Policy GB1 – The Black Country Green Belt

Object

Representation ID: 22117

Received: 01/10/2021

Respondent: Antony Cockitt

Also I wish to say I am oppressed to any development of this valuable green belt in the future.

Support

Representation ID: 22174

Received: 11/10/2021

Respondent: Ms & Mr Jill & I Stevens & Huskisson

Number of people: 2

Agent: JVH Town Planning Consultants Ltd (rep Walton Homes Ltd)

Policy GB1 Green Belt

The proposed new green belt boundaries are shown on the proposals maps. We support the new defined green belt boundaries and the drawing of the green belt boundary around WAH 255 at Wood Lane Streetly.
The new boundary as defined on the proposals map is a suitable long term boundary defined by clear physical features.
Attached to this submission is a masterplan concept that demonstrates how the site can be developed and maintain the integrity of the new green belt boundaries. The Woodland Trust woodland land to the north of the site is a suitable recipient for compensatory improvements as required by 2b of the above policy and the NPPF at paragraph 142.

Comment

Representation ID: 22190

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. Indeed, it is imperative if the housing requirement is to be met. Policy GB1 advises Green Belt release sites will need to include physical features that define the Green Belt boundary and that compensatory improvements to the environmental quality, biodiversity and accessibility will be required to offset the impact of removing the land from the Green Belt.

As detailed in these representations the surplus land in the Club’s control fulfils this brief. It has strong defensible Green Belt boundaries. The site can be developed to preserve and enhance biological interesting features, such as hedgerows, with built development located on the paddock land. Public access will be created to Green Belt land that it is currently inaccessible.

Support

Representation ID: 22230

Received: 11/10/2021

Respondent: Steve Crutchley

Policy GB1 – The Black Country Green Belt

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. Indeed, it is imperative if the housing requirement is to be met. Policy GB1 advises Green Belt release sites will need to include physical features that define the Green Belt boundary and that compensatory improvements to the environmental quality, biodiversity and accessibility will be required to offset the impact of removing the land from the Green Belt.

Support

Representation ID: 22269

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Green Belt

3.12 As noted above at paragraphs 3.4, 3.5 and 3.6, we agree with Black Country Authorities’
general approach to the Green Belt and agree this approach is reflected in detail at draft Policy GB1 (The Black Country Green Belt).

3.13 Paragraph 142 of the NPPF sets out that:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”.

3.14 Through the preparation of this Plan, the Black Country Authorities have demonstrated
exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. Part 2 of draft Policy GB1 provides the policy requirement for new development to include physical features that define the new green belt boundary in a readily recognisable and permanent way compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from the green belt, in accordance with paragraphs 142 and 143 of the NPPF.

3.15 Part 3 of draft Policy GB1 sets out that the Green Belt will be preserved from inappropriate
development so that it continues to maintain its openness and serve its key functions, which is in line with the requirements of paragraph 147 of the NPPF.

Comment

Representation ID: 22300

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

Draft Policy GB1 (The Black Country Green Belt)
2.98 Draft Policy GB1 is unsound as it does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for housing.
2.99 As set out in its response to Draft Policies CSP1 and HOU1, Investin objects to the BCP on the basis that it seeks to provide only 47,837 dwellings in the plan period, leaving a significant shortfall of 28,239 dwellings. The BCP has failed to provide sufficient land to meet the minimum housing needs, as per NPPF paragraph 11(b), and will need to ensure that additional housing land is provided through further Green Belt release.
2.100 As earlier indicated, there are several shortcomings in the Black Country Green Belt Study: Stage 1 and 2 Report (Land Use Consultants, September 2019), and it is considered that the omission of several sites submitted through the Call for Sites is unsound on the basis that the Green Belt Study has applied an inconsistent and flawed approach in the assessment of sites submitted through the Call for Sites.
2.101 This is because the Stage 1 Contribution Assessment has been prepared at such a strategic level as to render its findings on the extent of the potential harm to the Green Belt purposes, as a result of development, questionable when applied to smaller individual potential development sites adjacent to the urban areas.
2.102 By way of example, the geographical scale of some parcels is extremely vast (e.g. between 100-500 ha) whilst others are of a much smaller scale (e.g. between 1-50 ha).
2.103 This varying scale will undoubtedly have a negative and inconsistent impact on the scoring identified in the Green Belt purposes ratings for each parcel, as set out at Table 5.1 within the Stage 1 Findings (page 44).
2.104 Investin considers the larger Green Belt parcels are capable of logical sub-division based on defensible boundaries. It also recommends that all of the parcels should be of a similar size and that care should be taken to ensure that a consistent approach is taken in respect of the assessment of different parts of the Black Country. This could be achieved through the subdivision of some parcels to ensure that they are all more equally sized. Indeed, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale.
2.105 The approach taken in respect of generating the land parcels for assessment is set out at paragraph 4.29:
“By combining the lines marking variations in contribution to Green Belt purposes, a list of land parcels was generated, each of which has a reference number and a rating for contribution to each purpose. The parcels are the product of the assessment rather than a precursor to it. The reasoning behind this approach was to draw out variations in contribution to inform the site-specific assessments undertaken at Stage 2, avoiding broad variations in contribution within prematurely and more arbitrarily defined parcels. Avoiding significant variations in contribution within defined parcels prevents the need for ratings to be generalised to reflect the strongest or average level of contribution within a defined area.”
2.106 Whilst the Stage 2 Harm Assessments consider the sub-parcels at a smaller scale, it is noted that not only are some of these sub-parcels still at a significantly large and inconsistent scale (some extend to <10ha whilst others are >100 ha), but that the assessment of harm is effectively an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
Land South of Little Aston Road, Aldridge, Walsall
2.107 This issue is evident through the assessment of land south of Little Aston Road, Aldridge, Walsall (Call for Sites ID 332).
2.108 Investin is promoting land south of Little Aston Road, Aldridge, Walsall and submitted the site accordingly through the Call for Sites process. A Vision Document is submitted alongside these representations which demonstrates how up to 170 dwellings could be delivered at the site.
Stage 1 Contribution Assessment
2.109 Within the Stage 1 Contribution Assessment, the site forms part of Parcel Reference B93 (East of Walsall) with a parcel size of 1768.3 ha, as illustrated below.
Figure 2.4 Parcel B93 at Stage 1 Contribution Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
Figure 2.5 Parcel B93 at Stage 1 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.110 As can be seen, the parcel boundary incorporates a vast swathe of the east Walsall. Ultimately, it is considered that 1768.3 ha is too large of a geographic area such that meaningful conclusions can be drawn as to the Green Belt Purposes of sub-parcels within the wider parcel. By way of comparison, a large proportion of other parcels within Walsall have been drawn significantly smaller at between 1-50 ha.
2.111 As earlier established, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale. This inconsistent approach has therefore unfairly resulted in parcel B93 being assessed as performing generally strong against the Green Belt purposes:
Table 2.5 Performance of parcel B93 against Green Belt purposes [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.112 This inaccurate scoring has consequently followed through into the Stage 2 Harm Assessment.
Stage 2 Harm Assessment
2.113 Within the Stage 2 Harm Assessment, the site form parts of Sub-Parcel Reference B93D (Little Aston Road) with a parcel size of 96.8 ha, as illustrated below.
Figure 2.6 Parcel B93D at Stage 2 Harm Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
Figure 2.7 Parcel B93D at Stage 2 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
2.114 Whilst the Stage 2 Harm Assessments has considered the sub-parcel at a smaller scale, it is not broadly aligned with promoted site reference #173 and fails to illustrate promoted site reference #332. Additionally, the assessment of harm of ‘Very High’ has effectively been derived from an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
2.115 This is a fundamental flaw in the methodology of the Green Belt Study which results in a failure to account for a more localised assessment of how sub-parcels and promoted sites perform against the Green Belt purposes. As a result of this shortcoming, the land at Little Aston Road, Aldridge, which would have otherwise been selected for Green Belt removal, has been artificially omitted.
2.116 The Green Belt Study methodology should be reviewed and amended to address this issue, and the land at Little Aston Road should be proposed for removal from the Green Belt and allocated for housing accordingly.

