Draft Black Country Plan

Comment

Representation ID: 22481

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

DUTYT TO COOPERATE
South Staffordshire District Council has sought to work closely alongside the Black Country
authorities in addressing its strategic cross boundary issues, primarily its unmet housing needs and
emerging potential employment land shortfall. We welcome the progress on the Black Country
Plan to date and support the Black Country in its efforts to meet its own development needs as
fully as possible whilst progressing Duty to Co-operate discussions with surrounding authorities to
address any remaining shortfalls. The comments below outline where the District Council consider
clarifications or alterations are required to the evidence which sits behind the proposed Draft Black
Country Plan policies, in order to fully address national policy requirements and respond to
regional evidence on unmet needs.

We note the findings of the Black Country Plan Duty to Co-operate Statement July 2021. However,
we are not entirely clear from the published statement what the intended next steps are to
distribute the Black Country’s housing and employment shortfalls. Specifically, there is no clear
reference to the evidential basis that will be used to determine surrounding authorities’
contributions to the GBHMA/Black County unmet housing needs or employment needs (if arising).
Given the Black Country’s role in currently generating the majority of unmet housing needs within
the GBHMA, it is important that the Black Country clarifies where additional contributions to its
unmet needs are required based on the existing GHBMA evidence base. It is equally important that
the Black Country does not solely accept existing housing contribution offers proposed by other
local authorities before deferring any remaining shortfalls to subsequent early reviews of Local

Plans to address any remaining shortfalls. Such an approach would fail to engage with the existing
HMA evidence base (i.e. the 2018 GBHMA Strategic Growth Study) and could risk undermining the
progress of plans in the surrounding area.

Given the number of years the HMA has had to respond to its findings, it is important the Black
Country ensures the findings of the 2018 GBHMA Strategic Growth Study are reflected in Duty to
Co-operate discussions on unmet housing needs with surrounding authorities. In the first instance,
we consider that the existing strategic growth locations recommended in each local authority area
around the GBHMA should be fully explored and delivered as far as possible, given the cross-
authority evidence base that sits behind them. We would only consider it appropriate to not bring
forward these recommendations if a local authority could show these are truly not deliverable or
that there are more sustainable options within its area that could accommodate a similar level of
growth. We would welcome clarity on whether the Black Country intends to pursue such an
approach to provide a framework for further Duty to Co-operate discussions prior to submission of
the Black Country Plan.


Notwithstanding the comments made above, it is acknowledged that there is a significant
possibility that the locations identified in the GBHMA Strategic Growth Study 2018 may not be
capable of fully addressing regional housing shortfalls, particularly in light of the emerging review
of the Birmingham Development Plan. To address this issue, we would support the Black Country
and Birmingham Authorities in seeking to review and update the 2018 Strategic Growth Study and
would welcome involvement in such a study. Any such review should:

• Build upon, rather than replace, the existing growth locations proposed in the 2018
Strategic Growth Study
• Offer an independent audit of urban capacity across the GBHMA, identifying areas where
further work could identify further non-Green Belt housing supply
• Be based upon close engagement with the West Midlands Combined Authority and any
other relevant Integrated Transport Authorities to ensure future growth locations are truly
aligned to existing or proposed sustainable transport improvements

To deliver the findings of any reviewed HMA-wide evidence base we would also support any
efforts to establish governance arrangements for the co-operation process on unmet housing
needs. The lack of such a formal structure has created significant uncertainty in current local plan
reviews and could be crucial to the effective delivery of any future updated growth study
recommendations.

Throughout the consultation period on the South Staffordshire Local Plan which is due to
commence on the 1st November, we will continually assess any housing shortfalls within the
context of duty to cooperate and our proposed approach to date. Further conversations regarding
our proposed contribution may be required depending on the outcome of ongoing duty to
cooperate conversations and the ongoing progression of Local Plans in our and neighbouring HMA
areas.

Support

Representation ID: 22482

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

PLAN
We trust that the above comments assist the Black Country in finalising its approach prior to the
submission of the Black Country Plan. Overall, the District Council is supportive of the efforts to
date made by the Black Country Plan to address its development needs and intends to continue co-
operating with the Black Country to address these issues, subject to further discussions on the
matters set out above. We would welcome further discussions with officers to agree ways forward
on these points.

