Development Allocations

Object

Representation ID: 19249

Received: 07/10/2021

Respondent: Mr William Snowden

Re site WAH 253.
1. Any incursion into or reducing the green belt should be avoided while brown field and former industrial sites remain unused. Green space should remain untouched to combat the climate crisis and urban sprawl.
2. WAH 237 is productive arable land. British food self sufficiency has fallen from 78% in the mid-1980s to 60% now. Nationally and locally we should not be destroying this valuable local asset and adding to the issue of food miles.
3. The developments will increase demand on existing services in Aldridge. Medical services and schools are already operating under pressure of numbers. Local shopping and parking facilities such as the shops at Lazy Hill Road / Walsall Wood Road are extremely limited.
4. The proposed extension of gravel and mineral prior to the land being developed for housing would cause noise and disruption to local residents and turn a residential area into an industrial one.
5. The transport of sand and gravel would mean a high volume of heavy vehicles on Lazy Hill and Stonal Roads, both roads are inappropriate for this. Until recently lorries going to and from the landfill site on Chester Road used both Lazy Hill and Stonal Road causing constant erosion of the surface and a safety hazard so that the local authority had to impose a weight limit which is still in force.
6. Both roads have a high proportion of traffic and are used as rat runs in particular Stonal Road would see a massive increase in traffic.

Object

Representation ID: 19260

Received: 11/12/2021

Respondent: Mrs Ruth Long

I STRONGLY OBJECT to the proposed plans for the development of the new large housing
sites BOTH alongside and opposite Links Side Way, Aldridge W59,SHT. I [REDACTED- GDPR] chose to buy our home as it was surrounded by Green Belt and open space.
Housing should be developed on Brownfield Site first and foremost before destroying Green Belt. It is not just about protecting Green Belt, it 5 about promoting regeneration on derelict and Urban Sites in the Black Country first!! \We are constantly being told on TV programmes
such as "Countryfile" to plant trees to promote a cleaner environment and to grow plants to attract bees/wildlife into our gardens. YET, in Aldridge there are proposals for YET MORE housing developments in the future!! Hence, reducing the clean air in our postcode and destroying
both wildlife and valuable farmland.
During the last 10 years we've experienced a HUGE INCREASE in SPEEDING traffic along
Stonnall Rd/ Birch lane crossroads. The prospect of YET MORE traffic(despite the proposed widening of the
afore mentioned roads) simply horrifies us!!! Since living here several traffic accidents have occured at the Chester Rd/ Birch lane crossroads. We can only foresee this getting worse with the INCREASED future traffic from the propose future large housing sites!!! Subsequently, a HUGE increased in pollution as well!! To conclude briefly my other major concerns are:-
Reduction of already limited parking in Aldridge around the Shopping Area
• Increased traffic on roads around the school runs/ rush hours.
· The extraction of sand and gravel before development.

Object

Representation ID: 19289

Received: 08/10/2021

Respondent: Mr Roy Mason

Site reference WAH234 (Columba Park - Aldridge Rd) WAH 246 (Chester Road)

Traffic congestion, lack of facilities (shops & schools)

Object

Representation ID: 19315

Received: 04/10/2021

Respondent: Mr & Mrs S. Maurice & Gillian Rigby

Number of people: 2

Black Country Plan [WAH240/WSA2]

Proposed House Building on Green Belt Land, Shelfield

We are alarmed to hear of proposed house building near the school in Shelfield on green belt land!! We had no idea that this was going to happen.
If this goes ahead, it opens the floodgates for the use of valuable green belt around Walsall Wood.
We have already had lots of house building in this area over the last few years. In the original unitarian plans for this area, the green belt land between Shelfield and Walsall Woos was to be left as buffer land between the area.
We have already had the large tip in Walsall Wood and to lose the small amount of green belt land would be detrimental to the environment and wildlife due to the loss of trees etc..
Also, due to the number of extra house building sewage plant in Green Lane Walsall Wood, due to collapse of the sewer pipes and the subsequent escape.
Consideration should be given to many areas of derelict land around the Black Country before using our green spaces.

Object

Representation ID: 19327

Received: 05/10/2021

Respondent: Mr Steven Ames

As a resident of Reedswood I strongly oppose the plans to develop the following:-
Pouk Hill Close Urban Forest
The Old Golf Course Reedswood Park
My partner walks our dog, [redacted - sensitive information] every day at Pouk Hill Urban Forest.
If this land was to be developed the amount of wildlife lost would be huge, plus the vital trees which reduce carbon and noise pollution from the M6 motorway.
We have a duty of care to green spaces for the future.

Object

Representation ID: 19706

Received: 08/10/2021

Respondent: Mr Malcolm Caine

The following comments apply to Walsall Local Authority, Streetly Ward.

Every planner should well know the reasons why land was designated as “greenbelt”. Those reasons have not changed, in fact they are even more apposite now than ever before. This land is sacrosanct and must never be developed.

On the land marked on the plan as WAH 234 and bounded by Doe Bank Lane, Queslett Road East, and
Aldridge Road, Streetly, it is proposed to build 960 homes.This cannot be allowed as Streetly is full. Full of houses, full of people, full of cars. If there is any doubt about this, try enrolling a child at a local school, try registering a family at a local GP practise, try parking a car at a local railway station after about 7.00a.m. They are all full.

960 new homes would mean at least 960 extra cars on the roads leading to more pollution and the
emission of more carbon dioxide. If only half the houses had one child, that would need the provision of 480 extra places in our existing schools, which are already full. To build this number of dwellings on this land without the necessary extra infrastructure in terms of of new schools, surgeries, hospitals and improved transport links etc. etc. Is totally unacceptable.

With reference to the land bounded by Chester Road, the railway line to the east, and Pacific Nurseries on their northern side, the same objections apply as for WAH 234. Chester Road is overloaded with traffic especially during rush hour. There are no schools nearby, and no GP surgeries, in a word; no infrastructure, and therefore unsuitable for development.

With reference to the two smaller pieces of land in Streetly, one to the north of the junction of
Wood Lane and Foley Road West and the other bounded by Chester Road, Windermere Drive and the
railway line, adjacent to Pacific Nurseries on their southern side, this is nothing more than blatant backland development. There has been an enormous amount of this in Streetly in recent years.For example the former Cutler’s Garage site, the former Satterthwaites site, the former Buccaneer public house site and the construction of Centurion Drive, all off Chester Road, to name but a few. As noted above, Streetly is full. We do not need more housing in this area.

The latter of the two sites mentioned above includes Hingley’s Covert, an area of mature woodland. To destroy this would be an act of folly, especially as it is well known that trees absorb carbon dioxide - a much needed property in the campaign to reduce global warming. To cut down trees and replace them with cars would deliver a double negative blow to this campaign, and must not be allowed.

Finally, the answer to the housing shortage is surely not to fill in every crook and cranny, willy nilly, be it green or brown, but to build new towns with a finite size. This could be defined in terms of land area or population numbers. This would allow for the provision of all the necessary infrastructure at the planning stage. When such a town became full, that would mean the end of all
development and another new town built somewhere else. If this scheme were adopted, it would mean
that any brownfield sites, such as the former petrol station on Queslett Road East, could be returned to the greenbelt. Now that would be something!

Object

Representation ID: 19726

Received: 04/10/2021

Respondent: Mrs Georgina Armstrong

I love Pelsall and love having green spaces to walk and enjoy during lockdown it has been a life saver for many.

I wish to save our green belt and oppose the green belt development and switch to a brownfield first approach when looking for future development sites.

Object

Representation ID: 19732

Received: 07/10/2021

Respondent: Mrs Gillian Witchalls

WAH 242 & WAH 233 etc
As a local resident and regular user of Walsall's premier park the wonderfull Arboretum, and also a regular walker in the surrounding countryside and canalside. I strongly object to the proposal to destroy this Green Belt land that we are so lucky, as urban fold to enjoy on our doorstep. I t is so vital to protect these green spaces for our mental and physical wellbeing, and how would we have survived the last eighteen months without them!
The design of the proposals WAH242 & WAH233 would cause a fragmentation in the precious Green Belt and would destroy the wildlife corridors which support so much diverse wildlife - many birds which are listed on the RSPB red list, and destroy the hedgerow network.
What happened to the 'Brownfield first' policy
I think I can guess

Object

Representation ID: 20042

Received: 11/10/2021

Respondent: Rt Hon Valerie Vaz

Re: Draft Black Country Plan July 2021 (the Draft Plan)
I have the following comments to make on the Draft Plan:
2 Evidence

The draft Plan indicates that the Government have provided the figures for housing need and yet this has not been broken down into the types of household.

The need in Walsall South is for family homes which are affordable and for social housing.
Currently there is provision for single household dwellings at Tameway Tower a large development in the Town Centre. However, there is no mention of social housing or working with Housing Associations.

The Draft Plan mentions that of the 13,344 new homes required 5,418 will be on land that is currently Green Belt. This means that 40% of the additional homes for Walsall will be built on the Green Belt in Walsall.

This is a huge incursion into the Walsall Green Belt and contravenes current planning law and guidelines.
The plan encourages the unrestricted sprawl of built-up areas, encroachment of countryside abutting the main urban district of Walsall town centre – countryside
which has the biggest social and health benefit and is within walking and cycling distance, proposes inappropriate merging of Pheasey and Streetly, undermines the special setting and characteristics of Walsall Arboretum, and discourages recycling of derelict and other urban land in Walsall and the wider Black Country.

The proposals amount to a continuous erosion of the Green Belt if they become the adopted Policy. There would be no requirement by a developer to provide
evidence that there were very special circumstances for building on the Green Belt.

3 Lack of transparency

As Member of Parliament for Walsall South I have become increasingly concerned about planning matters and planning decision making in Walsall. The recent decision to place a GRT transit site in an unsuitable site in Pleck whilst ignoring suitable sites that are actually designated for development as GRT sites in the SAD (unlike the site chosen) is a prime example.

What the consultation document does not do is shed any light on the ownership of land that is being designated for housing allocation. Much of this is Green Belt land and currently designated agricultural. Designation of this land for housing development massively increases the value of this land at a stroke. The public and other stakeholders should be notified as part of this consultation process about who owns the land subject to such change of use and therefore land value, what connections the landowners may have with councillors, officers, and political parties (such as through donations or membership) in order that the public can draw their own conclusions about such connections if in existence.

It is well known for example that developers land bank Green Belt and agricultural land on the edge of existing built environments in the hope that and even expectation that local planning policy will be changed and their speculative land banking of Green Belt will reap huge dividends for them.

4 Policy

Unlike the other Boroughs’ table of sites which indicate which site is on Green Belt or brownfield, Walsall’s Table 31 Page 506 fails to identify which parcel of land is on Green Belt. This is misleading the public.

The current policy on the Green Belt from the National Planning Policy Framework (NPPF) states:
137 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.

138. Green Belt serves 5 purposes:
(a) to check the unrestricted sprawl of large built-up areas;
(b) to prevent neighbouring towns merging into one another;
(c) to assist in safeguarding the countryside from encroachment;
(d) to preserve the setting and special character of historic towns; and
(e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

To include and redraw the Green Belt in the current draft plan contravenes the NPPF.

The narrative for Walsall does not set out why those tests should be overridden and once they are in the plan, there would therefore be no need to be any justification at the planning permission stage that there are very special circumstances to justify building on the Green Belt.

Moreover the sites that are suggested are either on or near Sites of Local Importance for Nature Conservation SLINC and/or agricultural land. The policy document is silent on more efficient use of this land for local agricultural and community purposes.

Conclusion

For all those reasons, and the fact that many constituents have contacted me with serious concerns and objections, I would submit that the land identified as follows should be removed from the draft plan:

• WAH242 Calderfields West (breaching s138 (a) (c) (d) as it adjoins Walsall Arboretum, and (e)
• WAH 234 Land by Doe Bank Lane/Queslett Road (breaching s138 (a) (b) as Streetly and Pheasey would be merged (c) and (e)
• WAH 231 Land off Sutton Road/Longwood Lane (breaching s138 (a) (c) and (e)
• the other smaller sites identified and located on the Green belt.

Object

Representation ID: 20988

Received: 10/01/2022

Respondent: Miss Joanne Bevan

I am responding as a resident in close proximity to the sites of Grange Crescent, Fordbrook Lane, Mob lane, Coronation Road,Green Lane all in Shelfield but my objections go further to the surrounding areas of Rushall, Walsall Wood.

• I have myself witnessed on the Green belt land in Grange Crescent and on the fields at the back of Fordbrook Lane an array of wildlife which includes Bats, Hedgehogs, Buzzards, Kingfishers, Woodpeckers, Moorhens, foxes and shrews and herons. By building on this area you are not only putting at risk protected species but taking away the natural habitat and natural food sources and importantly we have bees.
• The local schools are already over occupied. Data taken from https:// www.get-information­-schools.service.gov.uk/. We do not have the capacity for additional young families in affordable housing.

Junior Schools Capacity Occupancy
Pelsall Village 315 302
Ryders Hayes 540 474
St Michaels 315 418
Rushall 250 257
St Francis 210 202
Greenfields 289 283
1919 1936

• There are already traffic issues along Fordbrook Lane due to work/school traffic. Hawthorn road is used as a cut through from the A461Lichfield Road to and from Pelsall/Rushall and is often subject to racing vehicles. (numerous occasions requests have been made to the council for traffic calming measures and nothing is done). To name but a few of the traffic issues.
• Brownhills and Walsall are both run down with empty shops, neither have encouraged new businesses and there is no indication of anything changing.
• Police friends have already indicated that there are months delays in responding to crimes which goes currently unpunished/prosecuted , increase in affordable housing is not going to improve this, but will just increase the crime rates for a police force who are obviously under manned.
• There is already a waiting time for GP appointments, additional housing will not improve this and although GP's get funding based on the number of patients registered to them, health care in the community is worsening and people are forced to use A & E's in a trust already with extremely poor performance.
• Shelfield and Pelsall alone has a population of 24k. Our green belt land is not only a source of exercise but a source of access between shelfield/ Pelsall/ Brownhills and further. It is an important part of our mental wellbeing. (Walsall does not have the capacity for additional mental health needs)
• Unfairly unproportionately high allocation of release of Green Belt land in Walsall. If we wanted to live in a concrete jungle we would have moved to Birmingham .
• The first point of the Black Country Well-being Strategy is:
"The Black Country's Health and Wellbeing Strategies identify the following as key priorities for tackling health and wellbeing:
a) Healthy lifestyles including physical activity, healthy eating, and addressing tobacco and alcohol consumption and obesity; "
This cannot be done by taking high proportions of Green Belt Land away.
• Noted also in the plan:
"a) Industry and warehousing (E(g)(ii), E(g)(iii)), 82 and 88 use)
b) Motor trade activities, including car showrooms and vehicle repair
c) Haulage and transfer depots
d) Trade, wholesale retailing and builders' merchants
e) Scrap metal, timber and construction premises and yards
f) Waste collection, transfer and recycling uses as set out in Policy W3."