Support

Representation ID: 22346

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

In light of the above, [representation on Policy CSP1] it is inevitable that Green Belt land in the Black Country will need to be released to help the authorities meet their housing needs over the Plan period. It is evident that the BCAs have examined fully all other reasonable options for meeting their identified need for development and have concluded that they could not achieve this alone by adopting a strategy that accords with the criteria set out in paragraph 141 of the NPPF. In our view, this demonstrates that the exceptional circumstances do exist to justify the BCAs making changes to existing Green Belt boundaries.

We support the BCA’s acknowledgement that the site at Aldridge Road is considered appropriate for the release from the Green Belt, as evidenced by Policy HOU1. The site is well contained, with well-defined, defensible boundaries on all sides (i.e. Aldridge Road to the north, Calderfields Golf Club to the east, Walsall Arboretum to the south and residential land uses to the west). These features provide a visual separation from open land surrounding the site, meaning that its release would not result in the unrestricted sprawl of large built-up areas. The Golf Club to the east, in particular, is a key element of the separation between the site and Streetly to the east. As this would mean a strong gap is maintained between the site and the built-up areas of Aldridge and Streetly, the removal of the site from the Green Belt would not result in the merging of neighbouring towns.

Support

Representation ID: 22372

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

RSL also fully support the approach adopted by Policy GB1 – The Black Country Green Belt. Part 2 of the policy confirms that sites are to be removed from the Green Belt and allocated to meet housing, employment, or other needs. It continues by stating such proposals will be designed to ensure new green belt boundaries are defined in a readily recognisable and permanent way, and that compensatory improvements of the remaining green belt will be secured to offset the impact.

The extensive and up to date evidence base which has informed the Plan-making process to date has fully demonstrated that the exceptional circumstances necessary to amend Green Belt boundaries exist. This is most evident in view of the fact that even with the removal of some, lower performing and less sensitive Green Belt land, there remains a significant shortfall in both the future housing and employment land requirements over the plan period.

Paragraph 140 of the NPPF confirms that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 141 continues that before concluding that exceptional circumstances exist, the relevant authority should demonstrate it has examined fully all other reasonable options for meeting its identified needs, including making the best use of brownfield land, optimising densities in towns and cities and other locations well served by public transport, and informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need.

The BCA’s evidence base includes the Urban Capacity Review Update 2021, a recent update to on-going studies to assess and quantify the potential capacity of land within urban areas, including brownfield land. The Review confirms that capacity within the urban area could deliver 39,257 homes and 205 hectares of employment land to 2039. This update has also incorporated assumptions about increasing densities where local character allows. This clearly demonstrates that all other reasonable options for accommodating the full housing and employment needs within the Plan area have been investigated, prior to considering Green Belt release.

On the basis of an identified shortfall of 36,819 homes and 360 hectares of employment land, Paragraph 3.24 of the BCP confirms that the BCA have worked constructively with neighbouring authorities to explore the ability for these shortfalls to be located elsewhere outside the Plan area. Notwithstanding, it is clear that whilst this will be an on-going exercise, the BCA recognise that this may only address a proportion of the shortfalls. Whilst the exact level of BCA unmet need is not confirmed within the BCP and will no doubt continue to be an evolving issue, the accompanying BCP Summary document indicates that at present, offers from neighbouring authorities suggest that between 8,000 to 9,500 homes and 102-173 hectares of employment land could be accommodated, albeit this will need to be tested by their respective Local Plan reviews.

In the circumstances, RSL consider the BCP and its associated evidence base clearly indicate there are exceptional circumstances justifying the release of Green Belt land within the BCP area. Associated Green Belt and Landscape Sensitivity Assessments have been undertaken and as confirmed at paragraph 3.16 of the BCP, have identified land that if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Grebe Belt boundaries. In respect of housing, even taking account of existing urban capacity, proposed Green Belt release and the current best-case scenario regarding the export of unmet needs to neighboring authorities, there is still a potential shortfall of some 18,739 homes. A similar scenario is likely in respect of employment land.

Comment

Representation ID: 22409

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

2.98 Draft Policy GB1 is unsound as it does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for housing.
2.99 As set out in its response to Draft Policies CSP1 and HOU1, St Philips objects to the BCP on the basis that it seeks to provide only 47,837 dwellings in the plan period, leaving a significant shortfall of 28,239 dwellings. The BCP has failed to provide sufficient land to meet the minimum housing needs, as per NPPF paragraph 11(b), and will need to ensure that additional housing land is provided through further Green Belt release.
2.100 As earlier indicated, there are several shortcomings in the Black Country Green Belt Study: Stage 1 and 2 Report (Land Use Consultants, September 2019), and it is considered that the omission of several sites submitted through the Call for Sites is unsound on the basis that the Green Belt Study has applied an inconsistent and flawed approach in the assessment of sites submitted through the Call for Sites.
2.101 This is because the Stage 1 Contribution Assessment has been prepared at such a strategic level as to render its findings on the extent of the potential harm to the Green Belt purposes, as a result of development, questionable when applied to smaller individual potential development sites adjacent to the urban areas.
2.102 By way of example, the geographical scale of some parcels is extremely vast (e.g. between 100-500 ha) whilst others are of a much smaller scale (e.g. between 1-50 ha).
2.103 This varying scale will undoubtedly have a negative and inconsistent impact on the scoring identified in the Green Belt purposes ratings for each parcel, as set out at Table 5.1 within the Stage 1 Findings (page 44).
2.104 St Philips considers the larger Green Belt parcels are capable of logical sub-division based on defensible boundaries. It also recommends that all of the parcels should be of a similar size and that care should be taken to ensure that a consistent approach is taken in respect of the assessment of different parts of the Black Country. This could be achieved through the subdivision of some parcels to ensure that they are all more equally sized. Indeed, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale.
2.105 The approach taken in respect of generating the land parcels for assessment is set out at paragraph 4.29:
“By combining the lines marking variations in contribution to Green Belt purposes, a list of land parcels was generated, each of which has a reference number and a rating for contribution to each purpose. The parcels are the product of the assessment rather than a precursor to it. The reasoning behind this approach was to draw out variations in contribution to inform the site-specific assessments undertaken at Stage 2, avoiding broad variations in contribution within prematurely and more arbitrarily defined parcels. Avoiding significant variations in contribution within defined parcels prevents the need for ratings to be generalised to reflect the strongest or average level of contribution within a defined area.”
2.106 Whilst the Stage 2 Harm Assessments consider the sub-parcels at a smaller scale, it is noted that not only are some of these sub-parcels still at a significantly large and inconsistent scale (some extend to <10ha whilst others are >100 ha), but that the assessment of harm is effectively an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
Land North of Little Aston Road, Aldridge, Walsall
2.107 This issue is evident through the assessment of land north of Little Aston Road, Aldridge, Walsall (Call for Sites ID 173).
2.108 St Philips is promoting land north of Little Aston Road, Aldridge, Walsall and submitted the site accordingly through the Call for Sites process. A Vision Document is submitted alongside these representations which demonstrates how up to 137 dwellings could be delivered at the site.
Stage 1 Contribution Assessment
2.109 Within the Stage 1 Contribution Assessment, the site forms part of Parcel Reference B93 (East of Walsall) with a parcel size of 1768.3 ha, as illustrated below.
Figure 2.4 Parcel B93 at Stage 1 Contribution Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
Figure 2.5 Parcel B93 at Stage 1 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.110 As can be seen, the parcel boundary incorporates a vast swathe of the east Walsall. Ultimately, it is considered that 1768.3 ha is too large of a geographic area such that meaningful conclusions can be drawn as to the Green Belt Purposes of sub-parcels within the wider parcel. By way of comparison, a large proportion of other parcels within Walsall have been drawn significantly smaller at between 1-50 ha.
2.111 As earlier established, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale. This inconsistent approach has therefore unfairly resulted in parcel B93 being assessed as performing generally strong against the Green Belt purposes:
Table 2.5 Performance of parcel B93 against Green Belt purposes [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.112 This inaccurate scoring has consequently followed through into the Stage 2 Harm Assessment.
Stage 2 Harm Assessment
2.113 Within the Stage 2 Harm Assessment, the site form parts of Sub-Parcel Reference B93D (Little Aston Road) with a parcel size of 96.8 ha, as illustrated below.
Figure 2.6 Parcel B93D at Stage 2 Harm Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
Figure 2.7 Parcel B93D at Stage 2 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
2.114 Whilst the Stage 2 Harm Assessments has considered the sub-parcel at a smaller scale, it is not broadly aligned with promoted site reference #173 and fails to illustrate promoted site reference #332. Additionally, the assessment of harm of ‘Very High’ has effectively been derived from an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
2.115 This is a fundamental flaw in the methodology of the Green Belt Study which results in a failure to account for a more localised assessment of how sub-parcels and promoted sites perform against the Green Belt purposes. As a result of this shortcoming, the land at Little Aston Road, Aldridge, which would have otherwise been selected for Green Belt removal, has been artificially omitted.
2.116 The Green Belt Study methodology should be reviewed and amended to address this issue, and the land at Little Aston Road should be proposed for removal from the Green Belt and allocated for housing accordingly.