Support

Representation ID: 22483

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Gypsy and Traveller allocations
We welcome the Black Country’s efforts to ensure that it fully meets its own Gypsy and Traveller
allocation needs as set out in Policy HOU4 of the Draft Plan. South Staffordshire will shortly be
publishing updated evidence regarding its own Gypsy and Traveller pitch needs as part of its Local
Plan Review. This will comprise an updated Gypsy and Traveller Accommodation Assessment
(GTAA), Pitch Deliverability Study and evidence of the likely capacity on potential public sites
within the District. It currently appears that this will show a significant shortfall against the
District’s plan period and 5 year pitch needs, which cannot be accommodated even when all
existing Green Belt site release is maximised and all potential public traveller sites are explored.
Given the Black Country’s proximity to South Staffordshire and the extensive Green Belt supply
South Staffordshire will have to explore we would welcome engagement on the following matters
prior to the Black Country Plan later in 2021 to establish:

1. If the Black Country can remove/reduce the need for South Staffordshire to accommodate
additional pitch needs within its Green Belt;
and
2. Whether the Black Country can assist in accommodating South Staffordshire’s remaining
pitch needs once all deliverable Green Belt site options in South Staffordshire are
accounted for.

Support

Representation ID: 22484

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Employment needs and functional geography
The clarity that the Draft Plan provides in relation to Black County’s employment land requirement
is welcomed, with it noted that that the plan will seek to provide for a minimum of 565ha up to
2039 with this figure based upon the findings of the Black Country EDNA update (August 2021).
The Draft Plan confirms that following site assessment, the plan has been able to provide for 365ha
of this within the administrative boundaries of the Black Country. It is understood that this supply
is made up of allocations within the urban area, redevelopment of existing employment premises,
other site that have planning permission for employment developments and 48ha of employment
allocations within Walsall’s Green Belt.

It is recognised that this results in a shortfall of employment land, with paragraph 7.12 of the Draft
Plan confirming:
“210ha or 37% of employment land need arising in the Black Country cannot be met solely within
the Black Country. This unmet need should be exported, as far as possible, to authorities that have
a strong existing or potential functional economic relationship with the Black Country, for example
in terms of migration patterns, commuting links and / or connectivity through physical
infrastructure such as rail and motorway. This work is ongoing and will be secured through the Duty
to Co-operate and evidenced through Statements of Common Ground.”

Whilst we recognise that cooperation on unmet employment needs is ongoing, the above
statement is somewhat ambiguous as to what the Black Country authorities consider to be the
most appropriate functional geography for addressing unmet employment needs. The PPG
confirms that when addressing strategic matters under the Duty to Cooperate and confirming
these through Statements of Common Ground, the geographical area for doing this will depend on
the strategic matter being planned for and ‘the most appropriate functional geographical area to
gather evidence and develop policies to address these matters, based on demonstrable cross-
boundary relationships’. It is therefore critical that clarity is provided on what you consider the
functional geography for addressing your unmet employment needs is, in order to enable swift
progress with Statements of Common Ground following our respective Regulation 18
consultations.

We recognise that South Staffordshire has a strong functional economic relationship with part of
the Black Country, specifically Dudley, Walsall and Wolverhampton, but it is unclear from the
statement above what other authorities the Black Country consider fall within the functional
geography. The Black Country EDNA (2017) recognises South Staffordshire and Birmingham as
areas ‘areas of strong economic transactions with the Black Country’ and Cannock Chase, Lichfield,
Tamworth, Wyre Forrest, Bromsgrove and Solihull as ‘areas of moderate economic transactions
with the Black Country’ so it seems appropriate given the scale of the shortfall that solutions are
sought across the wider geography. It is also noted that Shropshire are proposing a contribution of
30ha of employment land towards Black Country employment needs and their evidence relating to
the M54 growth corridor does appear to imply there are functional links between the Black
Country and parts of east Shropshire, so including Shropshire within the functional geography is
also considered appropriate.

