Policy GB1 – The Black Country Green Belt

Comment

Representation ID: 44966

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

5.0 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]
23 ‘Green Belt review note’, Ref: EX39, December 2017
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.
5.11 However, 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
suitable for Green Belt release and should be allocated for residential development.
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.

Object

Representation ID: 45864

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

Comments on: Policy GB1 – The Black Country Green Belt


Nature of comment: Objection


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

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

SUMMARY


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

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

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

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

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

Comment

Representation ID: 45884

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst we recognise the constraints of accommodating the majority of the Black Country’s housing needs within the existing urban area, from a transport perspective these locations are almost always more suited for new development – where good public transport serves high-volume corridors and the provision of consumer amenities are close to where they live and work. While the impact of new development will continue to have a significant (and often detrimental) impact on existing networks, as evidenced in numerous studies including the Walsall to Wolverhampton Corridor Study, it is vital the transport measures proposed, mitigate against any negative transport impacts – especially those which further reduce the viability or attractiveness of alternatives to private car usage.

Unfortunately, from the above corridor study findings together with PRISM outputs, the proposed infrastructure improvements for this corridor appeared to do very little to offset the increase in travel demand or affect positively, travel behaviours in the area. Therefore, an increase in car mode share and a decrease in bus, walking and cycling mode shares was predicted by the study, with any new development planned only exacerbating existing transport issues in the corridor.

With this in mind, it is only where no other possible sites are available should sustainable urban expansions of greenbelt land be explored and TfWM will continue to work alongside the Black Country authorities to fully understand the levels of sustainable transport provision, alongside the necessary mitigation measures required to support such proposed growth.