There is a national shortage of HGV drivers, large haulage companies have not encourage newly qualified drivers while they have been able to get cheaper labour from abroad, this shortage has been happening for decades, not only since Brexit. The above types of industry highlighted in the plan are all very dependent on HGV and not a broad enough spectrum to get working families into Walsall.
• Already only two-thirds of working-age residents in Walsall are in employment, and for those in work, earnings are below the national average while testing economic conditions prevail. None of this information is a picture of a flourishing economy with in Walsall.
• Walsall is already struggling, it is crime ridden, with closed shops, with a poorly manned police force and unpunished crimes. The only reason I am still a resident of Hawthorn Road is because of the surrounding Green Belt Land. If the intention is to remove this then Walsall will have one less resident. Walsall Council needs to come up with a strategy to improve all services
for the existing population and get that right.

Object

Representation ID: 21190

Received: 11/10/2021

Respondent: Mr John Embrey

Objection to Black Country Plan in General and please see attached sheets for objections to 1 site in particular.

Local Authority - Walsall Council

As a resident of Middlemore Lane West, Aldridge WS9 SOR, I wish to raise the following objections to the Black Country Plan 2021, as outlined below.

Several residents have been in contact with local MP Wendy Morton and Walsall Councillor John Murry
about this matter since it was raised during the Covid-19 restrictions in 2020. Assurances have been given in writing, there will be no building in Aldridge on the Green Belt land, this has been reiterated today by the Prime Minister and supported by the Mayor of West Midlands, Andy Street, that building on green-belt land is now not on the Governments agenda.

The wedge of green belt land on the junction of Middlemore Lane West and Bosty Lane, which is
bounded by Daw End railway cutting, is unsuitable for development for the following reasons: -

1. The site is adjacent to a Site of Special Scientific Interest (SSSI,)please see attached Defra plan below.
This is an ancient site as documented on Walsall Council's website, please see -
https://go.walsall.gov.uk/parks and green spaces/conservation and the environment/sites of
special scientific interest sssis/daw end railway cutting

'The old quarry and railway cuttings at Daw End provide excellent exposures on Wenlock Shale {Coalbrookdale Formation) and the overlying Wenlock Limestone which were deposited during the Silurian Period about 410 million years ago.
These are the best exposures available in Britain for this particular group of rocks. During deposition of the Wenlock Limestone marine organisms grew in patches on the sea bed trapping sediment and forming low mounds or reefs. These patch reefs are well seen in the Wenlock Limestone at this site. This is an important geological locality for the study of the Wenlock Series in
Britain.

2. Any development on this important sensitive site would comprise the existing delicate eco­ structure and be extremely detrimental to the wildlife and to the historic flora and fauna of the site and area generally.

3. Heavy industrial goods traffic on the roads bordering the site, makes access to the site difficult. Access to the Middlemore Lane Industrial estate from Bosty Lane is restricted and can only be accessed by a single-track bridge. This already causes significant tailbacks along the section of Middlemore Lane West onto Bosty Lane.
Furthermore, the use of this route by heavy goods traffic is set to increase when the proposed Council recycling centre on Middlemore Lane opens.

4. The junction of Middlemore Lane West and Bosty Lane has been the cause of numerous serious
accidents, with some incidents involving the deployment of the air ambulance service. Development on this site will increase traffic at this junction and would be likely to create a high number of incidents without significant improvements to the highway, including the potential to construct a new double-track road bridge over the railway.

5. The development of this green belt site will create additional environmental air pollution and exacerbate the existing noise pollution from the container base.

6. Very limited public transport services in the area, with the local bus service providing a­ maximum service of two busses per hour. There are currently no public rail links in the area.

7. The green belt creates an important natural division-between the parishes of Aldridge and Rushall and prevents coalescence. This land provides a much-needed haven for wildlife, and currently includes a haven for several horses which graze the pasture and provides a buffer zone to the SSSI.

Object

Representation ID: 21213

Received: 05/10/2021

Respondent: Martin Hudson

Dear Sir or Madam,
Whilst I accept we have an ever growing population, there appears to be a nationwide epidemic of building on
- and destroying - our precious green belt leaving much reduced open space for our leisure and enjoyment.
I am totally opposed to building of any sort on any green belt anywhere and more especially in Walsall where I live; there are plenty of brown field sites which could and should be used instead.

I wish to make specific objection to the proposed building at the three [text I bold] following sites, firstly for the principle of reducing the local green belt amenity and secondly because of local infrastructure issues which are already at breaking point, before any new build is considered:

3) The green belt of land at the rear of Wood Lane / Foley Road West, Streetly may not be as visible as the two sites above but should not be built on and again creates infrastructure issues

As well as it being totally wrong to build on green belt when there is more than sufficient brown belt, there is insufficient infrastructure to support existing residents today, before 5418 new properties are considered.
Here I refer to insufficient Medical Facilities (i.e. doctors, medical service provision), schools at all key stages and the further overcrowding of our busy, blocked highways.

I totally object to the above three local green belt building proposals. I would strongly urge you to re-consider these sites and ask you to concentrate your searches on far more suitable brown field sites before our green spaces are lost forever and are totally concreted over.

Support

Representation ID: 21237

Received: 11/10/2021

Respondent: Newlands Developments

LAND SOUTH OF BENTLEY LANE, WALSALL
RESPONSE TO DRAFT BLACK COUNTRY PLAN 2039 (REGULATION 18) CONSULTATION

Newlands Developments Limited have prepared these representations on behalf of the landowner in relation to land south of Bentley Lane, Walsall (hereafter referred to as ‘the Site’). Newlands Developments welcome the opportunity to be involved in the preparation of the Black Country Plan, and it is within this context that they wish to make representations to the Regulation 18 Consultation.

The Site is shown outlined in red on Drawing 21501 F0004 B (Appendix 1) and is located to the west of Walsall in close proximity to M6 Junction 10. It extends to 11.2 hectares and has the potential to deliver an employment development (Use Classes E(g)(ii), E(g)(iii), B2, and B8) in a sustainable location.

The Site is deliverable, available and suitable for release from the Green Belt to deliver a high quality employment development that will significantly assist in meeting the Black Country’s identified employment land needs, as well as the unmet need from the Functional Economic Market Area, including Birmingham and South Staffordshire.

The Vision, Strategic Objectives and Strategic Priorities (Section 2)
The Vision
The Black Country Authorities have set out a vision for the Black Country up to 2039. We support the vision, in principle, which seeks to create a prosperous, stronger and sustainable Black Country. This vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8.

Strategic Objectives
We have reviewed the strategic objectives and strategic priorities set out in Table 1 (Black Country Plan – Objectives and Strategic Priorities) of the draft Plan. We are supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Core Strategy was adopted in 2011, particularly in relation to climate change, health and wellbeing, promoting sustainable transport, enhancing the natural and built environment, and meeting infrastructure needs It is considered that an employment development at the Site would align with these Strategic Objectives, especially Strategic Priority 7, which aims to provide a balanced portfolio of employment sites and to protect and enhance existing sustainable employment areas to support the development of key employment sectors and enable existing businesses to expand. We consider that the Site, which has the capacity to deliver an employment (industrial and/or logistics) development of up to 11.2 hectares in a sustainable location, would assist the Black Country Authorities in achieving this Strategic Priority and would support the diversification of the Black Country economy.

Spatial Strategy (Section 3)
The Spatial Strategy is set out in Draft Policies CSP1, CSP2, CSP3 and CSP4, and illustrated on the Key Spatial Diagram (Figure 2), which provides the overarching basis for the Plan’s proposals for growth and infrastructure improvements. We are supportive of the Key Spatial Diagram, as this accords with Paragraph 23 of the NPPF, which requires broad locations for development to be indicated on a key diagram, and land-use designations and allocations identified on a policies map.
The Site, located in Walsall, is identified on the Key Spatial Diagram as an employment development site (EMP1) located within a Core Regeneration Area (CSP2).

Development Strategy
Draft Policy CSP1 (Development Strategy) provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039. Part 1 of this policy seeks to deliver at least 355 hectares of employment land. Part 2 explains that the spatial strategy seeks to deliver this by focusing growth and regeneration into the Growth Network that comprises the Strategic Centres and Core Regeneration Areas. We are supportive of this policy, which seeks to direct growth to the most sustainable locations and to sites which have been assessed as most suitable by the Black Country Authorities’ site selection process and as part of the Sustainability Appraisal (SA).

The Development Strategy, set out under Draft Policy CSP1, has been developed through a comprehensive assessment of a range of alternative options, as set out in the Spatial Options Paper. The SA also includes an assessment of eleven spatial options identified by the Councils. Each option has been assessed for its likely sustainable impacts.

The Preferred Spatial Option selected is Option J (Balanced Growth), which focuses growth within existing Strategic Centres, Core Regeneration Areas and Towns and Neighbourhood Areas in the sub-region. The strategy takes advantage of their existing infrastructure capacity, in addition to a limited number of new growth areas near to the edge of settlements that take account of environmental, climate change, accessibility and socio-economic requirements. Spatial Option J ensures that development within the Green Belt is only located in the most sustainable locations with good access to help reduce reliance on private car usage. This approach, along with Spatial Option J, is fully supported.

The Site benefits from a sustainable location with good access to surrounding sustainable modes of transport. There are two bus stops located immediately adjacent to the north of the Site along Bentley Lane. From this stop, services connect the Site to Walsall and Wolverhampton with regular 30-minute services seven days a week. The Site’s good public transport links are also important in the context of Paragraph 142 of the NPPF, which identifies that where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land that is well served by public transport.

With regard to the local road network, the Site is located along Bentley Lane, which provides direct links to M6 Junction 10 via Bloxwich Lane, and is suitable for use by HGVs. The Walsall to Wolverhampton Core Regeneration Area is based around the Black Country Route and M6 Junction 10 road corridor, which is located approximately 2km to the south of the Site. This sustainable location, which is also in close proximity to a large labour force, means that it is suitable for high quality industrial and logistics development. It is therefore considered that the Site is suitable and deliverable and could be released from the Green Belt to provide much-needed employment land. This would be in accordance with the aims of the NPPF and would also assist in meeting the employment land need of the District and the unmet needs of the FEMA.

Core Regeneration Areas
The strategic approach for the growth network is set out within Draft Policy CSP2. We are supportive of this policy, in particular Part 4(a) which states that the Core Regeneration Areas linking the Strategic Centres will provide the principal concentrations of strategic employment areas. These are high quality employment areas that will be safeguarded and enhanced for manufacturing and logistics activity to support the long-term success of the Black Country’s economy. Furthermore, Part 4(c) advises that the Core Regeneration Areas will provide the principal locations for new industrial and logistics development: providing 192 hectares of developable employment land to meet growth needs. As noted above, the Site is located within the Walsall to Wolverhampton Core Regeneration Area and has a development capacity of 11.22 hectares.

Green Belt
The Black Country Authorities have undertaken Local Sites Assessment Reports for the proposed allocations, including Land south of Bentley Lane, Walsall (Site Reference SA-0057-WAL). A copy of the Site Assessment Form completed for the Site is included at Appendix 2.

The Site Assessment Form includes a Green Belt assessment of the Site, owing to its location within the Black Country Green Belt. The Assessment identifies that the Site comprises a narrow gap between towns and has urban edges on two sides and urbanising influences to the west. It concludes that the release of this area from the Green Belt would only weaken the contribution of land to the west of the Site, which would not increase overall harm. Furthermore, the Site Assessment Form goes on to state:
“The Site is considered more suitable for employment uses rather than residential uses and is also one of only a few sites identified by the EDNA (the Black Country Economic Development Needs Assessment) as being suitable for employment.”

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.

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. An Economic Development Needs Assessment (EDNA), which provides an objective assessment of the industrial land needs for the Black Country against the area’s economic development needs, was prepared for the Black Country during 2016/17. This Assessment identified that there was a potential shortfall in employment land over the Plan period of between 283 hectares (against baseline growth scenario requirements) and 563 hectares (against most likely growth scenario requirements). A Black Country EDNA update (EDNA2, 2021) has been produced by WECD Consultants to update employment land demand estimates presented in the 2017 EDNA1, to inform the objective assessment of employment land needs for the Black Country to 2039. The EDNA2 (2021) notes that there have been some significant changes in the use of employment space since the publication of EDNA1, particularly in the last 18 months. Whilst manufacturing remains an important sector for the Black Country Economy, the COVID-19 pandemic has fuelled e-commerce, resulting in increased demand for logistics space requirements, including last mile facilities in close proximity to large urban populations. Accordingly, there is now projected to be an undersupply of employment land of between 148 hectares and 168 hectares.

The EDNA2 (2021) has estimated that the potential loss of employment land over the Plan period would be 62.7 hectares based on the detailed review of employment sites (including losses to residential uses and other alternative forms of development for employment spaces in the Black Country). Allowance for this loss will need to be considered for the future provision of employment space in the Black Country, bringing the level of employment land requirement in the Black Country to 30-31ha per annum over the next planning period (equivalent to between 212 and 232ha). This represents 37% of employment land need arising in the Black Country that cannot be met solely within the Black Country.

The Black Country Urban Capacity Review Update (May 2021) also concludes that, at this stage, a significant shortage of employment land will remain. This is after consideration of the potential for additional sources of employment land to meet the shortfall, such as current non-employment allocations which have not yet been developed for the alternative use, intensification of existing sites, any vacant land, and contributions from outside of the Black Country (for example, within South Staffordshire and Shropshire). It concluded that these potential sources will not fully accommodate the need for employment land and the gap in supply will remain significant in scale. Consequently, 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”.

However, 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.

With regard to making as much use as possible of suitable brownfield sites and underutilised land, the Urban Capacity Review Update (2021) identifies that the only additional sources of employment land supply within the Black Country urban area, which are not identified in the EDNA, are:
• • ‘Land within the urban area that is currently allocated for development for non-employment uses – in the main housing- but not yet developed for that use. This land is currently either occupied by employment uses and has scope for intensification, or vacant land that could be used for new employment uses in the future.
• • Additional employment land within existing employment areas – either through the intensification of existing under-occupied employment sites or land that is either currently vacant or may become vacant over the Plan period.’