It is also noted that the Black Country EDNA update (August 2021) concludes that the plan should
seek to provide for around 30% B8 activity and 70% E(g)(ii)/(iii)/B2. It is unclear from the Draft Plan
if the proposed employment allocations are along these lines and therefore whether the plan is
seeking to deliver new employment along this split. Subject to a review of the South Staffordshire
EDNA, it is expected that we will have a significant oversupply of B8 land (as a result of the WMI
consent) and therefore your policy intentions for this issue may affect the contribution we can
make towards your unmet employment needs. Confirmation of this is sought, and if the aim is to
achieve this split, then details of the shortfall for B8 and E(g)(ii)/(iii)/B2 should be separately


provided to inform Duty to Cooperate discussions, as well as confirmation of whether the most
appropriate functional geographies differ between B8 and E(g)(ii)/(iii)/B2 needs.
In summary, we seek confirmation on the following:

1. Which authorities does the Black Country consider fall within the most appropriate
functional geography for addressing your unmet employment needs?
2. Is it the Black Country’s intention that the plan seeks to provide for 30% logistics (B8) needs
and 70% commercial (E(g)(ii)/(iii)/B2)? If yes, then please could you provide a breakdown of
what your shortfall is by use class.
3. If the Black Country are looking to provide for a split between B8 and (E(g)(ii)/(iii)/B2) uses,
can it confirm what the functional geography is for each use (if different).

Support

Representation ID: 22485

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site delivery in Walsall
Notwithstanding our concerns regarding Dudley’s site selection process, we support the Black
Country’s efforts to identify housing growth within the Green Belt. Across the Black Country, the
Draft Plan appears to release land capable of delivering 7,720 dwellings within the Green Belt up to
2039. The vast majority of this supply arises from Walsall, which is proposing 5,418 dwellings up to
2039 on Neighbourhood Growth Areas identified within the local authority’s Green Belt.

South Staffordshire does not object to the sites selected in the Walsall area, subject to cross-
boundary working to understand and mitigate any cross-boundary infrastructure impacts.
However, we do have concerns that the figures given in the Draft Plan for the selected sites under-
represent their true contribution to housing supply within the plan period (i.e. up to 2039). Having
reviewed the sites in Tables 30 and 31 of the Draft Plan, we consider that the true capacity of the
selected Neighbourhood Growth Areas identified in Walsall is likely to be around 1,715 dwellings
higher than the figure given in the consultation document. This is due to what appear to be overly
conservative estimates of larger site delivery affecting five housing sites allocated in the Walsall
area. The site-specific reasoning behind this is given in Appendix 2 of this response, but in
summary assumptions used to estimate site delivery up to 2039 appear to be contrary to the
assumptions given in paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study
(May 2021).

We would request this matter is revisited to ensure that the true capacity of Green Belt release in
Walsall is reflected in the submitted plan. Failing to do so will put unnecessary pressure on Green
Belt elsewhere in the Black Country and in other neighbouring authorities.

Comment

Representation ID: 22486

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site selection in Dudley
We welcome the findings of the Site Assessment Report: August 2021 and consider this to be a
mostly robust piece of work to identify sites for selection. However, we do have some concerns
regarding the lack of weight/regard given to the GBHMA Strategic Growth Study 2018 in the final
site selection process, particularly in broad locations identified by the 2018 study in the Dudley
area (Appendix A of that document).

It currently appears that only 860 dwellings are proposed on Dudley’s Green Belt edge, in two sites
forming the Kingswinford Neighbourhood Growth Area. However, previous correspondence
received from the Black Country authorities in response to South Staffordshire’s 2019 Spatial
Housing Strategy and Infrastructure Delivery (SHSID) consultation indicated that there was
potential for up to 5,000 dwellings to be delivered in Green Belt areas surrounding Dudley2. Whilst
we appreciate this was only a high-level indication of capacity, it also appeared to be broadly
consistent with the more detailed findings of the GBHMA Strategic Growth Study 2018. This
recommended that the western edge of the Black Country (including Dudley) could accommodate
500-2,500 dwellings through dispersed housing development, whilst the southern edge of Dudley
(around Halesowen) had the potential to accommodate a 1,500-7,500 dwelling sustainable urban
extension based around garden village principles. Whilst neither option was without its potential
constraints, these two areas of search were still considered on balance to be more sustainable,
deliverable and less harmful to Green Belt purposes than other strategic development
opportunities elsewhere within the GBHMA.