Support

Representation ID: 22422

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Policy GB1 – The Black Country Green Belt
In the light of the above, it is inevitable that Green Belt land in the Black Country will need to be
released to help the authorities meet their housing needs over the Plan period. It is evident that
the BCAs have examined fully all other reasonable options for meeting their identified need for
development and have concluded that they could not achieve this alone by adopting a strategy
that accords with the criteria set out in paragraph 141 of the NPPF. In our view, this demonstrates
that that the exceptional circumstances do exist to justify the BCAs making changes to existing
Green Belt boundaries.
We support the BCA’s acknowledgement that the site is considered appropriate for the release
from the Green Belt, as evidenced by Policy HOU1.

Comment

Representation ID: 23056

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy GB1 – The Black Country Green Belt
Alterations to the Green Belt require exceptional circumstances in accordance with National Planning Policy Framework (‘NPPF’) paragraph 140. Given the scale of housing need and an identified shortage of brownfield land to meet the need (Urban Capacity Report 2021), we agree with the BCA that there are exceptional circumstances to justify the release of Green Belt.
The policy states that compensatory improvements will be required to offset the impact of removing land from the Green Belt. The Viability and Deliverability Study (May 2021) has allowed for a compensatory contribution of £1,000 per dwelling. No details have been provided on the projects this contribution will fund nor whether improvements could be made on site or on other land within the same ownership/control in lieu of paying the contribution.
The BCA is currently not proposing to safeguard any land for future development within the plan. Paragraph 143 of the NPPF states that plans should “identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period” and “be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period” [Savills emphasis]. Given the BCA has determined that Green Belt release is already required to meet current housing needs and it is acknowledged that there is a significant housing shortfall arising from the BCA and wider HMA, it is accordingly expected that additional Green Belt release will be required to meet the development needs of the District beyond the plan period. It is also considered to be likely that additional Green Belt release will also be required within the plan period as well.
We therefore consider that in order to accord with NPPF paragraph 143, the BCA should be identifying additional land in sustainable locations which can be released from the Green Belt in the plan and safeguarded for future housing needs beyond the plan period. Our client’s land to the west of Chester Road (Call for Sites ID 107) is considered to be in a sustainable location and could be an appropriate addition to Strategic Allocation WSA9 within the plan or at the least, it could be safeguarded to assist the BCA in meeting future needs.

Support

Representation ID: 23087

Received: 07/10/2021

Respondent: Halesowen Abbey Trust

Celebrating Halesowen's Countryside
Black Country Plan Consultation
The Halesowen Abbey Trust supports the Green Belt designation of countryside in our Area of Benefit, as shown on page 14 of our attached report, following the Green Belt review and assessments.
For many years, the Trust worked with Dudley Council to improve this historic countryside, which is an important amenity serving a large population. We will provide a comprehensive report, in due course to explain our support in more detail. In the meantime, I attach a report, dated March 2020, titled,
'Celebrating Halesowen's Countryside', which explains the trials, tribulations and pleasure we have
experienced in respect of this countryside.
Will you please acknowledge our support by confirming safe receipt of this email and attachment?
'When any of the jaded toilers in the district known as the Black Country have an afternoon to spare, and feel that a few hours passed amidst the beauties of nature would be a benefit to them, there is nothing more natural than that they should travel by train to Hagley Station, or obtain a horse and conveyance, and proceed with as little delay as possible to the foot of Adam's Hill, Clent, in preference to taking a much longer and more troublesome journey elsewhere with no better result. The time occupied in reaching Clent from the surrounding populous districts is so comparatively short, and the neighbourhood around Clent Hill so beautiful, that it is pre-eminently the place to select for the popular day or half-day outing.'
Clent, 1910 - E Blocksidge, Stone St, Dudley.
We are fortunate to have beautiful countryside adjacent to and within Halesowen. It is an important informal recreational and educational resource for the region and has hitherto been formally recognised for its historic; landscape and ecological importance.
Recognition pre-dates the modern era. The Premonstratensian Canons of Halesowen Abbey, noted for their love of natural beauty, chose the site that was later known as Lapal - derived from the French 'la' added to the Anglo Saxon 'pol', meaning 'the pool' - A clear reference to the fishponds created for the Abbey. The Canons occupied the Abbey from 1218 until the dissolution of 1538. The remains of the Abbey were scheduled as an Ancient Monument as early as 1915 - in recognition of the importance of the site.
We are fortunate that the remains are preserved in their original rural setting, which is important to the character and identity of historic Halesowen.
Unsurprisingly, the Dudley Historic Environment Record indicates an unusually high incidence of entries, ranging through the mesolithic; bronze and iron ages, as well as the Romano-British and mediaeval periods. There may have been a substantial Roman Villa.
It has long been accepted that any disturbance of the ground, at, or in the vicinity of Manor Farm, is likely to reveal artefacts of archaeological significance.

Watching Brief for Erection of a New Barn at Manor Farm - 2008/2009
The owner of Manor Farm was granted planning permission for the erection of a large modern barn, just outside of the scheduled area of the monument but in close proximity to the Abbey's Infirmary - the most complete of the monastic remains on the site.
The erection of the barn took place in the field known as 'Abbey Oaks' and commenced on the 17th December 2008. The Borough's Archaeological Officer was engaged to carry out a watching brief and report the results.

To those familiar with the area, it came as no surprise to find that the chosen site was rich in archaeological deposits. Many fragments of mediaeval encaustic clay tiles from the Abbey were found. A small selection is shown in the above image.

Green Lanes. Public Rights of Way and Mediaeval Ploughing
Superficially, it may appear strange to group 'green lanes', Public Rights of Way and medieval ploughing, but in this instance they are further links to the historic rural past of Lapal and llley. The photograph opposite shows Manor Lane, circa 1905, when it was little more than a 'green lane'. From 1218, until 1538, It was an highway maintained by the Abbot of Halesowen Abbey. Subsequent development meant that it was upgraded, the most extreme change being from the junction with Grange Hill through the new section to junction 3 of the M5, as a dual carriageway, now known as Manor Way. Not so extreme, but still notable is Lapal Lane, split by Manor Way. The northern section serving the Manor Abbey Estate has been upgraded as an urban road with footpaths, increased carriageway width and street lighting, whilst Lapal Lane South, separating Manor Farm from Lapal Farm, is still a narrow country lane. Development in the Lapal countryside would change that.

