Draft Black Country Plan

Object

Representation ID: 21465

Received: 11/10/2021

Respondent: Lower Penn Preservation Group

I'm raising an objection on behalf of Lower Penn Preservation Group about the use of greenbelt land in this plan. Brownfield sites should be the major focus of the plan for future developments, as recently stated both by the West Midlands mayor and the prime minister.

Duty to Cooperate:

The Black Country Plan should focus its efforts on using brownfield sites within its authorities rather than exporting its requirements to South Staffordshire. As South Staffs is 80% green belt, this in effect forces them to use their green belt to meet the Black Country requirements (4000 houses) under the duty to cooperate.
(Draft Black Country Plan - Policy CSP1 – Development Strategy- Section 3.20 page 31)

Thus the Black Country responsibilities relating to the sustainability of any developments is being sidestepped by pushing green belt development onto neighbouring authorities. The Black Country sustainability appraisal actually states that the sustainability impacts of exporting development to neighbouring authorities has not been considered by them.
(Black Country Sustainability Appraisal – Section 1.4.4 page 5)

The group believes that more up to date modelling of use of urban spaces will give a more accurate view of housing demand and potential release of space for residential use following the Covid pandemic. This will allow more protection to be afforded to the natural environment in the green belt areas both within the Black Country authorites and within the neighbouring authorities.

Names and addresses of the members of our group that support these statements are attached below.