Given the acuteness of the regional housing shortfalls, it is important that the GBHMA Strategic
Growth Study’s recommendations are fully explored. In light of this, we do not consider that the
Site Assessment Report: August 2021 has given sufficient weight to the findings of the GBHMA
Strategic Growth Study 2018 and do not consider it currently offers a robust basis for establishing
the upper end of Dudley’s potentially suitable Green Belt capacity. Specifically, it currently appears
that large numbers of site options have been discounted on Dudley’s Green Belt edge not because
they are truly undeliverable, but because they are not considered to be sufficiently suitable (e.g.
sufficiently free from policy constraints) and have not arisen from a wider GBHMA-wide evidence
base. This also affects many sites in broad areas recommended for growth by the GBHMA Strategic
Growth Study 2018. Common reasons given in the site assessment conclusions for rejected sites in
Dudley’s Green Belt include:

• Levels of sensitivity/harm identified in the 2019 Green Belt Study and Landscape Sensitivity
Assessments
• Additional local designations or officer judgements which duplicate factors already
considered through the cross-boundary 2019 Green Belt/landscape sensitivity evidence
• Comments regarding proximity to heritage assets which do not indicate whether heritage
impacts could be mitigated or are likely to be significant, which do not appear to reflect an
accepted Historic England methodology for understanding of the significance of a heritage
asset3
• Constraints that are likely to be capable of mitigation/compensation through site layout
(e.g. minor areas of Sites of Local Importance for Nature Conservation (SLINC)/Sites of
Importance for Nature Conservation (SINC) coverage within a site, slight overlap with Flood
Zones on a site’s boundary corner)

A list of the sites within Dudley’s Green Belt that appear to be capable of delivery but have been
discounted largely on the basis of the reasons given above are included in Appendix 1 of this
response. [see attachment]


We also note that many of the sites listed in Appendix 1 fall within areas of Very High harm Green
Belt and Moderate-High landscape sensitivity4, which the Black Country have previously indicated
would be considered a significant constraint on site options5. We agree with the general principle
of considering sites options’ relative suitability based upon local Green Belt/landscape evidence
and do not have any concerns with the threshold proposed. However, we do not believe it is
appropriate to use such a threshold to discount strategic recommendations of the GBHMA
Strategic Growth Study 2018, given the scale of the shortfall and knock-on impacts this will have
on shortfalls elsewhere in the GBHMA. Green Belt purposes, landscape character impacts,
sustainability and deliverability of such locations have already been considered at a GBHMA-wide
level through the GBHMA Strategic Growth Study 2018. Therefore, in lieu of better HMA-wide
evidence, it is imperative that the recommendations of the 2018 study are fully explored and
delivered as far as possible.

If the Black Country are of the view that the GBHMA Strategic Growth Study recommendations
cannot be accommodated in the specific areas of search proposed in that study (e.g. South of
Halesowen) then it is imperative that other site options around Dudley’s edge are explored fully to
offset the loss of housing delivery this implies. This is particularly important as Dudley’s
administrative area holds significantly more areas of potential Green Belt than other Black Country
authorities (aside from Walsall). To do otherwise risks shifting these pressures into less sustainable
locations within the GBHMA which are more remote from the source of unmet need (the Black
Country). We do not believe it would be sustainable or desirable for all Green Belt land in Dudley to be allocated without regard to suitability factors. However, the Site Assessment Report: August
2021 clearly shows there is a wide choice of land (as indicated in Appendix 1 of this response)
capable of accommodating a higher Green Belt housing supply figure in this area, consistent with
the figures given in the previous 2019 correspondence from the Association of Black Country
Authorities and the scale of locations identified for growth in the GBHMA Strategic Growth Study
2018. We would welcome further discussions with the Black Country authorities to ensure a
consistent cross-boundary approach to this issue.