In the 1980s the Halesowen Abbey Trust restored the Public Rights of Way of Lapal and Illey under the umbrella of the ‘Dudley Countryside Management Project’ jointly funded by Dudley Council and the Countryside Commission. As part of that work, the overgrown and neglected mediaeval ‘green lanes’ were restored. They were ditched either side for drainage, and in the steep section to Coopers Wood, wrought iron horseshoes from the medieval period were found, preserved in the clay. The presence of these, and hedgerow dating methods, helped to date the ‘green lanes’, the maintenance of which are referred to in the extant Court Rolls of Halesowen Abbey.
Today, the ‘green lanes’ are a valued relic, reminding us of the origins of some of our oldest local roads. They are also a source of pleasure and recreation for the hoards of walkers who enjoy this historic countryside. The value of the Public Rights of Way to the physical and metal well-being of those who enjoy them should never be under-estimated.
Ridge and Furrow appearing as undulations of the land, is a legacy of medieval ploughing. The Sites and Monument Records, held by Dudley Council, state that these date from between 1066 and 1485, and are found at Lapal and Illey on unimproved grassland. Where land has been under regular modern arable cultivation evidence of ridge and furrow has generally been erased. The photograph, taken at Illey Clearly shows the undulations with are best observed in a low oblique sunlight.
Below is an atmospheric photograph of Manor Farm, taken in the 1960s. It records the historic site as it was in its lengthy period as a working tenanted farm, which lasted from the dissolution of the monastery in 1538, until it was sold in 1993 by Viscount Cobham, whose family had held the site since 1560. A benefit of the long period of tenancy in farming was the lack of disturbance of most of the monument. Archaeological excavations took place in 1870 by J. R. Holliday and between 1925-1928 and 1934-1940 by the Duke of Rutland. Seven hundred and sixty of the Abbey's tiles are held in the British Museum and eight tiles are now in the Holliday Collection at the Victoria and Albert Museum, with six fragments in Halesowen Central Library and a case of tiles in St. John the Baptist Church, Halesowen. The long shadows in the photograph emphasise the earthworks of the Abbey. In the foreground is a dam to one of the former monastic fishponds.

Under the terms of a Guardianship Agreement of 1979, with the then owner, Viscount Cobham, English Heritage have the right to open the Abbey to the public along a defined and restricted route, with access to the Infirmary. A small car park is identified for visitors. For several years that right has not been enacted, but the public can walk the Public Rights of Way, giving limited access to some of the fishponds and allowing views of the monastic remains.
The six bedroom farmhouse, for Manor Farm (seen in the above photograph), built in the late 19th century, replaced a mediaeval building, the use of which is in doubt. The old building has been variously described as the former Abbot's lodging and as a mill. The impressive replacement was designed by Yeoville Thomason, the distinguished architect responsible for Birmingham's impressive Council House and other such fine buildings.

In the 18th Century, this was the landscape enjoyed by William Shenstone of the Leasowes; his relative and friend, Lord Dudley of the Grange and their literary associate, John Scott Hilton of Lapal House. Shenstone used stone from the Abbey to construct his ruined 'Priory'- a major feature of his landscape creation, the Leasowes. Sir George, Lord Lyttelton (1709- 1773), of Hagley Hall, allegedly took stone from the Abbey to create one of his fine parkland follies, the Castle.

Official Recognition, 1989
Hitherto, we have concentrated on llley and Lapal, but this is simply part of a swath of special countryside that in the mid nineteenth century was described as 'Clentine' because of its relationship to the famed Clent Hills. The Clent Hills are set within beautiful countryside and are inseparable from it and vice-versa.
Whilst the public are aware of the importance of the
'Clentine' countryside, unfortunately it is not afforded the protection of an 'Area of Outstanding Natural Beauty', or a 'Country Park'. Perhaps it should be? Nevertheless, in 1989, it was recognised in a statutory plan, produced, at that time, by an enlightened Dudley Council planning department, titled 'A Place for Leisure'. It was formally acknowledged by the Royal Town Planning Institute for its progressive and positive approach.

Besides being prepared to 'establish and define the boundaries of the Green Belt', the other main reasons for preparing the plan were:
• to give recreation and open space considerations significant place in decision making
• to provide land for the whole range of outdoor recreational activities in the Borough
• to contribute towards urban regeneration

The four main aims of the plan were:
1. to provide a positive context for the protection and enhancement of open land throughout the Borough
2. to establish a site specific basis for a programme of new development

3. to establish a land use context for the development of a nature conservation strategy
4. to provide an opportunity for the public to participate in planning decision

The implementation of 'A Place for Leisure' led to the employment of a Countryside Manager and the creation of the Dudley Countryside Management Project (DCMP}, which started a three year experimental phase in September 1988. A 'Biennial Report 1991-1993' indicated how successful the project was.
Betray?
The Dudley Countryside Management Project has been downgraded and no longer has planning department support, or recognition. Similarly, 'A Place for Leisure', and its aims and objectives, are not acknowledged and are even denied by the current planners. In 2015, Dudley's planners supported a huge enterprise zone on the countryside of Lapal and llley, as shown on the plan opposite. Ancer Spa were commissioned to pursue this. It would have decimated splendid historic countryside, important to the character and identity of Halesowen and its people. Understandably, this sorry episode damaged public confidence in Dudley's planners.

On that occasion, councillors, who had hitherto been sidelined by the planners, responded quickly and threw out the proposal at a meeting of full Council. However, with the employment of new staff, the planners have ever since been aggressively pursuing development of Dudley's countryside.

In spite of Dudley Borough having a surplus of urban housing land to meet its own needs beyond the end of the next plan period in 2038, the planners have provisionally agreed to 5,000 new houses in Dudley's Green Belt to meet the claimed needs of neighbouring authorities. This first came to light in a letter of the 9th September 2019 from Wolverhampton Council to Shropshire Council, which stated
"Given that the Black Country Green Belt is located primarily in Walsall and, to a lesser extent, in Dudley, these are the two main housing market areas for delivery of housing, with only small amounts of housing potential in Wolverhampton and Sandwell. Therefore, based on a scenario that there was sufficient unconstrained physical capacity identified within the Green Belt, it may well be that a Delivery Study (based on similar principles to that completed by PBA for Birmingham), could reasonably conclude that these two nominal housing market areas could only be expected to deliver up to 5,000 homes each over the 15-year Plan period, based on upon what the market can be expected to deliver. This would therefore only provide up to 10,000 homes in total."
It is fortunate that such revealing and premature comments have come to light. Again public confidence in the integrity of the planning process, has been justifiably damaged. In September 2019, we were led to believe that evidence was still being collected and collated, in advance of being considered. Then the matter should go to Cabinet before going public. It is a controversial decision for a Council, with no justification to develop its Green Belt for its own needs, to offer its precious countryside for the needs of others. Do such grounds, which would surely be ongoing, if agreed, constitute the 'exceptional circumstances' as required by the National Planning Policy Framework? The Green Belt, instead of having the protection required in guidance would become a perpetual resource for development.

Volunteers Support the Previous Policies of Dudley Council
Whilst the current Dudley planners have turned their backs on recognition, protection and improvement of our countryside, volunteers who pro-actively worked with their predecessors, continue with the task. Within the limits of available resources, footpaths are cleared and problems are addressed. Elected members are appreciative and supportive.
In the summer of 2017, volunteers of the Halesowen Abbey Trust, constructed a substantial footbridge at the Trust's Grade 1 Listed Leasowes Walled Garden (in the Green Belt); transported it to site, adjacent to Uffmoor Wood, in the vicinity of Tack Farm and installed it. This overcame a major flooding problem, which had prevented appropriate use of a popular Definitive Right of Way.

Promoting Appropriate Use & Enjoyment of the Countryside

The National Planning Policy Framework reflects the Government's positive attitude towards Green Belts, and states:
13. Protecting Green Belt land
133. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence
141. Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Paragraph 141 relates perfectly to the aims of 'A Place for Leisure', which defined the Green Belt boundaries of Dudley in 1989 and not in the 1970s as claimed by the Borough's planners.

The Halesowen Abbey Trust has produced eight walk leaflets to promote use and enjoyment of the local countryside in their area of benefit. An 'Index and Guide' has just been published to accompany the walk leaflets and explain how the walks link up. The illustrated leaflets are full of information to assist the user.

