at section 4 of the Vision Document enclosed at Appendix 6, which identifies the key design principles for each masterplan option. This includes the provision of a defensible Green Belt boundary to the north / west.

On point e), it will be essential that the Councils’ evidence base appropriately identifies necessary infrastructure to facilitate and mitigate the proposed development to allow for NGAs to be appropriately phased and delivered alongside any necessary infrastructure.