2 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf
bases (e.g. Areas of High Historic Landscape Value, judgements regarding settlement
patterns, defensible boundaries and settlement gaps etc.)
3 See Historic England guidance available here: https://historicengland.org.uk/images-
books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-
local-plans/)
4 As set out in 2019 Black Country Green Belt Study and Landscape Sensitivity Assessment
5 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf

Comment

Representation ID: 22487

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Urban Capacity Review Update May 2021

The published Black Country Urban Capacity Review Update May 2021 provides evidence of the
extent of the housing shortfall arising from the Black Country’s urban area, informing the housing
requirement set out in Policy HOU1 of the consultation document. We note and welcome the
attempts to maximise urban supply set out in this document and agree with the conclusion that
there will be a substantial shortfall arising from the Black Country urban area up to 2039. This is
consistent with the GBHMA-wide picture given in the GBHMA Strategic Growth Study 2018, which
indicated a significant shortfall would remain at a GBHMA-scale up to 2036 even if significant
density increases were realised in land supply across the GBHMA.

South Staffordshire therefore considers that the Black Country Urban Capacity Review Update May
2021 offers a reasonable basis on which to progress Duty to Co-operate discussions regarding the
Black Country’s urban housing shortfall within the GBHMA. However, before the extent of the
Black Country’s urban capacity is finalised through the submitted Black Country Plan, there are matters that we believe could be more fully addressed within the document, that may then help to
inform ongoing Duty to Co-operate discussions regarding the exact extent of the shortfall and the
scale of contributions required to address it.



Firstly, we note that the urban capacity review has sought to identify urban land opportunities
from annual updates of individual local authority SHLAAs, informed by regular call for sites
exercises. We acknowledge that this approach largely conforms to the historic approach set out in
Planning Practice Guidance for establishing housing land availability within an area. However, there
is a need for greater consistency on how urban supply is assessed across the conurbation, given
the Duty to Co-operate implications of shortfalls arising from this area. Specifically, Birmingham
City Council have recently commissioned assistance from the PropTech sector to find innovative
ways to survey its urban land supply, allowing it to identify and survey a far larger number of infill
site opportunities than would otherwise be possible through a traditional SHLAA exercise. This is
despite previous SHLAAs being found to be consistent with guidance at the time through the
Birmingham Development Plan examination. This work does not appear to be limited to increasing
densities in established urban centres and appears more reflective of the approach advocated by
the more recently published National Model Design Code, which encourages “[c]oding for the
intensification of lower density areas that use land inefficiently”1 when planning for an efficient use
of urban land. For consistency in approach across the housing market area to addressing the 35%
urban uplift in housing needs, we consider that the Black Country should work with the West
Midlands Combined Authority to explore similar approaches to identify further urban supply to
meet its needs.

We would also welcome a re-examination of the approach to windfall allowances within the urban
capacity review, which paragraph 2.1.11 confirms have been based upon past land supply trends
on small sites (i.e. sites of 9 homes or less). This suggests that future trends will not have an impact
upon windfall development realised within the Black Country and that there is no realistic scope
for windfall development on sites or 10 or more homes. Whilst we understand the desire to pursue
a conservative approach to such matters, we do not consider it fully reflects the opportunities for
windfalls identified in paragraph 71 of the NPPF, which also requires expected future trends to be
considered in establishing any realistic windfall allowance. We would support a slightly more
ambitious windfall allowance that had regard to recent and upcoming permitted development
changes (e.g. Class E to residential) that may not be fully reflected in current past trends, or the
potential for landowner intentions to change during the plan period on non-residential uses.
Given the significant scale of the Black Country’s housing shortfalls, we do not anticipate that
exploring the approaches set out above would alter the need for Duty to Co-operate discussions to
address housing shortfalls. However, they would offer greater comfort to surrounding authorities
within the GBHMA that the Black Country is truly maximising all available housing land within its
urban area and help to reinforce the necessity of housing contributions from other areas of the
GBHMA.