The Urban Capacity Review identifies that 488 hectares of occupied employment land was allocated for housing within Black Country Authority Area Action Plans and Site Allocations Documents. This land was allocated on the basis of it being assessed to be of low quality in terms of its sustainability for employment uses in the long term and the future investment intentions of the businesses who occupied it.

As part of the evidence base work for the Black Country Plan, a Black Country Employment Area Review (BEAR) has been prepared, which has been informed by a landowner engagement exercise (as noted in the Landowner Engagement Exercise Technical Report (August 2021)). The BEAR seeks to identify the current intentions for existing employment sites and business needs to inform the Black County Plan approach on the protection and retention of employment land. The report reviews the extent to which existing housing allocations involving the redevelopment of employment land should be deleted, with those sites retained for employment activity.

The BEAR has concluded that many of the occupied employment sites currently allocated for housing contain businesses which have either invested in their premises and/or intend to remain in situ in the long term, and specifically throughout the new Plan period. In addition, the BEAR notes that the re-allocation of employment sites to housing would impact negatively on the ability of the Black Country to provide sufficient employment land to meet its identified needs, as any employment land lost to alternative uses would need to be replaced elsewhere and added to the land requirement. Therefore, the BEAR strongly suggests that these sites should be retained for employment uses and current housing allocations deleted through the Black Country Plan review. The EDNA2 (2021) also identifies a requirement for a net increase in employment land over the new Black Country Plan period, which is likely to require the retention of more existing employment land than previously anticipated.

In terms of optimising the intensification of existing sites and maximising the development of under-utilised buildings, the Urban Capacity Review recognises that there are likely to be some additional opportunities for intensification and redevelopment within existing employment areas that were not identified in the EDNA. However, it is anticipated that any new allocated sites are likely to be limited and small in scale, potentially contributing up to 50 hectares of additional employment land. Further recycled land may also come forward as ‘windfalls’ over the Plan period. It must also be acknowledged that increasing site densities, as part of intensification, can make sites less attractive to the market in certain sectors, for example, due to inadequate yard space/depths that precludes operational efficiency.
With regard to discussions with neighbouring authorities, further contributions are being explored through the Duty to Cooperate with neighbouring local authorities who share a physical and/or functional relationship with the Black Country. The EDNA2 (2021) estimates a potential contribution of 19 hectares of employment land to be made through Duty to Cooperate arrangements with South Staffordshire. The Shropshire Regulation 19 Local Plan also includes a contribution of 30 hectares of employment land towards meeting needs arising in the Black Country. In addition, there is an estimated contribution from the proposed West Midlands Interchange at Four Ashes of between 72 and 94 hectares. This would equate to a total of 121 hectares of contribution from outside the Black Country, which would mean that the undersupply of employment land requirements to meet market, growth and replacement demand in the Black Country would reduce to between 91 and 111 hectares.

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. Despite this, there remains a significant undersupply of employment land in the area. Therefore, we consider that the Black Country Authorities have demonstrated that exceptional circumstances exist to remove certain areas of land from the Black Country Green Belt to meet employment land needs, including, land to the south of Bentley Lane in Walsall. However, it should be noted that local authorities should not shy away from higher employment land and housing numbers just because Green Belt release will be needed to achieve these numbers. Broader spatial objectives can and should be taken into account to justify higher employment land and housing figures, as demonstrated in the High Court ruling on the three statutory challenges to the adoption of the Guildford Local Plan (in Compton Parish Council & Ors v Guildford Borough Council & Anor [2019] EWHC 3242 (Admin)):

‘"Exceptional circumstances" is a less demanding test than the development control test for permitting inappropriate development in the Green Belt, which requires "very special circumstances." That difference is clear enough from the language itself and the different contexts in which they appear, but if authority were necessary, it can be found in R(Luton BC) v Central Bedfordshire Council [2015] EWCA Civ 537 at [56], Sales LJ. As Patterson J pointed out in IM Properties Development Ltd v Lichfield DC [2014] EWHC 2240 at [90-91 and 95-96], there is no requirement that Green Belt land be released as a last resort, nor was it necessary to show that assumptions upon which the Green Belt boundary had been drawn, had been falsified by subsequent events.’ [70]

This High Court judgment provides clarity on the circumstances under which the exceptional circumstances test can be met. It goes on to state:

“Likewise, at IR80, the Inspector found that land available for additional business development in the Guildford urban area was very limited, and it was unrealistic that much extra capacity could be obtained on existing sites such as the existing Surrey Research Park:

"The ability to meet the identified business needs therefore depends on making suitable new land available and there is no realistic alternative to releasing land from the Green Belt. Exceptional circumstances therefore arise at the strategic level to alter Green Belt boundaries to accommodate business and employment needs.”

We believe the same principles apply here and ‘exceptional circumstances’ are clearly demonstrated in light of the significant shortfall in employment land required.

Infrastructure and Delivery (Section 4)
Strategic Policies should make sufficient provision for infrastructure, as confirmed in parts b) and c) of NPPF Paragraph 20, which states:

“Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for infrastructure for:
b) transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
c) community facilities (such as health, education and cultural infrastructure)”

Draft Policy DEL1 (Infrastructure Provision) of the Draft Black Country Plan emphasises that all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impacts on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area. We are therefore generally supportive of this policy, owing to its conformity with national planning policy.

It is however noted that Part 3 of Draft Policy DEL1 advises that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents and, where appropriate, masterplans:

a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure provision.

Whilst generally supportive of this approach, it is considered that the Site can be suitably delivered without significant upgrades to the supporting infrastructure. We would therefore be grateful to be included as part of any future consultation on the Infrastructure Delivery Plan. Indeed, we would expect the Infrastructure Delivery Plan to support the emerging Black Country Plan through Examination.
Promotion of Fibre and 5G Networks
Draft Policy DEL3 (Promotion of Fibre to the Premises and 5G Network) requires all major developments to deliver Fibre to the Premises (FTTP) capacity/infrastructure to all individual properties or alternatively, non-Next Generation Access technologies that can provide speeds in excess of 30MB per second, where FTTP cannot be delivered. Furthermore, any proposals for infrastructure to support the delivery of 5G networks will be supported, in principle, subject to meeting the requirements of other local policies and national guidance.

We are generally supportive of Draft Policy DEL3, particularly as this aligns with Paragraph 114 of the NPPF, which requires planning policies and decisions to support the expansion of electronic communications networks, including next generation mobile technology (such as 5G) and full fibre broadband connections. However, it is important to note that the promotion of Fibre may not always be practicable or viable in new developments. Criterion (1) is therefore supported insofar as it allows for this requirement to be reduced where it can be clearly demonstrated that it is not practical or viable.

Health and Wellbeing (Section 5)
Draft Policy HW1 (Health and Wellbeing) provides a strategic context for how health and wellbeing is influenced by planning. We are supportive of this draft policy, particularly as it aligns with the requirements of NPPF Paragraph 92 as it aims to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible, and enable and support healthy lifestyles to address identified local health and wellbeing needs.

Part F of Draft Policy HW1 advises that the regeneration and transformation of the Black Country should provide a range of quality employment opportunities for all skill sets and abilities along with the education and training facilities to enable residents to fulfil their potential and support initiatives to promote local employment and procurement during construction.

The development will provide job opportunities during both the construction and operational phases. This will ensure that the development accords with the aims of Draft Policy HW1 in achieving a healthy, inclusive and safe development to address identified local health and wellbeing needs.

The Black Country Economy (Section 7)
Part (a) of NPPF Paragraph 82 makes reference to local authorities having regard to Local Industrial Strategies when setting out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth. The West Midlands Local Industrial Strategy (May 2019) recognises the significant shortfall in employment land across its geography (Page 63) and makes a commitment to implementing a strategic programme of employment land development based on up-to-date, locally-led evidence (Page 65). This supports the allocation of the Site in this sustainable location.

Part (b) of Paragraph 82 requires strategic policy-making authorities to set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the Plan period. In addition, NPPF Paragraph 83 states that planning policies should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries, and for storage and distribution operations at a variety of scales and in suitably accessible locations. The Site reflects the locational requirements of logistics that are described in the Planning Practice Guidance (PPG) (031 Reference ID: 2a-031-20190722) and, in particular, it would be attractive to last mile operators given its excellent access to the wider conurbation. Both the PPG and National Infrastructure Commission’s (NIC’s) ‘Better Delivery: The Challenge for Freight’ Report (April 2019) (see Recommendation 4) make specific reference to the provision of sites for last mile logistics in recognition of the changing nature of the market and boom in ecommerce. This supports the case for designating the Site for employment uses and initial interest has already been received from a number of occupiers looking to invest at this location.

Draft Policy EMP1 (Providing for Economic Growth and Jobs) seeks to ensure a sufficient quantum of development opportunities are provided to meet the demand for economic growth and support the diversification of the Black Country economy. The Black Country Authorities will seek the delivery of at least 355 hectares of employment land within the Black Country, in Use Classes E(g)(ii), E(g)(iii), B2, and B8 between 2020 and 2039: mostly through sites allocated for development in the Plan. This includes 164 hectares in Walsall. The Site is identified on the Employment Key Diagram as an Employment Development Site and will thus be safeguarded for employment uses within Use Classes E(g)(ii), E(g)(iii), B2, and B8, as noted within Part 4 of Draft Policy EMP1. We are supportive of this draft policy which aligns with the aims of NPPF Paragraph 82.

Improving Access to the Labour Market

Draft Policy EMP5 (Improving Access to the Labour Market) requires planning applications for new major job-creating development to demonstrate how job opportunities arising from the proposed development will be made available to the residents of the Black Country, particularly those in the most deprived areas of the sub-region and priority groups. Furthermore, Part 2 of Draft Policy EMP5 goes on to state that planning conditions or obligations will be negotiated with applicants and applied as appropriate to secure initiatives and/or contributions to a range of measures to benefit the local community, including the potential for working with local colleges and universities, to ensure:-

a) The provision of training opportunities to assist residents in accessing employment opportunities;
b) The provision of support to residents in applying for jobs arising from the development;
c) Enhancement of the accessibility of the development to residents by a choice means of transport;
d) Child-care provision which enables residents to access employment opportunities;
e) Measures to assist those with physical or mental health disabilities to access employment opportunities.

We are generally supportive of this approach as it looks to ensure that development proposals for employment generating uses meet the needs of local residents. However, it is noted that there is no information available as to the level of financial contributions which will be sought as part of development proposals. We would therefore be grateful if the Council could provide further details of the contributions which will be sought as part of any future consultation. Whilst it is important to ensure that development proposals meet the needs of local residents, this cannot result in schemes becoming unviable.
Transport (Section 9)
Draft Policy TRAN1 (Priorities for the Development of the Transport Network) advises that key transport corridors will be prioritised through the delivery of infrastructure to support active travel (walking, cycling), public transport improvements, traffic management (including localised junction improvements) and road safety. Part 4 of Draft Policy TRAN1 also emphasises that key transport priorities identified for delivery during the lifetime of the Black Country Plan currently include M6 Junction 10 and key road corridors, including the A454.

Linked to the above, Draft Policy TRAN4 (The Efficient Movement of Freight) also encourages road-based freight to use the Key Route Network whenever practicable. In addition, Draft Policy TRAN4 advises that junction improvements and routeing strategies will be focused on those parts of the highway network evidenced as being of particular importance for freight access to employment sites and the motorway network. We strongly support Draft Policies TRAN1 and TRAN4, especially as the ongoing investment and improvement of committed transport priorities and projects, including to M6 Junction 10 and the Black Country Route (A454) which are located approximately 2km to the south of the Site, reinforces the suitability of the Site for a high quality employment development as it will be adequately serviced by a variety of travel modes. These transport improvements will support the scale of growth proposed at the Site and within the wider Core Regeneration Area, and will also facilitate improved access to the Site for local communities.

Paragraph 113 of the NPPF advises that all developments that will generate significant amounts of movement should be required to provide a Travel Plan, and the application should be supported by a Transport Statement or Transport Assessment so that the likely impacts of the proposal can be assessed. As such, we are supportive of Draft Policy TRAN3 (Managing Transport Impacts of New Development), which is consistent with NPPF Paragraph 113, emphasising that Transport Assessments and Travel Plans produced by developers are essential to demonstrate that an acceptable level of accessibility and safety can be achieved using all modes of transport to, from and through the development.

Draft Policy TRAN5 (Creating Coherent Networks for Cycling and Walking) also encourages new developments to create an environment that encourages sustainable travel via safe and direct links that connect to existing walking and cycling networks, and good walking and cycling links to public transport nodes and interchanges. We are generally supportive of this policy as it accords with the requirements of Paragraph 110 of the NPPF, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users.

Parking

Draft Policy TRAN7 (Parking Management) identifies that the Black Country Authorities will ensure a consistent approach to maximum parking standards is enforced in new developments, as set out in supplementary planning documents.

Whilst it is considered important to promote sustainable transport methods as part of new developments, the provision of parking is critical to the success of logistics schemes. Indeed, where a logistics development is in operation for 24-hours a day, it can mean a shift change takes place overnight where public transport is either limited or not available.

a. achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than this that is required under new national planning policy or building regulations; and, in addition
b. incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion.

We would therefore recommend that draft Policy TRAN7 is amended to confirm that maximum parking standards would not relate to logistics developments.

Environmental Transformation and Climate Change (Section 10)

Biodiversity Net Gain
NPPF Paragraph 32 advises that Local Plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Moreover, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

As such, it is considered that draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) is not consistent with national policy as it requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The NPPF places no requirement on development proposals to deliver a notional target of a 10% net gain. It is therefore considered that draft Policy ENV3 should be amended to simply require all development proposals to achieve a biodiversity net gain.

Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. Part 1(d) of Draft Policy ENV9 is of particular relevance to employment developments as it encourages developments to consider crime prevention measures and Secured by Design Principles. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards.

Climate Change

Policy CC2 (Energy Infrastructure) identifies that development proposals would need to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Such an approach is supported, given that the policy suitably reflects that opportunities for decentralised energy provision may not always be appropriate or viable.

Policy CC7 (Renewable and Low Carbon Energy and BREEAM Standards) identifies that major development must:

With regard to BREEAM Standards, Part 6 of Draft Policy CC7 requires all new non-residential developments greater than 5,000 sqm gross to meet BREEAM Excellent Standards, unless it can be demonstrated that achievement of the standard would make the proposal unviable, through submission of an independently assessed financial viability appraisal. Draft Policy CC7 is therefore generally supported as it notes that achieving BREEAM excellent may not always be a viable option.
Sub-areas and Site Allocations (Section 13)
The strategy for Walsall is set out at Paragraph C.8 in Chapter 13 of the draft Black Country Plan, which is as follows:

“In the future, Walsall will be a more confident place, with renewed investment in key infrastructure and key centres, greater opportunities for work and leisure and an affordable, accessible housing stock.”