The 'Area Map' clearly illustrates the link up of the walks over an extensive area. We are fortunate to have such an asset, but at present the future of that countryside is in doubt. It need not and should not be that way

Comment

Representation ID: 23188

Received: 11/10/2021

Respondent: Historic England

we would want to ensure that any amendments to the Green Belt are assessed both in terms of their Green Belt functions for historic towns, if appropriate, and on the impact to the significance of heritage assets including their setting.

Support

Representation ID: 23225

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy GB1 – The Black Country Green Belt

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. These sites will not only assist in meeting the development needs, but they deliver more affordable housing, green infrastructure, executive housing, assist in achieving the objective of 25% 4 bedroom dwellings, and will improve the infrastructure (e.g. school and doctor places).

One thing we note here is the desire to create permanent boundaries to the NDAs. Presumably with the intent that they will endure beyond the plan period as required by the National Planning Policy Framework. However, this does pose an important question. Is the draft plan saying that the Black Country has maximised its Green Belt capacity for not only this plan, but also the next? So that any additional development needs that cannot be accommodated in the urban area will have to be exported.

Object

Representation ID: 23231

Received: 11/10/2021

Respondent: Member of Parliament

In recent years, we have seen the steps taken and significant investment to successfully assist with the remediation of brownfield sites for housing. The United Kingdom is on the verge of playing global host to the UN Climate Change Conference (COP 26), yet it is unclear what full and proper assessment has been undertaken of all available brownfield sites in my constituency ahead of proposing large swathes of development on existing Green Belt sites.
It is extremely disappointing that the Black Country Plan fails to live up to its brownfield first policy aspiration, nor even recognises the value and multiple benefits that such a policy and protections would create.
By failing to live up to that policy the Green Belt will undoubtedly be sacrificed first, our communities and environment damaged and the opportunity to regenerate urban and brownfield sites lost for a generation, if not forever.
Turning again to the figures on which this Plan is based and even on the basis of the flawed starting point of 13,344 units required over 20 years, this equates to 667 units per year.
Adopting an urban and brownfield sites first policy would provide 12 years of homes without having to touch any of the Green Belt sites.
If the trajectory of population growth continues to fall and migration flows reduce, the preservation of our Green Belt would endure for longer, if not indefinitely, whilst housing need can be met on brownfield sites, and our towns and district centres are regenerated and reinvigorated to be able to meet the challenge of the post Covid-19 era and provide the needed homes.
Without such a commitment to uphold the development of brownfield sites first, developers will simply continue to choose Green Belt sites over brownfield sites seeing them as the easier and cheaper model for development.
The stated aims of the Green Belt and the protections that it is given are well documented. There should be no de-designation of existing Green Belt.
As identified in the National Planning Policy Framework, the Green Belt serves 5 key purposes. Key amongst those objectives is to check the unrestricted sprawl of large built up areas.
On all of the key sites identified on Green Belt land in my Aldridge-Brownhills constituency, these principles are being set to one side to meet questionable targets and quotas that for the reasons I have identified above have not been justified in the Plan.

Comment

Representation ID: 23310

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

As set out in our response to CSP1 we agree that exceptional circumstances exist to release land from the Green Belt for development. Indeed, it is imperative if the housing requirement is to be met. However, even with Green Belt land release it is necessary for a significant proportion of the housing requirement to be direct to neighbouring authority areas.

Comment

Representation ID: 23370

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy GB1
We support the general policy wording in line with our comments on CSP3. We do not support the large-scale removal of land from Green Belt. Where Green Belt status is removed, a policy of creating physical features to define the boundary is welcome, but this may be difficult when those boundaries are not, themselves, well defined.
In as much as they be complimentary improvements to offset the impact of development are welcome the wording is vague as to how these will be achieved, whether at the site it- self or elsewhere. The risk is that such ambitions will fall foul of viability tests and little will actually be done to improve the Green Belt beyond the new site boundary.

Support

Representation ID: 23415

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

Green Belt

4.16 Paragraph 140 of the NPPF confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.

4.17 The Black Country Authorities consider that, through the preparation of the Black Country Plan, exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. The Black Country Urban Capacity Review Update (May 2021) summarises the various sources of housing supply and compares current supply with identified need. The report calculates that the amount of housing need that cannot be accommodated in the Black Country urban areas remains significant, at around 36,819 homes. This is despite reviewing all potential sources of housing capacity, making a series of structured assumptions around density and windfalls, and comprehensively exploring the capacity on occupied employment land in the context of up-to-date employment land evidence. In addition, the Urban Capacity Review also notes the strategic Duty to Cooperate issues, particularly the current and emerging housing shortfall position across the Greater Birmingham and Black Country Housing Market Area. It is also important to note that Paragraph 4.7 of the Urban Capacity Review concludes that “the exceptional circumstances necessary to trigger a Green Belt review in the Black Country, in order to meet housing and employment land needs, have been met”.

4.18 Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, as noted in NPPF Paragraph 141. This will be assessed in terms of whether the strategy:

a. Makes as much use as possible of suitable brownfield sites and underutilised land;
b. Optimises the density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c. Has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.

4.19 With regard to making as much use as possible of suitable brownfield sites and underutilised land, the Urban Capacity Review identifies (at paragraphs 2.1.7-2.1.9) that the inclusion and assessment of sites within the current SHLAAs has followed Government guidance, best practice, sustainability principles and the spatial strategy of the current Black Country Core Strategy (BCCS). A ‘brownfield first’ principle is applied. The sites identified as deliverable or developable are mainly those with planning permission, allocations on surplus employment land and other sites in the BCCS growth network (including greenfield sites, where appropriate i.e. those with planning permission or considered to be policy compliant). The SHLAAs have been informed via a Black Country ‘call for sites’ carried out in 2017-20 to inform the BCP.

4.20 Therefore, in terms of the sites included within the Black Country SHLAAs, it is considered that the assessments have been comprehensive in their scope and identifying potential sources of supply, including making as much use as possible of suitable brownfield sites and underutilised land. In particular, the Urban Capacity Report (at paragraph 3.1.2) identifies that it has undertaken a review of existing housing allocations, which has resulted in a reduction of housing supply from allocations on currently occupied employment land, as reflected in each of the individual SHLAAs.

4.21 In terms of optimising density, the Urban Capacity Report (at paragraph 3.1.9) refers to the Strategic Growth Study (2018) findings and conclusions, which suggests that the Birmingham and Black Country urban area should seek to apply a minimum 40dph density threshold (net area). This could yield an additional 4,000 dwellings (1,000 dwellings from sites of 200+ dwellings and 3,000 dwellings from small sites below 200 dwellings) in the Black Country (subject to further local testing). The Strategic Growth Study based the findings on a sample of 750 sites across the 14 HMA Local Planning Authorities.

4.22 In 2019, a review was undertaken by the Black Country Authorities to test this conclusion more locally. It identified that from 2009-2019 approximately 86% of sites of 15 dwellings or more have been developed at a density of 35dph and higher. Around 54% have been developed at a density of 35-60dph. The Urban Capacity Report notes that it is not possible to increase densities on sites with planning permission and any increases arising from changes in policy would not take effect until 2024 (anticipated BCP adoption date). An analysis is, however, undertaken of the potential uplift arising from the draft BCP Policy on housing density and accessibility.

4.23 The analysis considers the potential uplift resulting from applying the draft Policy standards to sites of 10 dwellings or more that are unlikely to be the subject of planning permission before 2024. This results in a maximum additional supply of 476 dwellings which is significantly less than the Strategic Growth Study assumption of around 4,000 dwellings. The Urban Capacity Report explains this is due to a more detailed analysis of more up to date site information. The analysis assumes all sites within the 35-45dph density range have a density of 35dph and can uplift to 40dph. The Urban Capacity Report considers that it could be the case that many of these sites are already due to deliver at near 40dph (or above). For example, the Walsall SHLAA 2020-2021 states that it has already applied the emerging minimum 40dph assumption to all sites (bar those considered ‘deliverable’ within the five-year supply). Indeed, some sites within the supply are already significantly exceeding some minimum densities from the BCCS and Strategic Growth Study.

