Draft Black Country Plan

Support

Representation ID: 21451

Received: 11/10/2021

Respondent: Carney Sweeney Limited

Agent: Carney Sweeney Limited

Peveril Securities strongly support the Bushbury strategic allocation in Policy CSA1 in the draft Black Country
Plan (BCP) for housing and related purposes including the potential provision of a primary school and the
delivery of land as part of that process as an extension to the Northycote Country Park. The site allocations
WOH257, 258, 259 and 260 are supported.
Peveril has an agreement with the landowner to deliver the site for housing on all land north of Northycote
Lane and it is understood the Council (who owns land WOH260) is willing to also bring its land forward. Work
carried out by Peveril in relation to on-site infrastructure and environmental constraints has concluded that
there are no matters that would prevent delivery of housing and it is understood the same position applies to
the Council land. Thus, in terms of the important issue of the delivery of housing to meet identified needs (see
below), it can be concluded that the Bushbury allocation can be delivered because a house building company
has agreement with the landowner of most of the site and the second landowner (the Council) is also in a
position to deliver its land. It can be anticipated that once the allocation of the site is confirmed through the
Examination into the BCP, Peveril will actively progress a planning application with a view to delivering the
housing within the first five to seven years of the Plan period. This is likely to improve upon the phasing
proposals for delivery in paragraph D30 of the BCP.
To support the view that the site is capable of delivery, Peveril has prepared an up to date masterplan which is
attached. This demonstrates how the forecast housing numbers for the site in Policy CSA can be
accommodated through a comprehensive approach by a combination of Peveril and Council land and that the
key planning requirements for the development of the site can be met. The masterplan also shows how a
primary school site of the appropriate size can be accommodated on Council land.

The context of the NPPF advice in relation to the proposed review of Green Belt boundaries and the delivery of
appropriate levels of housing is important. Peveril supports the broad conclusions which the BCP reaches
concerning the spatial strategy (Policy CSP1 and CSP2) and the scale of housing land that is required within the
Black Country (circa 48,000 dwellings in the Plan period). They also support Wolverhampton's status as a
strategic centre. The economic investment being made in the City and the housing needs related to that
supports the logical conclusion that it is necessary for Wolverhampton to release land from the Green Belt to
accommodate housing requirements within the Plan period. Peveril is therefore supportive of that process and
the conclusion that has been reached (see Table 4 of the BCP).
In terms of the choices made in relation to Green Belt release and proposed housing sites which have fed into
the BCP, Peveril considers the release of Green Belt on the eastern side of the City represents the best option
to provide housing land in accordance with the NPPF advice relating to how to review Green Belt boundaries in
the Local Plan process. In this regard, the contents of NPPF paragraphs 140 to 143 have been complied with to
support the release of the land at Bushbury for housing purposes.
Specifically in relation to paragraph 143 of the NPPF, the review of Green Belt boundaries on the eastern side
of Wolverhampton is consistent with the Development Plan strategy for meeting identified housing needs –
with Wolverhampton one of the four strategic centres in which to locate a proportion of the housing needs
(covering criteria (a) of paragraph 143). As far as criteria (b), (c) and (d) are concerned, it is not necessary to
identify in this case safeguarded land between the urban area and the Green Belt because the proposed
allocation immediately abuts the urban area and is mainly between the existing urban area of
Wolverhampton; the tree belts in the Northycote Country Park and road infrastructure. As far as criteria (e) is concerned (and also related to criteria (f), the boundaries of the Green Belt shown on the masterplan are in
themselves permanent and defensible in the long term. They comprise potentially an estate road and tree belt
on the northern edge of allocation WOH259; established tree belts to the east of WOH258 and WOH257 (with
dedicated land extending the Country Park) and then Bushbury Lane defining the Green Belt boundary to the
east of WOH260. Therefore, these criteria of paragraph 143 are complied with.
In addition, the allocation of the Bushbury area would allow the tree belt to continue to perform the purposes
of the Green Belt in paragraph 138 of the NPPF. Whilst there is inevitably ‘encroachment’ into what is
currently countryside, this encroachment is limited and is defined (see below) by existing and proposed
significant boundaries such as tree belts, roads and other features. The other purposes of the Green Belt are
not significantly offended by the extension of the settlement to the east – to a great extent the eastern
boundary of the allocation is the woodland within Northycote Country Park. However, development on the Bushbury site represents a contained and managed extension of the settlement framework and would comply
with the criteria in draft Policy CSP1.
In this way the combination of the appropriate provision of objectively assessed housing need and the
redefining of Green Belt boundaries in accordance with NPPF policy results in the proposed Bushbury
allocation being considered 'sound' for the purposes of paragraph 35 of the NPPF.
Peveril therefore strongly supports Policy CSA1 of the draft BCP relating to this area and Policies CSP1 and 2
relating to the provision of objectively assessed need in Wolverhampton in the Plan period. This justifies the
need for the review of the boundaries of the Green Belt around Wolverhampton – in which release of land on
the eastern side of the City for the Bushbury area represents the best of the options that are chosen.
Peveril would welcome further dialogue with the City Council as planning authority (and landowner) to ensure
early delivery of the allocated site should it be confirmed through the Examination process.

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