We are supportive of this strategy and consider the delivery of the Site will help this to be achieved, particularly as the development will comprise an employment development which will generate direct and indirect jobs in construction and direct local employment opportunities when operational. The development will be sustainable in accordance with the strategy proposed for Walsall.

Walsall to Wolverhampton Core Growth Area
At Paragraph C.26 of Chapter 13, the Draft Plan defines the Walsall to Wolverhampton Core Regeneration Area as being located around the road, rail and waterway corridor, with the Black Country Route linked to M6 Junction 10, the re-opened railway stations at Darlaston and Willenhall, and the Wyrley and Essington Canal which provides a pedestrian, cycle and leisure route from Birchills, through Walsall Strategic Centre, Phoenix 10 and Darlaston to Moxley.

Paragraph C.26 goes on to state:

“Much regeneration has already taken place in this area, and many new homes and jobs are expected to be delivered in the future at key locations such as Phoenix 10, Bentley Lane, Moxley Tip and in Willenhall Town Centre. The Core Regeneration Area will continue to be the focus of public sector investment to regenerate brownfield sites” [Our emphasis].

We strongly support the strategy for the Core Regeneration Area and consider that land south of Bentley Lane can contribute to the aims for this area. As noted in Table 36 (Walsall Sites Allocated for Employment by Black Country Plan Policy EMP1), the Site (BCP Site Ref. WAE404 ‘Lynx / Beatwaste Site, Bentley Lane) has the capacity to deliver up to 11.22 hectares of employment land. In addition, Table 36 anticipates that such development can be delivered within the Plan period (i.e. by 2039).

Notwithstanding the above, we note that the Site is referred to as ‘Lynx / Beatwaste Site, Bentley Lane’ within Table 36. However, the Site Assessment Form refers to the Site as ‘Land to the South of Bentley Lane, Willenhall, Walsall.’ We can confirm that the Site should simply be referred to as ‘Land south of Bentley Lane’, to avoid confusion.

Summary
We would be grateful if you could consider our comments and make the requested changes, and that we are kept informed of the next stages of the Local Plan’s preparation. In the meantime, if you have any queries, then please do not hesitate to contact me.

Support

Representation ID: 21285

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

DRAFT BLACK COUNTRY PLAN 2039 - REGULATION 18 CONSULTATION
LAND OFF BOSTY LANE, ALDRIDGE
Thank you for inviting comments on the Regulation 18 Pre-Submission Draft Black Country Local Plan. We respond on behalf of Owl Homes in respect of their land interests at Land off Bosty Lane, Aldridge (the ‘Site’). Owl Homes are a modern, privately-owned property developer specialising in the delivery of sustainable, high-quality homes.

The Site is identified as a residential site allocation: Middlemore Lane West, Aldridge (WAH233) for 35 dwellings within the Regulation 18 Draft Black Country Local Plan. The draft allocation would result in the Site being removed from the Green Belt. A Site Location Plan is attached at Appendix 1 and our Vision Document is at Appendix 2.

Taking into account the guidance provided in the National Planning Policy Framework (NPPF, July 2021), it is considered that there are exceptional circumstances that warrant the Site’s release from the Green Belt, and we are accordingly supportive of the Council’s decision to propose the Site’s release from the Green Belt and allocate it for housing development.

It is noted that the current Development Plan is comprised of the saved policies and maps from the Walsall Unitary Development Plan (UDP)(2005), the Black Country Core Strategy (BCCS)(2011), the Walsall Town Centre Area Action Plan (AAP)(2019) and the Walsall Site Allocations Document (SAD)(2019). Upon adoption, the Black Country Plan will replace the BCCS (2011) and significant elements of ‘Tier 2’ plans in the form of Area Action Plans and Site Allocations Documents. It is anticipated that the Black Country Plan will be adopted in April 2024, subject to independent examination.
The National Planning Policy Framework (NPPF) sets out the key plan-making framework and ‘tests of soundness’ for Local Plans (Paragraph 35). The National Planning Practice Guidance (NPPG) provides further advice on how these tests can be met, for instance in terms of evidence base gathering and working collaboratively with other relevant bodies on strategic planning matters.

It is understood that it is intended to submit the Black Country Plan (herein referred to as the BCP) for examination in March 2023 and anticipates adoption in April 2024, subject to independent examination. Our comments are submitted with the current national policy framework considerations in mind.

A summary of the proposed development for the Site is provided for background information in the section below. Our comments on specific elements of the BCP are then set out in chronological order. A conclusion of the key matters and changes to be considered is then provided.

Middlemore Lane West, Aldridge
Middlemore Lane West lies on the south-western edge of the settlement of Aldridge, which offers a range of shops and services, including a doctor’s surgery, dentists, opticians, and retail offerings. It is also within close proximity to Rushall and the services and facilities available there. As such, it is considered to represent a sustainable location for residential development.

The Site currently consists of agricultural land and extends to approximately 1.3 hectares. Middlemore Lane West and existing residential development adjoins the Site to the east. There is an existing train line along the northern boundary of the Site, beyond which is woodland. Bosty Lane runs along the south-western boundary, with agricultural fields extending beyond. As such, the Site benefits from strong defensible boundaries and is considered to represent the logical rounding off of the existing settlement.

As per the current draft BCP, the Site would be removed from the Green Belt and is identified as residential site allocation Middlemore Lane West, Aldridge (WAH233), for 35 dwellings.

The Concept Plan (shown within the Vision Document at Appendix 2) provides an indicative vision and masterplan for the Site. The development would provide appropriate landscaping to retain and enhance existing site boundaries. It would ensure connectivity both within the Site and to its surrounds via sustainable transport means. Informal and formal open space is accommodated within the development, and sustainable drainage technologies would ensure the Site is not subject to flooding. The vision for the Site would assist the Black Country in sustainably meeting the housing needs of existing and future residents.

Draft BCP Policy and Supporting Text Specific Comments

Section 2 – The Vision and Objectives
Section 2 provides the spatial vision, strategic objectives and strategic priorities for the Black Country up to 2039. These are supported by Owl Homes, with particular reference to the objective of providing housing that meets all needs, which the development of the Site can assist in delivering.
Strategic Priority 3: “to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents” and Strategic Priority 4: “to improve and diversify the Black Country housing offer” are considered to be of specific relevance. In line with these priorities, the proposed development would provide a mixture of dwelling types / tenures, to suit a variety of needs. The current Concept Layout includes 32 dwellings, 7 of which would be affordable. A mixture of detached, semi-detached, terraced, and terraced properties as well as maisonettes and flats are shown.

Section 3 – Spatial Strategy


Draft Policy CSP1 – Development Strategy

Draft Policy CSP1 (Development Strategy) provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039. Part 1a) states that at least 47,837 new homes will be delivered, creating sustainable mixed communities that are supported by adequate infrastructure. Part 2) of the policy outlines the spatial strategy which seeks to deliver this growth and sustainable patterns of development. Owl Homes is supportive of this proposed strategy, in particular the provision of new homes to meet housing needs. This is considered to be consistent with paragraph 20 (a) of the NPPF which requires strategic policies to make sufficient provision for housing.

Paragraph 35 (b) of the NPPF sets out that in order to be sound, a plan must be “justified’ – an appropriate strategy taking into account the reasonable alternatives, and based on proportionate evidence.” The subtext to draft Policy CSP1 (paragraph 3.7), advises that a range of alternative options were considered in deciding the proposed spatial approach, as demonstrated by the Spatial Options Paper. The chosen option (Spatial Option J – Balanced Growth) focuses growth within the existing Strategic Centres, Core Regeneration Areas and Towns and Neighbourhood Areas, alongside a limited number of new Neighbourhood Growth Areas near to the edge of settlements that take account of environmental, climate change, accessibility and socio-economic requirements.

The Regulation 18 Sustainability Appraisal (SA) outlines the range of benefits for the chosen option compared with the other alternative 10 options. The SA (Page 8) notes that the chosen option is “considered to perform the best, as it strikes a balance between retaining valuable environmental assets whilst also prioritising development in the most sustainable locations”.

It identifies minor positive outcomes in relation to landscape, biodiversity & geodiversity, climate change mitigation, transport, housing, equality, economy and education. Whilst the assessment notes potential minor negative impacts on waste, this is the case for all of the options, with the exception of option A (business as usual) and option b (employment-led growth) due to the uncertainties regarding the likely sustainability issues associated with waste generation. This demonstrates that the proposed strategy is the most justified and therefore sound approach, when compared with the other alternatives.

Paragraph 3.17 provides an overall summary of the strategy, which is that most housing growth and employment land development will be located in the existing built-up area, with additional homes and employment land allocated on sites removed from the Green Belt. The Council have acknowledged that there is a shortage of deliverable sites to meet housing and economic growth needs in the Black Country. Therefore, the Council’s proposed release of Green Belt land (including the Site) is supported.

Draft Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt
This draft Policy sets out the strategic approach for the Towns and Neighbourhood Areas and the Green Belt. We are supportive of the Policy, which states that 27,068 new homes will be provided, including a supply of small-scale residential development opportunities 1)(b)i. This is considered to be consistent with paragraph 69 of the NPPF, which supports the allocation of small and medium sized sites due to the important contribution they can make to meeting housing requirements and as they are often built out relatively quickly.

Draft Policy GB1 – The Black Country Green Belt

Draft Policy GB1 confirms that ‘The Black Country Green Belt’ will be preserved from inappropriate development (as defined in the National Planning Policy Framework) so that it continues to maintain its openness and serve its key functions. The boundary of the Green Belt is as defined on the Draft Policies Map for each authority.

Part 2) sets out that for sites removed from the Green Belt and allocated to meet housing, employment or other needs through the Plan (such as our Site):

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.”

As demonstrated by the Concept Plan submitted as part of these representations, defensible boundaries to the Green Belt are provided in line with part (a) of the policy, including the railway line and woodland to the north, Middlemore Lane West and existing residential development to the east, and Bosty Lane to the south-west. The proposals have been sensitively designed in order to retain all existing boundary hedgerows, with a 10 metre buffer to the railway line along the northern boundary. In terms of part (b), whilst Owl Homes are supportive of the principle of providing compensatory improvements to the Green Belt to offset the impact of removing land, it is considered that any requests should be proportionate to each individual scheme in order to be ‘justified’. Any contributions requested in relation to this point would also be considered in line with the planning obligation tests set out at paragraph 57 of the NPPF and Regulation 122 (2) of the Community Infrastructure Levy Regulations 2010. It is therefore suggested that the policy wording be amended to provide more flexibility and state “proportionate compensatory improvements…..”.

As emphasised elsewhere within these representations, Owl Homes welcomes the Council’s decision to release the Site from the Green Belt. Paragraph 140 of the NPPF sets out that Green Belt boundaries should only be altered where ‘exceptional circumstances’ are fully evidenced and justified, through the preparation or updating of plans. The supporting text to draft BCP Policy GB1 ‘The Black Country Green Belt’ identifies that exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment needs. This is in accordance with the NPPF, paragraph 139 and case law, namely that of Calverton Parish Council v Greater Nottingham Councils [2015] EWHC 1078 (Admin). We concur with the view of the BCA that exceptional circumstances exist at the strategic level to justify the release of Green Belt sites.
Section 4 – Infrastructure and Delivery

Draft Policy DEL1 – Infrastructure Provision
Draft Policy DEL1 sets out how the BCA will secure infrastructure provision from future planned development. It also sets out the requirement for viability evidence where, in exceptional circumstances, proposals are unable to comply with the policies of the BCP.

In this regard, Owl Homes are willing to provide any contributions as part of the delivery of the Site, providing they meet all of the tests set out within Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 and paragraph 57 of the NPPF and subject to any viability work.

Section 6 – Housing

Draft Policy HOU2 – Housing Density, Type and Accessibility

Draft Policy HOU2 seeks to locate new homes in places with good sustainable transport access to key residential services and provide a mix of housing types and densities which are appropriate to their location and to help meet local needs.

The principle of optimising the density of development in locations that are well served by public transport is supported and considered to be consistent with national policy (NPPF, paragraphs 125 and 141). However, it is considered that the wording of the policy should be amended so that section (4) of the policy only applies on Sites not allocated for housing within Chapter 13. Chapter 13 identifies the site allocations for each of the BCA areas and provides details of what it considers to be an appropriate density for each site. This is based on an assessment of each of the sites undertaken in the ‘Sites Assessed for Housing’ report, that includes a range of considerations including local context and individual site constraints. As such, this is considered to be a more robust density standard which aligns with paragraph 124 of the NPPF and the NPPG on achieving appropriate densities (see ‘Effective use of land’ Paragraph 004 Reference ID: 66-004-20190722). For example, in the case of this Site, part 4c) of Policy HOU2 would apply, which would set a minimum net density of 40 dwellings per hectare for the Site. However, the draft site allocation in Chapter 13 estimates an appropriate capacity of 35dph, given that the Sites Assessed for Housing report had identified a very low character density of 17dph in the local area.
Draft Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Draft Policy HOU3 seeks to deliver a sufficient proportion of affordable and wheelchair accessible homes. It also includes provision for self-build and custom build housing.

The principle of the policy to address the specific local housing needs of the Black Country via individual developments is supported, and is considered to be consistent with National Policy (NPPF, paragraph 62). Nevertheless, in line with the NPPF and NPPG (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509) the draft Policy should be fully evidenced by the supporting assessment work, particularly the Viability Assessment (May 2021) to ensure the cumulative requirements of the BCP policies do not undermine the deliverability of the Local Plan overall. Whilst the Viability Assessment appears to reflect these considerations (in Appendix 1) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 57).

We therefore support the references within the draft Policy to making provision for affordable and accessible housing in line with the policy “where this is financially viable”, and to the use of financial viability assessments.

Section 9 – Transport

Draft Policy TRAN3 – Managing Transport Impacts of New Development
Draft Policy TRAN3 seeks to ensure that both new developments and existing facilities identify travel and transportation impacts and proposals for mitigation. It sets out that any proposals which are likely to have significant transport implications will not be granted planning permission.

This policy is considered to be consistent with National Policy (NPPF, Chapter 9) and is accordingly supported. In terms of the Site itself, access is proposed to be taken from Middlemore Lane West, which connects to Bosty Lane (B4154). The suitability of taking access from Middlemore Lane West will be demonstrated through the provision of appropriate supporting documents submitted with an application. The Site is considered to be sustainably located, near to alternative transport links. Any future planning application at the Site will be supported by the necessary transport work.