4.24 In terms of the potential to exceed the suggested minimum 40dph, the BCP however needs to take into account the housing mix needs of the area. The Strategic Growth Study (paragraph 6.14) identified that generally it is possible to create developments within densities of 40dph or 50dph which continue to provide for a mix of housing types and sizes, including family housing. The BCCS Policy HOU2 (Table 8) identifies that generally schemes of 35-45dph will constitute 0-25% flatted developments. The Black Country and South Staffordshire Strategic Housing Market Assessment (SHMA, 2017) concluded that given the nature of existing housing stock, the optimum housing mix overall would be 12% 1 bed; 22% 2 bed; 40% 3 bed; and 26% 4 bed properties (to vary by area and tenure). Therefore, given that 66% of the preferred tenure is for 3 bed+ homes, there is limited scope to drive minimum densities further without compromising the housing needs of the community.

4.25 With regard to discussions with neighbouring authorities, the Black Country Plan confirms that it intends to draft and agree Statements of Common Ground with relevant authorities (including South Staffordshire, Lichfield, Cannock and Shropshire) and bodies on key duty to co-operate issues at the BCP’s publication stage. However, the issue of the significant shortfall in planned provision to meet housing requirements within the Black Country and wider HMA has been well-considered, as evidenced by the Greater Birmingham HMA Strategic Growth Study (2018) which was commissioned by the 14 local authorities that comprise the Greater Birmingham and Black Country Housing Market Area.

4.26 Based on the above, it is considered that the Council have fully examined all other reasonable options for meeting the identified need for development outside of the Green Belt in line with Paragraph 141 of the NPPF.

Compensatory Improvements

4.27 Paragraph 142 of the NPPF advises that, where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. Similarly, Draft Policy GB1 (The Black Country Green Belt) states that for sites that are removed from the Black Country Green Belt and allocated to meet housing, or other needs through the Plan (as listed in Chapter 13):
a. ‘The design of development will include physical features that define the new green belt boundary in a readily recognisable and permanent way; and
b. Compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from the green belt, in accordance with national policy.’

4.28 As such, the Draft Black Country Plan provides for compensatory improvements for the loss of Green Belt through those strategic allocations that are being released from the Green Belt. For example, Yieldfields will deliver significant improvements to the quality and accessibility of the existing Green Belt. These improvements will include the creation of a landscape buffer and soft edge/transition along the development edge and the countryside, in addition to retaining and enhancing existing mature tree belts and hedges, responding to the local countryside character to the north. In terms of connectivity, Yieldfields will include a series new pedestrian and cycle routes from the development to existing Public Rights of Way located in the Green Belt, as shown in the Vision Document and Masterplan. Therefore, L&Q Estates are supportive of Draft Policy GB1, and consider that the site is capable of meeting the requirements set out within Part 2 a) and b) of the policy.

Comment

Representation ID: 23462

Received: 08/10/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning Limited

The impact on the Black Country’s Green Belt.
The Black Country Green belt is unusual insofar as it comprises a network of green wedges
which separate induvial settlements within the Black Country communities. Unlike the
London Metropolitan or Birmingham Green Belts it does not simply surround the
conurbation.
The BCP makes the controversial proposal to remove areas of green belt to provide room for
some 7,720 dwellings across the Black Country. This comprises land for:
1,117 homes in Dudley,
171 homes in Sandwell,
5,418 homes in Walsall, and
1,103 homes in Wolverhampton
Understandably, these proposals have proved unpopular with local people and with local
politicians to the point where public statements have been made challenging the loss of
green belt and it is doubtful whether the Black Country Local Plan will ultimately receive
members’ support. The West Midlands Mayor (who doesn’t have strategic planning powers)
but does seem to have a wider influence, has also declared himself resistant to green belt
development within the boundaries of the conurbation.
Under Paragraph 140 of the NPPF Government guidance stresses that ‘green belt boundaries
can only be altered where exceptional circumstances are fully evidenced and justified,
through the preparation or updating of plans. Strategic policies should establish the need for
any changes to green belt boundaries…’
Whilst in circumstances such as these it is likely to be feasible to meet the criteria for some
green belt releases through the Local Plan process, but it is important to recognise that
paragraph 141 stresses that ‘Before concluding that exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to
demonstrate that it has examined fully all other reasonable options for meeting its identified
need for development. This will be assessed through the examination of its strategic policies’.
In this particular case, it is important to note that other opportunities to develop beyond the
green belt in and around Telford do exist without affecting green belt land in the Black
Country. Indeed, in years gone by, Telford New Town served as a formal overspill function
and provided just such a ‘safety valve’ to enable people to move elsewhere in the sub-region
to enjoy new opportunities, whilst not encroaching on the West Midlands green belt.
(Those formal overspill arrangements have long since expired, but the new town of Telford
has still not reached its original target population of 225,000 and yet still enjoys the benefit
of extensive infrastructure provided by the Exchequer to service the overspill population).
Furthermore, arguably, in a post-covid world, the Black Country now badly needs to protect
its landscape, environmental and ecological assets (as well as its recreational green space)
rather than gradually encroaching on its green belt and filling in the network of gaps
between established settlements which makes the Black Country so unique. At the same
time, it is entirely feasible that many people may relish the prospect of moving to a new
sustainable waterside development in Telford – against the background where many people
now appreciate the value of better space standards and greater open space which a new site
at Telford – or indeed at Codsall can offer. These opportunities need to be explored.

Support

Representation ID: 23584

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

3.14 In respect of the requirements set out in Policy GB1, criterion 2) a. requires the design of the development to include physical features that define the new Green Belt boundary in a readily recognisable and permanent way. WDL confirm that WSA6 can be developed in such a way. The canal already defines the boundary to the west and existing housing forms a boundary to the south and east. Therefore, it is only the northern boundary that will require consideration.
3.15 WDL does not support criterion 2) b. which requires compensatory improvements to the environmental quality, biodiversity and accessibility of remaining Green Belt to offset the impact of removing the land from the Green Belt. Compensatory improvements to environmental quality and biodiversity are covered by other policies within the Plan. Moreover, Green Belt is a planning designation and not one that is based on a site’s ecological value. It is also unclear how compensatory improvements to remaining Green Belt would be delivered. WDL therefore recommend this criterion should be removed from the policy.

Object

Representation ID: 23585

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Paragraph 3.15 - "Green Belt is a planning designation and not one that is based on a site’s ecological value. It is also unclear how compensatory improvements to remaining Green Belt would be delivered."