Draft Policy TRAN5 – Creating Coherent Networks for Cycling and Walking

Draft Policy TRAN5 seeks to encourage the development of sustainable modes of travel and ensure that places are well-connected with attractive, convenient, direct and safe routes available to non-car users.

As part of the proposed indicative layout for the Site, shown within the Vision Document at Appendix 2, a new pedestrian and cycle link will be created via the Site between Bosty Lane and Middlemore Lane West. This will improve accessibility in the local area to nearby facilities in Rushall and public transport services on Bosty Lane itself.

In terms of cycle parking provision, the quantum and design is likely to be addressed as the proposals for the Site evolve, and consultation with the Local Authority is undertaken.

Draft Policy TRAN 7 – Parking Management

Draft Policy TRAN7 sets out a number of criteria to ensure the sustainable delivery and management of parking. It advises that maximum parking standards will be utilised so that “a consistent approach to maximum parking standards is enforced in new developments and as set out in supplementary planning documents” (part c). In this regard, it is worthy to note that the most recent car parking standards for Walsall are those set out in Policy T13 of the Saved Unitary Development Plan (UDP, 2005). Given the age of these standards, we would like clarification as to whether these standards will be updated, in order to remain consistent with National Policy and the increasing emphasis on providing / encouraging alternative, more sustainable modes of transport.

Draft Policy TRAN 8 – Planning for Low Emission Vehicles

Draft Policy TRAN8 sets out how proposals for low emission vehicles will be supported. Whilst we are supportive of the principle of encouraging low emission vehicle use and providing infrastructure to facilitate this, it is considered that the current policy wording is too vague, particularly in relation to the provision of charging infrastructure. Paragraph 16d) of the NPPF states that Plans should contain policies that are unambiguous. Part a) of the Policy states that “adequate” provision for charging infrastructure should be provided as part of new developments, however it is not clear what is meant by this, as there is no indication / guidance as to what may be considered adequate. Without knowing what infrastructure may be required to be provided as part of new developments in relation to charging infrastructure, the viability implications cannot be fully understood. The Council should ensure that all of the anticipated development costs associated with all of the draft policies of the BCP have been taken into account, as required by National Policy (NPPF paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). It is therefore considered that in order to ensure that the policy is realistic and deliverable, it should be amended to be more explicit in terms of what infrastructure will be expected to be delivered.

Section 10 – Environmental Transformation and Climate Change

Draft Policy ENV1 – Nature Conservation
Draft Policy ENV1 seeks to safeguard and improve nature conservation within the Black Country, through a number of measures. This includes providing adequate information with planning applications for proposals that may affect any designated site or important habitat, species or geological feature.

In this regard, it is noted that a Local Sites Assessment Report has been undertaken in relation to the Site and has been published as part of the evidence base to the BCP. This provides further detail on the ecological status of the Site, which is considered to offer little intrinsic value other than the hedgerow running from the railway road bridge alongside Bosty Lane (B4154) to the corner with Middlemore Lane West. This is proposed to be retained as part of the development. The Daw End Railway Cutting SSSI borders the Site to the north. There are no existing buildings within the Site and the majority of landscaping, which is predominantly located on the peripheries of the Site is proposed to be retained. Therefore, it is anticipated that the proposal would have limited impact on ecology and through the enhancement of landscaping will provide opportunities for net gains to biodiversity. Further ecological survey work will be undertaken and provided as part of any future planning application at the Site.

Draft Policy ENV2 – Development Affecting Special Areas of Conservation

Draft Policy ENV2 requires any development that leads to a net increase in homes or creates visitor accommodation within 15km of the boundary of Cannock Chase SAC to carry out an appropriate assessment. Any adverse impacts will be required to be mitigated. Acceptable mitigation measures will include proportionate financial contributions towards the Cannock Chase SAC Partnership Site Access Management and Monitoring Measures (SAMMM).

Whilst the principle of the policy is supported, the costs associated with the local policy requirements proposed should be fully accounted for within the Viability Assessment (in line with the (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). Whilst the Viability Assessment appears to reflect these considerations (in table 3.5) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 58).

Draft Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain

This Policy seeks to avoid harm to the Black Country Authorities natural assets and ensure their conservation, enhancement and restoration via measures related to individual development proposals, delivering upon the NPPF provisions for the natural environment (Chapter 15). Reference is made to the 10% biodiversity net gain requirement currently proposed by the Environment Bill which is progressing through Parliament. As this Bill remains subject to amendments the Policy should ensure it reflects the up-to-date national requirements as the draft BCP progresses.

Draft Policy ENV4 – Provision, Retention and Protection of Trees, Woodlands and Hedgerows

Draft Policy ENV4 seeks to support and protect trees, woodland and hedgerow within the BCA. Whilst Owl Homes are supportive of the principle of the provision of new trees and the protection of existing ones, it is considered that the policy is too wordy, and goes beyond what is required by National Policy. Paragraph 131 of the NPPF sets out the planning policy expectations in relation to trees. This includes ensuring that trees are incorporated within developments, that measures are in place to secure the long-term maintenance of newly planted trees, and that trees are retained where possible. In light of the above, it is considered that the policy should be rationalised in order to be more clearly written and consistent with National Policy, and to serve a clear purpose.
As set out within the Vision Document at Appendix 2, and in line with the aspirations of this Policy, the proposed layout for the Site has been sensitively designed in order to retain the existing trees and hedgerow where possible. Further supporting information including a tree survey and Arboricultural Impact Assessment (AIA) will be undertaken to support the proposal, with appropriate mitigation where required.


Draft Policy CC7 – Renewable and Low Carbon Energy and BREAAM Standards
This Draft Policy seeks to ensure that a high standard of sustainable design is secured on all new developments over the Plan period, primarily through a list of requirements and standards. All proposals of ten or more homes are to achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document Part L 2013. In addition, they must incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the residual energy demand of the development on completion. It is advised that a variety of renewable and low-carbon energy sources and generation methods should be assessed and costed, including on-site and off-site sources where appropriate, and the use of district heat and / or decentralised energy networks. An energy assessment must be submitted. Some flexibility is provided in the case of viability issues and practical constraints resulting in the requirements being unachievable.

Whilst the principle of addressing climate change via the design of new dwellings is supported as part of overall sustainable development, the costs associated with the local policy requirements proposed should be fully accounted for within the Viability Assessment (in line with the (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). Whilst the Viability Assessment appears to reflect these considerations (in table 3.5) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 58).

Section 13 – Sub Areas and Site Allocations

Section 13 is divided into four chapters related to each of the four Black Country Authorities. Chapter C) relates specifically to Walsall and identifies the site allocations for the area.

The Vision for Walsall Council is provided at paragraph C.7, with a number of priorities and how they will be delivered set out at paragraphs C.9 and C.10. We support the vision and consider that the delivery of the Site can assist with a number of the priorities set out for Walsall, for example, by providing housing which meets all of people’s needs and is affordable, safe and warm.

In line with paragraph C.10, the proposed development will provide housing in a sustainable area, near to Aldridge and the services and facilities it benefits from. The proposed development will also integrate well with the existing urban area through the provision of footpaths within the Site, as well as improved footpath provision on Middlemore Lane West, ensuring cohesion with the adjacent settlement.
Figure 19 sets out the spatial strategy for Walsall. This removes our client’s Site from the Green Belt and identifies it as a housing allocation. The Site is also adjacent to the Green Belt and a Strategic Employment Area. Table 31 supplements the strategy and includes the ‘Walsall Sites Allocated for Housing by the Black Country Plan’. Within the table, the Site is listed as ‘Middlemore Lane West, Aldridge’ (WAH233) and is shown as having an indicative housing capacity of 35 dwellings. The site allocations process has been informed by the Sustainability Appraisal, as well as the Black Country Plan Site Assessment Report (August 2021).

We support the allocation of the Site for residential development, and consider that it represents a logical solution to meeting housing need by ‘rounding off’ / extended the existing settlement, in accordance with paragraph 3.17 of the BCP. The Site is near to a range of transport links and local services and facilities. The Vision Document submitted as part of these representations (Appendix 2) emphasises the suitability of the Site for residential development and provides further information on how it can be comprehensively brought forwards. Owl Homes have a strong track record of delivering homes within the local area, for example at Walsall Wood. This demonstrates their ability to deliver the Site in a timely manner, contributing towards the Council’s housing land supply position.

Within Table 31, further information is provided for the development of the Site, and states:

“A strategy for landscape and ecology that ensures the retention and / or mitigation for established trees. Footpath improvements along Middlemore Lane to provide safe and secure access routes. On-site provision or funding for off-site arrangements to improve access to a primary school and local health centre.”

The further information provided within table 31 is in line with the proposals submitted to date. The Concept Plan shown within the Vision Document at Appendix 2 would retain all existing boundary hedges and provide footpath improvements along Middlemore Lane. As part of the planning application process, a detailed strategy for landscape and ecology would be provided in line with site-specific evidence. Owl Homes are also willing to provide any contributions which are considered to meet the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 and paragraph 57 of the NPPF and subject to any viability work. Our comments in relation to relevant draft BCP policies e.g. on Renewable and Low Carbon Energy are also applicable in this site-specific context.

Summary of Suggested Changes and Conclusion

In summary, support is provided for the overall strategy for future development within the Black Country Authorities, with particular reference to the removal of smaller sites such as Land off Bosty Lane from the Green Belt at the edge of Towns and Neighbourhood Areas in the form of rounding off (paragraph 3.17). The residential allocation of Middlemore Lane West, Aldridge (WAH233) is also supported. The development of the Site will deliver 32 high quality homes, set within a strong landscape setting, with an attractive public open space as part of the development.

Several changes are proposed above, based on the Local Plan tests of soundness (NPPF, paragraph 35), and we respectfully request that these are considered going forwards to the Pre-Submission (regulation 19) Plan.
We would be grateful for confirmation that these representations have been received and registered as duly made. We trust this submission is clear and helpful, but should you have any questions in relation to the above and/or attached please do not hesitate to contact me.

Comment

Representation ID: 21303

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Section 13 – Sub Areas and Site Allocations

Section 13 is divided into four chapters related to each of the four Black Country Authorities. Chapter C) relates specifically to Walsall and identifies the site allocations for the area.

The Vision for Walsall Council is provided at paragraph C.7, with a number of priorities and how they will be delivered set out at paragraphs C.9 and C.10. We support the vision and consider that the delivery of the Site can assist with a number of the priorities set out for Walsall, for example, by providing housing which meets all of people’s needs and is affordable, safe and warm.

In line with paragraph C.10, the proposed development will provide housing in a sustainable area, near to Aldridge and the services and facilities it benefits from. The proposed development will also integrate well with the existing urban area through the provision of footpaths within the Site, as well as improved footpath provision on Middlemore Lane West, ensuring cohesion with the adjacent settlement.
Figure 19 sets out the spatial strategy for Walsall. This removes our client’s Site from the Green Belt and identifies it as a housing allocation. The Site is also adjacent to the Green Belt and a Strategic Employment Area. Table 31 supplements the strategy and includes the ‘Walsall Sites Allocated for Housing by the Black Country Plan’. Within the table, the Site is listed as ‘Middlemore Lane West, Aldridge’ (WAH233) and is shown as having an indicative housing capacity of 35 dwellings. The site allocations process has been informed by the Sustainability Appraisal, as well as the Black Country Plan Site Assessment Report (August 2021).

We support the allocation of the Site for residential development, and consider that it represents a logical solution to meeting housing need by ‘rounding off’ / extended the existing settlement, in accordance with paragraph 3.17 of the BCP. The Site is near to a range of transport links and local services and facilities. The Vision Document submitted as part of these representations (Appendix 2) emphasises the suitability of the Site for residential development and provides further information on how it can be comprehensively brought forwards. Owl Homes have a strong track record of delivering homes within the local area, for example at Walsall Wood. This demonstrates their ability to deliver the Site in a timely manner, contributing towards the Council’s housing land supply position.

Within Table 31, further information is provided for the development of the Site, and states:

“A strategy for landscape and ecology that ensures the retention and / or mitigation for established trees. Footpath improvements along Middlemore Lane to provide safe and secure access routes. On-site provision or funding for off-site arrangements to improve access to a primary school and local health centre.”

The further information provided within table 31 is in line with the proposals submitted to date. The Concept Plan shown within the Vision Document at Appendix 2 would retain all existing boundary hedges and provide footpath improvements along Middlemore Lane. As part of the planning application process, a detailed strategy for landscape and ecology would be provided in line with site-specific evidence. Owl Homes are also willing to provide any contributions which are considered to meet the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 and paragraph 57 of the NPPF and subject to any viability work. Our comments in relation to relevant draft BCP policies e.g. on Renewable and Low Carbon Energy are also applicable in this site-specific context.

Summary of Suggested Changes and Conclusion

In summary, support is provided for the overall strategy for future development within the Black Country Authorities, with particular reference to the removal of smaller sites such as Land off Bosty Lane from the Green Belt at the edge of Towns and Neighbourhood Areas in the form of rounding off (paragraph 3.17). The residential allocation of Middlemore Lane West, Aldridge (WAH233) is also supported. The development of the Site will deliver 32 high quality homes, set within a strong landscape setting, with an attractive public open space as part of the development.

Several changes are proposed above, based on the Local Plan tests of soundness (NPPF, paragraph 35), and we respectfully request that these are considered going forwards to the Pre-Submission (regulation 19) Plan.
We would be grateful for confirmation that these representations have been received and registered as duly made. We trust this submission is clear and helpful, but should you have any questions in relation to the above and/or attached please do not hesitate to contact me.

Object

Representation ID: 21322

Received: 11/10/2021

Respondent: Class Q Ltd

I write as Agent for land identified as SA-0050-WAL in the Black Country Site Assessment Report and seek to make representation to the Regulation 18 Consultation to outline that this site is an appropriate location for housing development for approximately 93 dwellings instead of, or as well as, WAH231 which lies immediately to the west and proposes 202 dwellings.

The basis for discounting SA-0050-WAL as a potential allocation was based on the findings of the Black Country Site Assessment Report that found deficiencies in terms of harm to the Green Belt, harm to landscape, highways and ecology.

As a result of this assessment, further work has been undertaken to demonstrate that the conclusions reached in the Assessment are incorrect and that the site should be considered favourably as an allocation.

To demonstrate this, each matter is addressed in turn below.

Development of the site is considered to result in a high level of harm to the Green Belt and The landscape is
considered to have a “moderate-high overall sensitivity to residential development”

The assessment made the following comments “The sub-parcel makes a strong contribution to preventing the sprawl of the West Midlands conurbation, maintaining the separation of Walsall, Aldridge and Streetly (adjoining Sutton Coldfield) and preventing encroachment on the countryside. However, release of land on the urban fringes of the subparcel that have less significant boundaries between settlement and countryside would result in slightly less harm than release of the core area between towns”.

To address these concerns a Landscape and Green Belt Assessment has been prepared to consider and assess the potential effect on: site context and features; landscape and visual receptors; designations; and the Green Belt.

The Assessment should be read in full as part of this representation, however, it concludes that the proposal would cause less harm to the Green Belt and landscape receptors, and potentially visual receptors, than either Strategic Allocation Sites WAH231 and WAH242 and that it would provide a more appropriate release from the Green Belt, either in addition or as an alternative, and that it should accordingly be allocated for residential development.

Upgrades to the local highway would be required

The assessment, regarding highways access and transportation states that “The impact of 81 homes here would require a transport assessment to understand what mitigation would be required and whether that could have any significant impact on viability. Works may be required to Longwood Lane which currently has no footpath and to mitigate the additional impact on the junction from Longwood Lane to Sutton Road. The existing highway infrastructure here would not be sufficient to support an employment use”.

To address these concerns a Highways Advocacy Document has been prepared to review the highways feasibility and deliverability of a proposed allocation on the site.

The Highways Advocacy Document should be read in full as part of this representation, however, it concludes that, based on the quantum of residential development proposed for allocation on this site, it is considered that the impact of the proposals would result in a negligible impact on the capacity of the highway network and would have no adverse impact on highways safety.

The site was also cited as having importance for the retention of trees and hedges and concerns were raised about the potential impact on ecology

However, regarding trees the assessment states that “There are no protected trees or hedges, however there are established trees and hedges which may be worthy of retention. A tree survey is required to determine the quality of trees and whether they must be retained. Much of the site is open and the retention of trees and hedges would not significantly reduce the potential for redevelopment of the site”.

“The site is in close proximity to Hay Head SSSI to the East and any changes to established hedges or trees would require an Ecology assessment. The ecological valuation of the Black Country Green Belt is based on a set of assumptions that formed the basis for developing a set of criteria which allowed EcoRecord to attribute a relative value to individual land parcels within the Green Belt. A Valuation Matrix was used based on the following attributes to calculate a final ecological value score for each Landscape Unit: Land Use Calculated Value, Habitat Features, Nature Conservation Designation Value, Adjacency to SSSIs or Ancient Woodland, Historic Landscape Characterisation (HLC) Type Value, Twinspan Axiophyte Value (TAV) and Breeding Farmland Birds Value. The higher the score the higher the ecological value. Predominant Ecological Valuation of the Black Country Green Belt Score = 4 The site falls within a Nature Recovery Network Core Habitat Zone”. The site was therefore scored red meaning that its “Capacity significantly limited unless harm is caused to habitat of SINC / SLINC value, which cannot be wholly mitigated”.

To address these concerns, a Preliminary Ecological Assessment has been prepared and is attached with these representations.

The Preliminary Ecological Assessment should be read in full as part of this representation, however, it concludes that there are no ecological issues that would prevent the site from being developed, subject to addressing certain matters set out in the Assessment.

Other Matters
In addition to the above concerns that “The North East part of the site may be within an area of untreated Limestone, anything within this identified area is not safe to build on and would have a minor reduction to the developable area”.

Having reviewed the Environment Agency website for historic landfill/quarry workings whilst there is an old landfill a short way down the road; there is nothing below the site. The bedrock below the site is Coalbrookdale Formation, which is a Mudstone. Therefore, the Council have incorrectly assessed the site on this matter.

Conclusions
The Council’s decision to not allocate the land at Longwood Lane was based on the omission of the information now submitted as part of these representations.

The information provided clearly demonstrates that the land is an appropriate location for a residential development that can be achieved without undue harm relating to highway safety, landscape and Green Belt harm and ecological harm.

On this basis, the Council is requested to review the land again with a view to including it as a further residential allocation in the emerging Black Country Plan 2039.

Comment

Representation ID: 21388

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to National Grid assets.

HOU1, HOU2, HOU3 New Road (former car showroom), Willenhall - 275Kv Underground Cable route: BUSHBURY - WILLENHALL

Comment

Representation ID: 21389

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to National Grid assets.

WAE122 Former Moxley Tip, Moxley Road - YYD ROUTE: 275Kv Overhead Transmission Line route: OCKER HILL - WILLENHALL 1

Comment

Representation ID: 21395

Received: 11/10/2021

Respondent: National Grid

Agent: Avison Young

Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to National Grid assets.

WAE076 Rear of 18 Rose Hill, Willenhall - 132Kv Underground Cable route: WILLENHALL 275KV - WILLENHALL 132KV

Object

Representation ID: 21458

Received: 11/10/2021

Respondent: Cllr Lorna Rattigan

Comments on WAI-1238/WAH240 Coronation Road / Mob Lane. 763 Homes.
Not suitable for 763 homes
1. It has protected wildlife species within the trees, [species redacted].
2. It has flooding issues and protected trees.
3. It is not suitable due to the infrastructure regards to Highways, Coronation Road is already a narrow road and has traffic congesting issues with cars and buses as difficult at the moment with 2 way traffic and lack of parking for residents.
4. Infrastructure : Not enough schools, medical services to cater for such a large development, already challenged with school parking, causing chaos with secondary and primary schools already in the area.

Comments on SA 0317-WAL Green Lane / Greenfields
Not suitable for development.
1. It has flooding issues within the fields.
2. Has protected trees
3. Opposite the landfill site, which has bad odour issues which can have health issues.
4. Highways, as already has parking issues with the secondary school in close proximity.

Comments on SA 0264-WAL Barns Farm / Barns Lane
Not suitable for development as farm fields backs onto Stubbers green pools. Used for recreational use by residents as only green space for existing housing within the area and sailing club nearby.
1.1t has protected wildlife species within the trees, [species redacted] as backs on to the nature reserve of Stubbers Green, where we have rare species of birds and is a natural wildlife site, for bird watchers, which if start building on will effect the rare species of birds and waterfowl that currently live and migrate too depending on seasons.
2. It has flooding issues
3. It is not suitable due to the infrastructure regards to Highways, Barns Lane is already a very busy road, due to the closeness of Aldridge industrial area and has traffic congesting issues with parked cars and buses as difficult at the moment with speeding traffic, from lorries etc and lack of parking for residents.
4. Infrastucture : Not enough schools, medical services to cater for such a large development, already challenged with school parking, causing chaos with secondary and primary schools already in the area.

Comments on SA 0308-WAL Shelfield / Employment Land.
My understanding is that it is what is currently the landfill site, which we have had a lot of residents issues regarding bad odours and timescales of getting land back to normal, but this raises questions as to whether the land will be suitable for development!

Object

Representation ID: 21467

Received: 07/10/2021

Respondent: Peter Kendrick

REF WAH242 Calderfields Farm

I would like to express my disgust and dismay that as a person resident [redacted sensitive information] where the above development is proposed with one of the potential accesses [redacted sensitive information] the first notification I had of this was from a third party. In my experience people adjacent to or within a close vicinity have always been made aware of potential developments. I have had people coming to me and asking if I have heard anything because [redacted sensitive information]
There have been no notices posted that I am aware of and it has been left to local residents to advise everyone in the area of the proposal.
I assume the lack of council action is down to the pandemic and everyone working from home!

In view of the lack of consultation I would explore you to ensure the deadline for making representations at present the 11th October 2021 is extended and would be grateful if you would confirm you will do this.

I would also ask that in view of all your comments in the past on the necessity of protecting our precious green belt you will confirm that as leader of the council you will oppose the development of the above site for all the reasons that I feel certain and am partly aware have been stressed in comment forms that have already been lodged and that you have no doubt read with interest.

I have asked two questions here Mr Bird neither of which I consider complicated and would request a straightforward answer to each preferably, yes and to when, and secondly, yes I will support opposition particularly to the above proposed development as well as other Greenbelt areas in the borough.

Object

Representation ID: 21469

Received: 05/10/2021

Respondent: Ms Joanne James

REF WAH242 CALDERFIELDS FARM

Dear Councillor Bird

The Black Country Plan plans to build 5500 homes on Walsall Green Belt.

In an Interview for Birmingham Mail you said 'I'm not convinced these houses are required. I have not seen the methodology the government has used'. I too would question the computer based algorithm to assess the housing needs which seems totally overinflated. Local councils rather than the government are surely better equipped to judge their housing targets.

The projections assume the population of the Black Country will rise at an alarming rate from 2023-2039 well above normal growth and does not take into account that this could also decrease as well as increase. With work from home becoming the normal, people have been re-evaluating their lives and as a consequence people have been moving away from towns in search of a better quality of life.

If growth were normal, all future developments and improvements to our infrastructure can be fully accommodated within the urban area. Brownfield First. Surely there is more than enough Brownfield, old Industrial and windfall sites and developments that already have planning permission available to accommodate housing targets without the permanent destruction of Greenbelt.

I would also ask ‘has the pandemic changed the housing supply equation’. Working from home and shopping online have hollowed out many urban centres. Walsall in particular is full of offices and shops empty and unused. Could Walsall’s struggling high street and business zones with its good transport links be repurposed as residential neighbourhoods rather than our beautiful countryside.

I have submitted my objections to BCP but the consultation process is flawed and discriminatory. Communication of this plan has been extremely poor and over complicated meaning people are either unaware of it, or don't know how to respond.

Councillor Nawaz said "If the council can send a council tax bill to every house in the borough, then they can let every house in the borough know about the proposals'

Councillor Nawaz says he will be voting against the proposal and will be asking all the Walsall Labour Councillors to vote against the development.

My question is 'how will you vote?'

Will you vote to save our Green Belt? Once it's gone it's gone forever!

I look forward to hearing from you.

Object

Representation ID: 22096

Received: 11/10/2021

Respondent: Mr Roger Tye

There are far too many houses currently in the areas around Streetly and Aldridge, and the traffic is
horrendous in all the areas that are due to be built on for houses, there is no infrastructure for schools, doctors, hospitals( you cannot see a doctor at the moment and the queue on the phone is out of control with a wait time of 2hours)

The area needs an infrastructure plan before the housing plan???
there will just be hundreds more houses and cars and people with children etc/ illness and no more doctors/ hospitals/road infrastructure or schools to carry the already overstretched burden around this area
i completely object to this plan before a solid infrastructure plan is developed and approved

Support

Representation ID: 22179

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)

Chapter 13 Site allocations

Table 31
We support the Allocation of site Ref WAH 255 Rear of 91 Wood Lane, Streetly as shown on the proposals map . We support the net density figure of 35 dwellings which is appropriate for the site. We support the anticipated delivery date by 2026, because this is a site than can forward early in the Plan period to meet the housing needs. The land owners are committed to bring the land forward at soon as the Plan is adopted .
We attach to this submission the following drawings that illustrate how the site can be developed to a high standard taking into account the characteristics of the site.

Object

Representation ID: 22200

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Walsall Housing Allocations – Omission Site – SA-0063-WAL – Land at Druids Heath Golf Club

It is our view that the surplus land in the Clubs control, as identified by the Plan provided at Appendix 1 of this letter, should be allocated for residential development by the BCS. Figure 1 – Druids Heath Golf Club Context Plan, below shows the location of this land, and other nearby features of note, to assist in our critic of the Black Country Site Assessment Report (“BCSAR”).

Figure 1 – Druids Heath Golf Club Context Plan [available in Attached PDF]

The BCSAR has been prepared to assess the various sites promoted for development through the Call for Sites process and to help inform which sites should, and should not, be allocated for development in the emerging Plan. The Club promoted the land enclosed within the blue line on Figure 1 above for residential development though the Call for Sites consultation. It is identified as site SA-0063-WAL by the BCSAR and it is concluded that it is unsuitable for an allocation. However, the conclusions of the BCSAR are flawed and inconstant.

The BCSAR includes a series of criteria that are used to assess the suitability of sites for an allocation. A ‘traffic light’ system is used to assess each site against the criteria. We comment on the assessment of site SA-0063-WAL below.
• Green Belt Harm – It is suggested that the development of this site would lead to “high” harm to the Green Belt, and it is graded red. In the first instance it should be noted that proposed allocation SA-0309, shown on Figure 1, has exactly the same classification. This is clearly not, therefore, a constraint to development.

It is suggested that this parcel of land is important as it prevents encroachment into the countryside. Any development in the Green Belt will lead to a degree of encroachment, and the draft Plan requires Green Belt development. The site should not, therefore, be scored down for this reason. In any event this parcel of land has an access road running through it. The club house and its car park are located to the north east and east of this site respectively. There is also a large care home nearby. Encroachment has already taken place in this area, reducing the impact of the development of this site in this regard. It is proposed that this site is extended to include the existing clubhouse car park. As this site is PDL the additional impact by way of encroachment through the inclusion of this parcel of land is minimal.

It is advised that the Green Belt in this location makes a moderate contribution to protecting the gap between Aldridge and Streetly. The development of this site will have no material effect on this gap.

• Landscape Sensitivity – It is suggested that the development of this site would have “moderate/high” landscape harm. The site is flat and featureless, with the exception of the access road and occasional trees. The additional land proposed for inclusion is a car park. Whilst the wider area may be of some landscape sensitivity this is not true of this site. Furthermore, proposed allocation SA-0309 is also classed as having moderate/high landscape harm, but is still a proposed allocation. Indeed, given that the proposed allocation is currently woodland, at least in part, it is of more landscape importance than the land in the Club’s control.

• Greenfield / PDL – The site is classified as “red” and it is advised that there is no history of development. This is incorrect. The access road to the club runs through this site and is a significant feature. In addition, the inclusion of the car park makes a significant proportion of the site PDL.

• TPO and Trees – It is advised that there are no TPO trees on this site. There are trees within the site, however, as they are not the subject of a TPO they could be removed at any time. The site is classed as “amber” in this category. The allocated site is also classed as amber. However, it is advised “the western section of the site (the allocated site) is predominantly tree covered and is subject to a TPO”. Aerial images suggest that the majority of this section of the site has tree coverage. Taking this as a reference point the land in the Clubs control should clearly be classed as green.

• Biodiversity and Geodiversity – Both the land in the Clubs control and the proposed allocation SA-0309 are identified as ‘amber’ in this category. The land in the Clubs control constitutes a well maintained grass lawn, an access road and car park. The proposed allocation includes a large coppice of trees. This clearly suggested that the land in the Club’s control should be considered a less sensitive location for development from a biodiversity perspective.