Comment

Representation ID: 23598

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

5.5
Policy GB1 - The Black Country Green Belt
The BCP identifies at paragraph 3.15 that exceptional circumstances exist to justify changes to
the Green Belt boundaries. However, the amount of Green Belt release proposed is contested.
TO summarise Our representations on the housing policies:
• The should seek to meet identified development needs in full. There is no justification
for reducing the housing and employment land requirements.
• The BC? should also seek to meet the unmet needs of Birmingham.
• The housing land supply position has been over-stated.
The result is that additional viable sites need to be allocated to address the identified shortfalls in
land supply. The supply in the urban area has been exhausted, to the extent that it has been
significantly over-estimated. The only logical solution is for the plan to release further land from
the Green Belt.
Such an approach would be entirely consistent with the Framework. Paragraph 142 requires that
when drawing up or reviewing Green Belt boundaries, local planning authorities should take
account of the need to promote sustainable patterns of development. It also requires local
planning authorities to consider the consequences for sustainable development Of channelling
development towards urban areas inside the Green Belt boundary, towards towns and villages
inset within the Green Belt or towards locations beyond the outer Green Belt boundary. In the
case of the Black Country, there would be very significant adverse social and economic
consequences Of not providing sufficient land to meet the Objectively assessed needs.
Our client proposes an omission site for development in Section 10 of this statement. The land
should be released from the Green Belt and allocated for a residential or mixed-use
development.
Safeguarded land
Paragraph 137 of the Framework identifies that "the essential characteristics of Green Belts are
their openness and their permanence'
5.9
Paragraph
requires strategic policies to "estab
the need for any changes to Green Belt
boundaries, hqvinq reqqrq to their intended oermanence in the long term. so thev can endure
bevond the o/an oeriod"
Paragraph 143 states that when defining Green Belt boundaries, plans should (amongst other
requirements):
"c) where necessarv. identifv areas of safeguarded land between the urban area and
the Green Belt. in order to meet longer-term develooment needs stretching well bevond
the plan period'
e) be able to demonstrate that Green Belt boundaries will not need to be altered at the
end of the olan period" (our emphasis)
Therefore, national policy is clear on the need to ensure that Green Belt boundaries will not need
to be altered at the end Of the plan period (currently 2039). This is a critical aspect to achieving
the intended permanence in the long term. The appropriate mechanism for achieving this
through the provision of safeguarded land. However, the BC? does not propose to designate
any safeguarded land. Other sources of land for future development needs beyond the Green
Belt are extremely limited.
There is no justification for not providing sufficient safeguarded land in the Black Country. The
permanence of the Green Belt would not be maintained, as it would be inevitable that Green
Belt boundaries will need to be reviewed again before the end of the plan period to meet needs
beyond 2039.
5.10 How much safeguarded land is needed in practice was considered in detail at the Cheshire East
Local Plan Strategy examination. In that case it was determined that sufficient safeguarded land
should be made available for another full plan period following the end Of the current plan
period. Paragraph 99 of the Cheshire East Local Plan Strategy Inspector's report states:
"The overall amount of proposed Safeguarded Land is intended to meet
longer-term development needs stretching well beyond the end of the current
plan period; in fact, taking account of other sources of land, it should be
sufficient for another full 15-year period beyond 2030, so that the Green Belt
boundary defined in the CELPS-PC will not need to be amended until at least
5.12
The Further Interim Views of the Inspector (Appendix 2 to the Inspector's report) refer to this
conclusion being based upon examples Of best practice from around the country. Paragraph
50 of the Further Interim Views states:
"There is little guidance available on defining the appropriate amount of
Safeguarded Land, but after considering best practice, an approach which
considers a IO- 15 year period beyond the end of the current plan period seems
reasonable in the context Of Cheshire East: it strikes a reasonable balance
between avoiding the need to review the Green Belt at the end of the current
plan period and avoiding unnecessary releases of Green Belt land at this time. "
Therefore, in summary, sufficient safeguarded land should be provided to ensure that the current
requirement could be carried forward to the next 15-year plan period without the need for Green
Belt release. In practice the minimum requirement is to provide a similar amount Of safeguard
land to the amount of Green Belt being released for development in this plan period. Ideally
more should be provided, to allow flexibility for potential higher growth in the future and to
increase the permanence of the Green Belt.

Comment

Representation ID: 43809

Received: 11/10/2021

Respondent: Burrowes Street Tenant Management Organisation

General Comments
1. It seems to me that we are being forced into a substantial loss of Green Belt because the numbers the Government says we need to come up with are very high, and in my opinion needing to be reduced.

Comment

Representation ID: 43820

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

15

5. Policy GB1 - The Black Country Green Belt
5.1 The BCP identifies at paragraph 3.15 that exceptional circumstances exist to justify changes to
the Green Belt boundaries. However, the amount of Green Belt release proposed is contested.
To summarise our representations on the housing policies:

The BCP should seek to meet identified development needs in full. There is no justification
for reducing the housing and employment land requirements.

The BCP should also seek to meet the unmet needs of Birmingham.

The housing land supply position has been over-stated.

5.2 The result is that additional viable sites need to be allocated to address the identified shortfalls in
land supply. The supply in the urban area has been exhausted, to the extent that it has been
significantly over-estimated. The only logical solution is for the plan to release further land from
the Green Belt.

5.3 Such an approach would be entirely consistent with the Framework. Paragraph 142 requires that
when drawing up or reviewing Green Belt boundaries, local planning authorities should take
account of the need to promote sustainable patterns of development. It also requires local
planning authorities to consider the consequences for sustainable development of channelling
development towards urban areas inside the Green Belt boundary, towards towns and villages
inset within the Green Belt or towards locations beyond the outer Green Belt boundary. In the
case of the Black Country, there would be very significant adverse social and economic
consequences of not providing sufficient land to meet the objectively assessed needs.

5.4 Our client proposes an omission site for development in Section 11 of this statement. The land
should be released from the Green Belt and allocated for a residential or mixed-use
development.
Safeguarded land
5.5 Paragraph 137 of the Framework identifies that
their openness and their .










16

5.6 Paragraph 140 requires strategic policies to
boundaries, having regard to their intended permanence in the long term, so they can endure
.

5.7 Paragraph 143 states that when defining Green Belt boundaries, plans should (amongst other
requirements):

where necessary, identify areas of safeguarded land between the urban area and
the Green Belt, in order to meet longer-term development needs stretching well beyond
the plan period;

e) be able to demonstrate that Green Belt boundaries will not need to be altered at the
(our emphasis)

5.8 Therefore, national policy is clear on the need to ensure that Green Belt boundaries will not need
to be altered at the end of the plan period (currently 2039). This is a critical aspect to achieving
the intended permanence in the long term. The appropriate mechanism for achieving this is
through the provision of safeguarded land. However, the BCP does not propose to designate
any safeguarded land. Other sources of land for future development needs beyond the Green
Belt are extremely limited.

5.9 There is no justification for not providing sufficient safeguarded land in the Black Country. The
permanence of the Green Belt would not be maintained, as it would be inevitable that Green
Belt boundaries will need to be reviewed again before the end of the plan period to meet needs
beyond 2039.

5.10 How much safeguarded land is needed in practice was considered in detail at the Cheshire East
Local Plan Strategy examination. In that case it was determined that sufficient safeguarded land
should be made available for another full plan period following the end of the current plan
period. Paragraph 99 of the Cheshire East Local Plan Str

longer-term development needs stretching well beyond the end of the current
plan period; in fact, taking account of other sources of land, it should be
sufficient for another full 15-year period beyond 2030, so that the Green Belt
boundary defined in the CELPS-PC will not need to be amended until at least












17

5.11

conclusion being based upon examples of best practice from around the country. Paragraph
50 of the Further Interim Views states:

Safeguarded Land, but after considering best practice, an approach which
considers a 10-15 year period beyond the end of the current plan period seems
reasonable in the context of Cheshire East; it strikes a reasonable balance
between avoiding the need to review the Green Belt at the end of the current



5.12 Therefore, in summary, sufficient safeguarded land should be provided to ensure that the current
requirement could be carried forward to the next 15-year plan period without the need for Green
Belt release. In practice the minimum requirement is to provide a similar amount of safeguarded
land to the amount of Green Belt being released for development in this plan period. Ideally
more should be provided, to allow flexibility for potential higher growth in the future and to
increase the permanence of the Green Belt.

Comment

Representation ID: 43828

Received: 11/10/2021

Respondent: Mr Philip Stevens

Draft Black Country Plan 2018-39 Consultation 2021
Policy ENV4

We support Dudley Council in their policy of only building on brownfield sites, and their continuing support for the protection of Green Belt around Halesowen. I know that councilors have given support to our walking and conservation groups and made contributions towards the upkeep of our local heritage and historical sites.
We know that our local Green Belt and surrounding countryside including the Woodland Trust and National Trust with land owned by the Hagley Hall Estate is attracting visitors from afar.
Please continue to only build on brownfield sites and amend business and retail premises to conversion into residential as you seem to have done recently.