• Noise Impact – The site is classed as “red” for noise impact. It is advised that as the golf club would share the access to the proposed development site the coming and going of vehicles would have a “significant unacceptable impact on the amenities of occupiers of any houses here and the existing houses which adjoin the proposed shared access.” There are a number of problems with this rational:

1) It is suggested that vehicles visiting the golf club could adversely affect the residential amenity of any houses built on this site. However, the draft Plan proposes a residential allocation immediately adjacent to this site, and no such concerns have been raised in the allocation of this site. They would be equally affected.
2) It is suggested that vehicle movements could also affect the amenity of existing houses. The vehicle movements associated with the golf club already exist on the road network. We are not aware of any complaints in this regard from neighbouring property owners. This includes the nearby care home which is clearly a sensitive receptor. This statement is unfounded.
3) In order to get to the access to the golf club cars need to travel along Stonnall Road, and the wider road network. These roads are all residential in nature. Indeed, only a small fraction of the traffic on the local network is there to gain access to the club. However, there is no suggestion that these vehicle movements adversely impact the amenity of houses in the locality.
4) The vehicles visiting the site are by and large private cars. It is, in effect, being suggested that a very limited number private car movements are not compatible with residential development, which is quite simply is not the case.

• Conclusion – The site is rejected as a proposed allocation on three grounds. The first is noise impact from cars accessing the club. As referred to above this is completely unfounded. The second reason is due to the proximity of the site to the clubhouse, and potential disturbance caused by events at the clubhouse. This has not, however, prevented site SA-0309-WAL being allocated despite it being just as close to the clubhouse. We are also unaware of any noise complaints (or complaints of any kind) from the care home or nearby properties. The third reason is topographical constraints and the site potentially being seen from Hobs Hole Lane. This is equally true of the proposed allocation. Furthermore, this site is already subject to built development in the form of a car park impacting on its landscape character.

It is clear that there is ample evidence that the development of this site will have no detrimental harm, particularly when compared to the neighbouring proposed allocation. Furthermore, the development of the site will generate funds that will be directed back into the Club so that it can improve its facilities, making it a more attractive proposition whilst enhancing its viability. It is respectfully requested that this site is allocated for development in the Plan.

Object

Representation ID: 22241

Received: 11/10/2021

Respondent: Steve Crutchley

[Site Ref: SA-0314-WAL]

Harris Lamb Planning Consultancy (“HLPC”) are instructed by Mr Stephen Crutchley to submit representations to the Black Country Plan Regulation 18 consultation document. We have previously submitted representations to the Black Country Call for Sites Consultation on Mr Crutchley’s behalf. Mr Crutchley controls an area of land located to the rear of Sutton Road and Longwood Lane, Aldridge. Our Call for Sites representations proposed that the site is removed from the Green Belt and allocated for residential led development in the emerging Plan.

The site has not, however, been identified as a proposed residential allocation in the Regulation 18 consultation document. It is identified as site SA-0314-WAL by the Black Country Plan Site Assessment Report (“BCSAR”) and it is suggested that it is unstable for an allocation. It is our view the failure to identify the site as a residential allocation is a significant omission, and the site should be allocated for a high quality residential led scheme. The assessment of the site in the BCSAR is inaccurate, it does not properly reflect the suitability of the site for residential development and contains a number of factual errors. Furthermore, we have a number of concerns with the overall housing requirement in the emerging Plan, the approach taken towards the distribution of the housing requirement and Green Belt land release.

Policy GB1 – The Black Country Green Belt
As detailed in these representations our client’s site at Barr Beacon fulfils this brief. It has strong defensible Green Belt boundaries. The stie 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.

Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain
Measures to achieve biodiversity net gain on site could reduce coverage and consequently the number of units. This matter needs to be carefully considered in light of the draft Plans density aspirations.

Walsall Housing Allocations – Omission Site - Land at Barr Beacon (SA-0314-WAL)

The BCSAR has been used to assess the suitability of the sites promoted through the Call for Sites process as an allocation. A series of criteria are used to assess the sites. A “traffic light” system is then used to assess the sites against each criterion.

The land in our client’s control is identified as site SA-0314-WAL -Land rear of Sutton Road and Longwood Lane, by the BCSAR. The site is identified as ‘red’ in a number of categories. It is concluded that the site is unstable for development principally due to Green Belt and landscape harm and the potential impact the development would have on trees and ecology. However, the BCSAR fails to properly assess the site. For example:

• The site is “red” and is identified as having “very high harm” to the Green Belt. However, the Black Country Authorities have to remove land from the Green Belt to meet their housing requirement. Indeed, even with the current proposed Green Belt land release there is a housing shortfall of approximately 28,239 dwellings that is being directed to other Local Authority areas (as referred to above we believe this to be an underestimate). This will inevitably result in Green Belt release in these Authority areas. The fact that the site is within the Green Belt should not, therefore count against it as an in-principle constraint.

• It is suggested that the development of the site will result in “sprawl” and the site is important in maintaining the separation of Walsall, Aldridge and Streetly. Whilst there would be some sprawl this is true of the development of any greenfield Green Belt site. The site is well contained by strong defensible Green Boundaries. Indeed, the western boundary of the site adjoins a large area of woodland that would prevent any further development in this location. The sites boundaries and on-site features will help the development merge into the surrounding area. Indeed, the site is largely hidden from view from the public domain.

• The development will not result in Walsall, Aldridge and Streetly merging into one another or the gap being closed to any real extranet. The development of this site would not in any way reduce the gap between Aldridge and Streetly. It would result in the western expansion of Aldridge and Streetly lies to the east and south. The builtup edge of Walsall is at the junction of Sutton Road/ Skip Lane to the west, approximate 1km from the site. A significant gap would remain if the site were developed.

There are no overriding constraints to the development of the site from a Green Belt perspective.

• It is suggested that the development of the site would have “medium high’ landscape harm. This harm includes harm to woodland, hedgerows and the development of an area with a strong sense of tranquillity. The woodland areas that are referred to fall outside of the site boundary and would be unaffected. Whilst it is suggested that the area has a strong sense of tranquillity, it adjoins the Sutton Road and there is no public access to the site. The site largely sits within a bowl and the trees, hedgerows and other landscaping features can simply be retained with the development parcels nestled amongst them in the paddocks. The sites landscape setting is an opportunity, not a constraint.

• The site is scored down for been greenfield, however, the housing requirement cannot be met without greenfield land release. This should not be considered a constraint.

• The site is identified as ‘red’ for impact on trees. In terms of impact on trees, the important trees on site can simply be retained and the development planned around them. Any trees that are lost can be replaced. Indeed, it is envisaged that there would be an increase in the number of trees on stie as a consequence of the landscaping scheme associated with any residential development.

• It is suggested that the development would have biodiversity harm by refence to the need to remove trees. However, again the trees can be retained. The site is currently used as pastureland for the keeping of horses. Development would be concentrated on the pastureland which has very limited ecological value.

• It is suggested that the site has public rights of way running through it. The Councils interactive Map does not identify and Public Rights of Way or footpaths running through the site. The Beacon Way follows Sutton Road, it does not provide access to this site which is in private ownership.

• The sites visibility from surrounding houses is not a constraint. Clearly any site adjacent to the residential area of a settlement it is likely to have views across it from neighbouring houses. In planning terms, there is no right to view. In addition, the houses in this location have long back gardens and the development can easily be designed in such a way to ensure that existing residential amenity is protected.

• It is advised that the stie is more than 15 minuets walk from a food store. The site is within a 5 minute walk of the Marks and Spencer convenience store located at the Erdington Road/Sutton Road roundabout.

The site is a suitable and sustainable location for development. It can help provide much needed housing to address the significant housing shortfall identified by the draft Plan. It is respectfully requested that it is allocated for development.

Support

Representation ID: 22258

Received: 11/10/2021

Respondent: F E Johnson

Number of people: 3

Agent: Gareth Holland + Co Ltd

WAH 247

RE: SA-0200-WAL - Johnsons Farm + Meadow Farm
SA-0199-WAL - Sandfield Farm, Lichfield Road, Brownhills
WAE 247, WAE 409, WAE 410

The above sites have been put forward for employment and housing opportunities.
The sites are well located in terms of access to local facilities and services, including transport links with the sites being easily accessible.
The sites are available, suitable and deliverable.
On behalf of the landowners, it is confirmed that the sites are available and support is confirmed for the potential release from the green belt for development.

Comment

Representation ID: 22259

Received: 11/10/2021

Respondent: F E Johnson

Number of people: 3

Agent: Gareth Holland + Co Ltd

WAE409, WAE410

RE: SA-0200-WAL - Johnsons Farm + Meadow Farm
SA-0199-WAL - Sandfield Farm, Lichfield Road, Brownhills
WAE 247, WAE 409, WAE 410

The above sites have been put forward for employment and housing opportunities.
The sites are well located in terms of access to local facilities and services, including transport links with the sites being easily accessible.
The sites are available, suitable and deliverable.
On behalf of the landowners, it is confirmed that the sites are available and support is confirmed for the potential release from the green belt for development.

Comment

Representation ID: 22262

Received: 21/01/2022

Respondent: Miss Jodi Stokes

[Site Ref: HIGHFIELDS NORTH]

1.0 INTRODUCTION

1.1 These representations have been prepared on behalf of Parkhill Estates Ltd, in relation to their interests at Highfields North, Walsall (‘the Site’), as well as their other interests at:

• Alexander Metals, Wednesbury; • Hughes Road, Wednesbury; and
• Iron Park, Moxley.

1.2 Parkhill Estates have previously made representations to the Black Country Core Strategy Review, including the most recent Call for Sites exercise in August 2020.

1.3 The Site is shown on the Site Boundary Plan at Appendix 1 (drawing reference: BI-P-01).
The Site extends 18.34 hectares and is made up of a series of smaller fields.

1.4 The Site is located to the north of Walsall Road, between Walsall and Walsall Wood. There is existing housing to the west and south west, and a draft housing allocation to the west (reference: WAH256). There is a pub and commercial uses to the south (also north of Walsall Road). There are allotments to the north west and agricultural land to the north.
Highfields Landfill is located to the south of Walsall Road.

1.5 The Concept Plan (drawing reference: BM-M-14 revision A) at Appendix 2 proposes a modest residential development area of approximately 1.5 hectares in the south west part of the Site, that will accommodate up to 100 dwellings. In addition, there is a further area of 6.1 hectares in the north of the Site, which would also be suitable for potential future development. As part of the development, the existing planting and landscape on the site will be retained and enhanced as much as possible, informing new green-blue infrastructure, public open space and giving character to the development. A large area of public open space/ecology area will also be created. The development will also utilise existing topography to create new attenuation areas and blue-green infrastructure to mitigate the risk of flooding as part of the development proposals. The proposed development is set out within the Vision Document at Appendix 3.

1.6 In terms of flood risk on the Site, we realise that Walsall Council’s own modelling work by JBA consulting shows that the majority of the Site is either Flood Zone 2 or 3. Our own consultant, Wardell Armstrong, have undertaken an initial review of this work and the methodology and have concluded that the JBA work models the extent of flooding as a result of culvert blockage scenarios based on topographical surveys of the culvert/adjacent land. This was done on 25 culverts, but not the one immediately downstream of the Site,


which is how the drainage of the Site takes place. Wardell Armstrong are currently in the process of undertaking additional modelling to show how the Site drains via this culvert and hope to be able to submit this further information later this year and to show the true extend of flood risk on the Site. We have tried to engage with Walsall Council so that this work could be completed and submitted during this consultation period, however, we have received no response from the Flood Risk Management team to date.

1.7 It should also be noted that Parkhill Estates have owned the Site since the early 1980’s and have not experienced any flooding of the Site. There has been effluent spills from the Green Lanes Sewage Treatment Works owned by Severn Trent Water, which have caused damage to the Site, but these are not natural events and wholly avoidable.

1.8 Whilst part of the Site is designated as Jockey Fields Site of Specific Scientific Interest
(‘SSSI’), Natural England confirm that the SSSI is in ‘unfavourable – declining’ condition. As shown on the Concept Plan (drawing reference: BM-M-14 revision A) (at Appendix 2) only part of the Site defined as a SSSI would be developed. If the development of this part of the Site were to be supported, Parkhill Estates would be willing to consider the provision of compensatory provision at their other land interest at Ryders Mere to the north (which is under their ownership). Parkhill Estates are willing to hold further discussions with the Council in this regard.

1.9 On the basis that we disagree that the site specific conclusions of Walsall Council’s flood risk modelling, we consider that the Site is suitable for a high quality residential development to meet the Black Country’s identified housing need and unmet need from the Greater Birmingham Housing Market Area (‘GBHMA’).

HIGH FIELDS NORH WALSALL
Vision Document October 2021

1. The Vision
“An attractive well-connected residential development of high quality homes, set within a strong landscape setting, with extensive, accessible public open space as part of the development.
Creation of high quality homes for all
The development will create new high quality homes sensitive to the local setting and context whilst expanding the Walsall residential community.
A sustainable, well connected development
The development is in a highly sustainable and well-connected location within walking and cycling distance of a range of facilities, services, public rights of way and public transport options.
A development which responds to the local landscape and enhances its environment
The planting surrounding the site will be maintained and enhanced to add to the character of the development and inform new public open space and blue-green infrastructure. Large areas of public open space will be created on the site, benefiting both the new and existing communities and bringing about potential environmental benefits for ecology and biodiversity offsetting.
3

2. Introduction
This Vision Document has been prepared by Barton Willmore on behalf of Parkhill Estates Ltd. Parkhill Estates is working with landowners to support proposals for residential development at a site off Walsall Road, Shelfield, Walsall, West Midlands.
The purpose of this document is to support the promotion of the site to accommodate residential development and associated public open space. The key aims and objectives of the document are to:
• Present a vision and design framework to guide and shape the proposals
• Review the site in the context of current Planning Policy
• Present an initial understanding of the site and the local context
• Present the emerging concept masterplan, supported by an explanation of the key design principles that have informed it. Site Location
The site is located off Walsall Road, Shelfield.
Shelfield is a village suburb within the Borough of Walsall, West Midlands, situated 3 miles north of Walsall, 6 miles north west of Sutton Coldfield and 9 miles north of Birmingham City Centre.
The site is located on the north western edge of Shelfied, approximately 0.5 miles from the village centre and is accessed from Walsall Road, which runs along the site’s south eastern boundary.