Object

Representation ID: 43856

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.17 Policy GB1 refers to the Black Country Green Belt. Criterion 2 refers to sites that are removed from the Black Country Green Belt and allocated towards meeting employment, residential and other needs. It states that the design of developments on such sites will include physical features that define the new Green Belt boundary in a readily recognisable and permanent way.
4.18 Whilst the principle of this is understood, the Policy should also refer to the reinforcement of existing boundaries as some sites are likely to already have existing clearly defined boundaries where the provision of new boundaries would be inappropriate.
4.19 This current wording also does not consider sites which are to be released from the Green Belt in neighbouring authority areas, such as South Staffordshire. In such scenarios, there would be no need to provide a Green Belt buffer within the Black Country as there would be developed land beyond this buffer in the neighbouring authority area.

Object

Representation ID: 43912

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.22 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).
3.23 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).
3.24 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.
3.25 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.
Infrastructure
3.26 At the current stage of draft BCP preparation it is acknowledged that the evidence base is still being prepared, and this is particularly true with regards to infrastructure.
3.27 Paragraph 4.9 states “Parts of the Black Country’s existing highway infrastructure, and the motorway network, suffer from congestion”. Development should therefore be located at the most sustainable and accessible locations. Land at Pennwood benefits from being located near to a variety of existing amenities and facilities that are within walking or cycling distance of the proposed development. Figure 2 ‘Facilities Plan’ of the accompanying Vision Document demonstrates this.
3.28 Paragraph 4.11 emphasises the need for infrastructure investment in order to support future development. Barratt are proposing to create extensive green infrastructure (over 50% of the total site area) within their site that is multi-functional through the delivery of biodiversity, amenity, aesthetic and drainage benefits. In addition, where development is planned between new areas of public open space and new woodland park, new footpaths, cycle routes and landscape corridors are proposed.

Support

Representation ID: 43930

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy GB1: The Black Country Green Belt
3.22 As identified at paragraph3.14-17, 3.75, the draft BCP has identified exceptional
circumstances for the removal of land from the Black Country Green Belt such as land
at Queslett Road, Walsall (draft policy WSA8), in order to meet housing and
employment land needs. The Council summarise their exceptional circumstances case
further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).
3.23 Following national planning policy, the authorities are therefore justified in proposing
to amend the Green Belt boundary through the associated policies map.
3.24 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.
3.25 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.

Support

Representation ID: 44901

Received: 10/10/2021

Respondent: Cannock Chase Council

Support the recognition that compensatory improvements will be required to the
environmental quality and accessibility of remaining green belt. Support the use of
masterplan especially where these are cross boundary. The policy should include
reference to that some of the impacts or opportunities may cross administrative
boundaries.

Object

Representation ID: 44921

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy GB1 – The Black Country Green Belt

5.1 The justification to Policy GB1 states that exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. For the reasons set out in our response to Policy CSP1, we agree that exceptional circumstances have been demonstrated in accordance with the Framework [§139-
§141] but it is essential that further Green Belt land is released and additional sites are allocated for residential development to meet development needs in sustainable locations.

5.2 We are also concerned with the approach taken to assessing the Green Belt in the Black Country Green Belt Study [BCGBS]. Having reviewed the BCGBS methodology, we are concerned that there are shortcomings in the BCGBS and this has resulted in the contribution of some sites to the Green Belt purposes being assessed as greater than they actually are.

5.3 In particular, we note that the findings of the Stage 1 assessment provide a strategic review of the contribution made by land to the Green Belt purposes. Given the strategic nature of the Stage 1 assessment, many of the parcels of land which are assessed are significant in size and the boundaries identified often extend to several different urban areas. The assessed contribution
of these parcels does not therefore necessarily reflect the contribution of smaller areas of land within the parcels.

5.4 In addition, we note that the findings of the Stage 1 Assessment have been carried through into the assessment of sub-parcels at Stage 2. We consider that the use of the findings as the starting point to assess the ‘Harm’ of smaller sub parcels results in the assessed harm being greater in some instances than it would be if the contribution of sub-parcels was assessed individually.

5.5 In addition, at Stage 2 of the Assessment process, the ‘Harm’ ratings applied are based on an assessment of sub-parcels rather than individual sites. They are not therefore considered to provide an accurate assessment on the contribution of individual sites as they are often larger in size and assessed using different boundaries.

5.6 In this regard, Taylor Wimpey wishes to draw upon the signficiant issues raised by the Inspector in the ongoing examination into the Welwyn Hatfield Local Plan. Submitted for examination in May 2017, the plan as submitted did not provide for a sufficient housing land supply to meet the Full Objectively Assessed Housing Need [‘FOAHN’]. Following stages 1 and 2 of the hearing sessions, the Inspector issued a 'Green Belt review' note23 in December 2017 setting out their initial thoughts relating to the soundness of the plan in the context of the Green Belt Review findings:

“The Council has suggested that it is unable to meet its housing need because of Green Belt restrictions among other concerns. In my concluding remarks to the Hearing sessions into Strategic Matters, I pointed out that I did not consider the development strategy put forward in the plan to be sound, in part because there was insufficient justification for the failure to identify sufficient developable sites within the Green Belt. That is largely because the phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further.” (page 1) [Lichfields emphasis]

5.7 In order to ensure that the contribution of sites to the Green Belt is accurately assessed, Taylor Wimpey considers that a similar finer grained approach is appropriate in the case of the BCGBS.

5.8 We consider the findings of the BCGBS in the context of Taylor Wimpey’s land interests at Mob Lane, Chester Road and Clent View Road and provide more detailed commentary of this matter in the Green Belt Technical Report submitted with these representations. We have undertaken our own assessment of the contribution of each of these sites in isolation to the Green Belt purposes. For the reasons identified, when this more ‘fine grained’ approach is taken, the contribution of the sites is much less that when they are assessed as larger strategic parcels and sub-parcels in the BCGBS.

5.9 The assessment demonstrates that all three sites perform a limited Green Belt function and are suitable for removal from the Green Belt boundary and allocation for residential development.

Walsall Policies Map

5.10 With regard to the Policies Map for Walsall, Taylor Wimpey strongly supports the removal of the Mob Lan site from the Green Belt and the allocation of the site as part of Strategic Allocation WSA.2 (Land at Vicarage Road and Coronation Road, High Heath and land at Mob Lane, Pelsall). The Green Belt Technical report submitted alongside these representations, sets out
the reasons why the removal of the site from the Green Belt is wholly appropriate and will help to deliver much needed housing for the Plan area.

5.11However, Taylor Wimpey objects to the inclusion of land at Chester Road, Streetly within the Green Belt boundary. The contribution of the site to the purposes of the Green Belt is considered in detail in the Green Belt Technical Report submitted with these representations. For the reasons identified, we consider that the assessment of this part of the Green Belt in the Black Country Green Belt Study [BCGBS] is incorrect. We have provided a more detailed assessment of the contribution of the site in isolation and identify the reasons as to why the site is suitable for Green Belt release and should be allocated for residential development.

Dudley Policies Map

5.12 With regard to the Policies Map for Dudley, Taylor Wimpey objects to the inclusion of land at Clent View Road, Stourbridge within the Green Belt boundary. The assessment of this part of the Green Belt in the evidence supporting the Draft BCP is also considered to be incorrect. Our Technical Report considers this site in detail and identifies the reason as to why the site is

Part 2

5.13 Part 2 of the policy notes that

“For sites that are removed from the Black Country Green Belt and allocated to meet housing,
employment, or other needs through this Plan (as listed in Chapter 13):

a. the design of development will include physical features that define the new green belt boundary in a readily recognisable and permanent way; and

b. compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from the green belt, in accordance with national policy”.

5.14 Taylor Wimpey broadly supports these policy requirements. However, we request clarification on the mechanisms through which the authorities expect compensatory improvements to be delivered (e.g. through financial contributions, improvements on neighbouring land etc.) and would suggest that this information is provided in the policy. The BCP Viability Study (May 2021) indicates that a cost of £1,000 per unit has been included to account for Green Belt loss
mitigation and we also request clarification as to how this cost has been derived.