3. Planning Context
Local Planning Policy
The Development Plan in relation to this site comprises:
• Walsall Site Allocations Document (SAD) (2019);
• Walsall Town Centre Area Action Plan (AAP) (2019);
• The Black Country Core Strategy (BCCS) (2011); and
• Saved policies and maps from the Walsall Unitary Development Plan (2005).
The Black Country Core Strategy
The Black Country Core Strategy (BCCS) sets out the vision, objectives and strategy for future development in the Black Country up to 2026 and beyond. The Core Strategy identifies sufficient land to achieve 63,000 additional dwellings by 2026 and aims to provide 2,900 ha of employment land.
The strategy includes strategic and development management policies including: Policy HOU1 (Delivering Sustainable Housing Growth); Policy HOU2 (Housing Density, Type and Accessibility); Policy HOU3 (Delivering Affordable Housing); Policy TRAN2 (Managing Transport Impacts of
New Development); Policy ENV1 (Nature Conservation);
Policy ENV2 (Historic Character and Local Distinctiveness);
Policy ENV3 (Design Quality); Policy ENV5 (Flood Risk,
Sustainable Drainage Systems and Urban Heat Island); Policy
ENV6 (Open Space, Sport and Recreation); Policy ENV8 (Air Quality); Policy WM5 (Resource Management and New Development).
Site Allocation Document
The Site Allocations Document (SAD) is the plan that identifies specific sites to meet the current and future needs of Walsall. The SAD replaces many of the policies in Walsall’s Unitary Development Plan (UDP), in particular the Proposals Map which shows the land uses that are currently allocated for individual sites. The role of the SAD is to provide policies relating to the allocation of land for development, and the
designation of sites that are to be protected, based on the
BCCS.
The SAD policy map shows that the Site lies within the Green
Belt. Part of the Site is designated as a Special Scientific
Interest (SSSI) and a Site of Local Importance for Nature Conservation (SLINC). There are also areas of flood zones 2 and 3 shown within the Site.
The SAD includes a number of policies including: Policy HC2
(Development of Other Land for Housing); Policy HC3
(Affordable Housing and Housing for People with Special Needs); Policy GB1 (Green Belt Boundary and Control of Development in the Green Belt); Policy EN1 (Natural Environment Protection, Management and Enhancement); Policy EN3 (Flood Risk); Policy T4 (The Highway Network); and Policy T5 (Highway Improvements).
Emerging Policy
The Black Country Core Strategy (BCCS) is currently being reviewed to meet the new challenges and opportunities up to 2039 as the Black Country Plan (BCP).
The Draft Black Country Plan 2039 is being consulted on until October 2021 and the next steps are expected as follows:
• Pre-Submission Consultation (Regulation 19) – August/ September 2022
• Submission – March 2023
• Examination – April 2023/March 2024
• Adoption – April 2024
Draft Black Country Plan
The draft BCP is currently being consulted on. The BCP contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039. It contains a Vision for the Black Country in 2039, underpinned by strategic objectives and priorities. It sets out that the Black Country Authorities will deliver at least 47,837 new net homes and at least 335ha of employment land.

The draft BCP Policies Map shows that the Site remains within the Green Belt, and that part of the Site remains designated as a Special Scientific Interest (SSSI) and a Site of Local Importance for Nature Conservation (SLINC). The Site is also allocated as a Mineral Safeguarding Area (draft Policy MIN2). The draft residential allocation for the site includes an indicative capacity of 35 dwellings, based on an indicative developable area of 1.35(ha), and provides further specific information in relation to the development of the site.
The draft BCP also includes a number of strategic and development management policies. Comments in relation to these policies can be found in the representations submitted alongside this vision document.
Supplementary Planning Guidance/Document
Designing Walsall (July 2013)
The Designing Walsall SPD seeks to set out more detailed planning policy guidance on the principles of good design for all types of development. It supports the urban and landscape design policies in the Walsall Unitary Development Plan (UDP) and the Black Country Core Strategy 2011 (BCCS). Affordable Housing (February 2008)
This SPD seeks to guide the delivery of affordable housing to appropriate locations in the Borough, whilst at the same time providing for balanced, mixed communities. It sets out that 25% affordable housing will be sought on new developments of 15 dwellings or more.
Conserving Walsall’s Natural Environment (July 2013)
The SPD provides guidance on complying with the Black Country Core Strategy and Unitary Development Plan policies for the protection of the natural environment to ensure it is considered within the development process. It emphasises the importance that development makes a positive contribution to Walsall’s natural environment.
Black Country Air Quality (February 2017)
This SPD sets out guidance for addressing air quality issues, especially as a result of transport emissions. This joint SPD covers the four local authority areas (Dudley, Sandwell, Wolverhampton and Walsall), all of whom have declared the whole of their areas as Air Quality Management Areas (AQMAs) in respect of nitrogen dioxide, primarily associated with vehicle emissions.
Other Material Considerations
National Planning Policy Framework (NPPF) (2021)
The NPPF sets out the principles by which the new Plan will be produced and examined against. There are a number of key paragraphs in relation to the promotion of this site through the local plan process:
• The importance that a sufficient amount and variety of land can come forward where it is needed in order to meet the Governments objective of significantly boosting the supply of homes (paragraph 60);
• The need to establish a housing requirement figure for the authority’s whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (paragraph 66); and
• The need to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability (paragraph 68).

4. Site Context
The site is located on the north western edge of Shelfield in a highly sustainable location within walking distance of local facilities and services in Shelfield to the south and Walsall Wood to the north.
The site is currently in agricultural use and is bounded as follows.
Northern Boundary: The northern boundary of the site is demarcated by planting with fields beyond.
Southern/Eastern Boundaries: To the south and east the site is bounded by Walsall Road and development fronting on to Walsall Road.
Western Boundary: To the west the site is bounded by existing planting and landscape with residential development and existing allotments in Shelfield beyond.
Facilities and Services
There are a number of facilities and services within walking distance of the site located in Shelfield and Walsall Wood. These facilities include local centres, convenience stores, supermarkets, pubs, a number of primary and secondary schools, and medical facilities.
The site is also within walking distance of a number of sports, recreational and community facilities including Greenfields Allotments
There are a number of schools in the local area with the closest Primary School being St. Francis RC Primary School (approximately 0.6 miles, 12 minutes walk from the site) and the closest Secondary School being Ormiston Shelfield Community Academy (approximately 0.9 miles, an 18 minute walk from the site).

Bus
The closest bus stops to the site are located on Walsall Road approximately 0.2 miles from the proposed site access. These stops serve the 10 bus route, a very regular service, which runs between Walsall and Brownhills west with a daytime frequency of approximately one bus every 10 minutes.
Train
The closest train stations to the site are Bloxwich and Walsall, both located approximately 4.2 miles (a 12 minute drive or 20 minute cycle) from the site. Additionally Walsall can be reached via the aforementioned 10 bus. Walsall and Bloxwich offer the same regular services to Rugeley via Cannock, Birmingham New Street and Birmingham International (both via Wolverhampton).
Walking/Cycling
The site is located within close proximity of a number of Public Rights of Way including an existing public right of way across the site which will be retained as part of the proposals..
Car
The site is located on Walsall Road, a main road running between Walsall and Lichfield, connecting to both the A5 and M6 Toll. The site is additionally well located for key onward road connections to the M6 and subsequently the M5 and M54.

 
5. Opportunities & Constraints
The findings from the initial site and context assessment have been evaluated to identify the emerging constraints and opportunities relevant to the development of the site.
The composite plan in this section presents the analysis of these elements, the qualities of the site and its immediate setting that provides the context for future development proposals. The positive features and opportunities on and around the site should be retained, enhanced and incorporated into the scheme where possible, to strengthen local distinctiveness.
Opportunities
• Any development proposals on the site could be accessed via a new access onto Walsall Road.
• There are a number of Public Rights of Way (PRoWs) on the site and in the surrounding area which could be connected into as part of the proposals to improve local connectivity.
• There is significant existing planting located on the site which can be retained and enhanced to inform new public open space and green corridors and add character to the development.
• The site is within walking and cycling distance of a number of nearby facilities and services in Shelfield and Walsall
Wood.
• The development can take advantage of the existing landscape to inform new blue-green infrastructure and bring additional environmental benefits by creating areas for potential Biodiversity offsetting.
Constraints
• A proportion of the site is located within Flood Zone including Flood Zone 2 and 3 as well as Surface Water Flooding. Future modelling and/or groundworks may be required.
• The site is located within the green belt.
• Part of the site is located within a Site of Special Scientific Interest (SSSI) designation.
 
6. The Proposals
Key Guiding Design Principles
The plan for the site has been informed by the vision, site analysis and identified constraints and opportunities. The key design principles which underpin the development of the site are summarised below:
• The concept masterplan proposes a mdoest residential development area with potential scope for up to 100 dwellings.
• As part of the development, the existing planting and landscape on the site will be retained and enhanced as much as possible, informing new green-blue infrastructure, public open space and giving character to the development.
• Areas for biodiversity offsetting could be included as part of the proposals, taking advantage of the large area of open space within the site and bringing additional environmental benefits as part of the development.
• A large area of public open space will be created as part of the proposals including potential for a 4.0ha Wetland Wildlife Country Park; benefiting both the proposed and existing residential communities.
• The development will utilise existing topography to create new attenuation areas and blue-green infrastructure to mitigate the risk of flooding as part of the development proposals.
• Further modelling works and/or proposed groundwork may be required at the next design stage to produce a comprensive drainage strategy to facilitate development on some areas of the site.
• The northern area of the site (shown hatched blue) will be retained as an area for potential future development.
 
7. Development Benefits
The proposal will deliver an attractive well-connected residential development of up to 100 high quality homes, set within a strong landscape setting, with extensive public open space, providing potential environmental and community benefits as part of the proposals.
Creation of high quality homes for all
The development has the potential to create up to 100 new high quality homes sensitive to the local setting and context whilst expanding the Walsall residential community.
A sustainable, well connected development
The development is in a highly sustainable and well-connected location within walking and cycling distance of a range of facilities, services, public rights of way and public transport options.
A development which responds to the local landscape and enhances its environment
The planting surrounding the site will be retained and enhanced as part of the proposals. Large areas of public open space including a potential 4.0ha Wetland Wildlife Country Park will be created on the site, benefiting both the new and existing communities. The site also offers significant environmental opportunities through potential ecological mitigation and biodiversity offsetting.

[Policy-specific commentary on the Highfields North site]

Development Strategy

It is our view that the Site at Highfields North, Walsall would have limited harm to the
purposes of the Green Belt and to landscape character, and should be considered suitable and available for development adjacent to existing housing. The Site is in a sustainable location, with a wide range of service and facilities located within walking distance. There is a co-op store located approximately 600m to the south west, and a primary school located approximately 650m to the south west. There is a medical centre and pharmacy located 500m to the east (walking distance) as well as a pub, gym and post office also located nearby. The Site is also accessed from the Walsall Road (A461), which is also a bus route, with existing bus stops adjacent to the Site providing links to Walsall and Brownhills. The development of this Site would therefore support a sustainable pattern of development and would also be able to offset the impact of removing land from the Green Belt through compensatory improvements to the environmental quality and accessibility of the undeveloped area of the Site and potentially at Parkhill Estate’s other land interest at Ryders Mere to the north. This is considered to meet the requirements outlined within paragraph 142 of the NPPF.

3.7 As part of the development, the existing planting and landscape on the site will be
retained and enhanced as much as possible, informing new green-blue infrastructure, public open space and giving character to the development. A large area of public open space/ecology area will also be created.

Placemaking – Achieving well-designed places

3.11 The Vision Document (at Appendix 2) demonstrates that the Site and its surroundings
have been considered in detail and that the initial design is sympathetic to local character and history, including the surrounding built environment and landscape setting, and will function well with and add to the overall area. As the design of the development evolves, there will be a focus on ensuring a sense of place and optimising the potential of the Site to accommodate and sustain an appropriate mix of housing to reflect local need in this highly sustainable location.

Housing Density, Type and Accessibility

The proposals at Highfields North would reflect the type and accessibility requirements as set out in the most recent Strategic Housing Market Assessment, and would meet the minimum net density requirement to ensure the most efficient use of land in this highly sustainable location.

Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

the proposals at Highfields North would seek to include a policy compliant level of affordable housing in line with the draft policy requirement.

TRANSPORT

At Highfields North, whilst it may not be necessary to bring public transport into the Site, there are existing bus stops adjacent to the Site that provide links to Walsall and Brownhills. Active travel links such as pedestrian and cycle access will incorporated to enable cohesive access to these bus stops as well as the main route to a range of services and facilities within 600m of the Site.

Nature Conservation

9.2 Whilst the developable area at Highfields North sits within Jockey Fields SSSI, Natural England confirm the SSSI is in ‘unfavourable – declining’ condition. The Concept Plan (drawing reference: BM-M-14 revision A) (at Appendix 2) demonstrates that only part of the area defined as a SSSI would be developed and Parkhill Estates would be willing to ensure mitigation to the remainder of the Site as well as potentially providing compensatory provision at their other land interest at Ryders Mere to the north, which could include formalised public access dependant on discussions with Walsall Council. It should also be noted that the Black Country Authorities are unable to make adequate provision for housing and the development of this Site would provide up to 100 new homes, whilst allowing for mitigation measures that would improvement the condition of the Site, and also allow the use of Parkhill Estate’s other land interest at Ryders Mere for further nature conservation and/or public access.

We would seek to ensure that the development of Highfields North would deliver a minimum 10% biodiversity net gain in line with Policy ENV3.

Open Space, Sport and Recreation

The Concept Plan (drawing reference: BM-M-14 revision A) at Appendix 2 demonstrates that the development of this Site would significantly exceed any requirement for public open space and could potentially also open up the land at Ryders Mere for formal public access dependant on discussions with the Council in this regard.

Design Quality

The development of Highfields North would seek to ensure a high quality design in line with the requirements of draft Policy ENV9 and the supporting guidance.

Flood Risk

Whilst we note that Walsall Council’s own modelling work by JBA consulting shows that the majority of the Site is either Flood Zone 2 or 3, we are currently undertaking further modelling to ascertain the true extent of the flood risk within the Site. We hope to be able to provide a copy of this further modelling work as soon as possible.

Object

Representation ID: 22301

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

Call for Sites ID 332 / 10332 - Land South of Little Aston Road, Aldridge, Walsall
1.1 These representations to the Draft Black Country Plan (‘the BCP’) have been prepared by Lichfields on behalf of Investin Plc (‘Investin’). We focus on the strategic matters that are contained within the BCP and relate specifically to Investin’s land interests at land south of Little Aston Road, Aldridge, Walsall.
1.2 The site was submitted through the Call for Sites process and has been assessed accordingly:
Table 1.1 Call for Sites Submission
Site ID: 332
Form ID: 10332
Address: Land at south of Little Aston Road, Aldridge
Site Area (ha): 9.5
Source: Black Country Plan Interactive Site Map
1.3 A Vision Document is submitted alongside these representations which demonstrates how up to 170 dwellings could be delivered on land south of Little Aston Road, Aldridge, Walsall. [Entered as a separate submission]
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.