1 National Model Design Code – Part 2 Guidance Notes, Section U.1.i ‘Efficient Use of Land’

Comment

Representation ID: 22488

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Appendix 1 - Dudley Green Belt site options discounted but potentially capable of delivery [table] [see attachment]

[Taken table headings, presented here as headings:]
Ward/Site Reference/Site area

/Comments on site assessment [appears below these]:

Pedmore and Stourbridge East SA -0031 -DUD 19.8

Appears reliant on Green Belt/landscape factors in part for discounting. Heritage impacts cited as part of reason for unsuitability but no indication of 'substantial
harm'. Appears to have site frontage directly onto main road (Pedmore Lane); unclear why access is a constraint.

Kingswinford North and Wall Heath SA -0114 -DUD 27.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
Unclear why access could not be achieved through adjacent parcel (SA-0017-DUD)

Kingswinford North and Wall Heath SA -0033 -DUD 1.7

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
SLINC appears to be the only constraint preventing delivery of a site in otherwise less harmful Green Belt/landsacpe area.

Cradley and Wollescote SA -0034 -DUD 13.8 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only partially covers the site and the remainder could be feasibly considered

Cradley and Wollescote SA -0081 -DUD 64.2 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting archaeology is prohibitive.

Pedmore and Stourbridge East SA -0250 -DUD 20 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' to SAM indicating proximity is prohibitive.

Halesowen South SA-0088-DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' due to heritage effects; only a 'potential' to impact upon
setting.

Halesowen South SA-0087-DUD-B 30

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC/Ancient Woodland only cover small part of site and could be designed around.
Access concerns may be addressed through delivery alongside adjacent parcels (e.g SA-0242-DUD)

Halesowen South SA-0015-DUD 14.7

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why access onto Lapal Lane has been treated as a constraint as site appears to have
access onto other roads which could provide a satisfactory access

Halesowen South SA-0242-DUD 150

Appears reliant on Green Belt/landscape factors in part for discounting. Scale of potential development could deliver singificant scope for highways/access solution
and on-site facilities. SINC/SLINC/Ancient Woodland/Flood Zones only cover small part of site and could be designed around. Impacts around surface water aren't
clearly set out but at this scale it seems unlikely that they could not be designed around. No indication/evidence for why the potential harm on SAM setting is
considered to be substantial and therefore prohibitive. This appears to closely align to a recommendation made by the GBHMA Strategic Growth Study for a 1,500-
7,500 dwelling SUE South of Halesowen which doesn't appear to be given weight in site selection.

Hayley Green and Cradley South SA-0135-DUD 54 Unclear why SINC/SLINCs crossing site are considered prohibitive given significant site area - offers opportunity to design around these.
Halesowen South SA-0255-DUD 5.2 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0246-DUD 64 Appears reliant on Green Belt/landscape factors in part for discounting.

Sedgley SA -0125 -DUD 5.8

Appears reliant on Green Belt/landscape factors in part for discounting. Given the limited cover of pylons within the site, the significant site area and that the bat
corridor is only adjacent (not covering) the site, it is unclear why these constraints can't be overcome.

Pedmore and Stourbridge East SA -0018 -DUD - C 4.7

Text on page 106-107 indicates the site (Worcester Lane South) is suitable for development alongside adjacent parcels, acknowledging the potential to create a new
defensible boundary to the south; unclear why it hasn't been selected.

Pedmore and Stourbridge East SA -0251 -DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC only cover a small portion of the site and it is unclear why they cannot be
designed around.
Norton SA -0019 -DUD 1.37 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only affects limited area of site.

Gornal SA - 0139 -DUD 0.06

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why settlement pattern is considered a prohibitive constraint given the need to
increase densities within the Black Country.
Norton SA -0009 -DUD 1.19 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0091-DUD 2.73 Appears reliant on Green Belt/landscape factors in part for discounting.

Hayley Green and Cradley South SA-0244-DUD 1.5 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC/TPO coverage is only partial and majority of the site appears unaffected.

Norton SA -0018 -DUD - A 38

Appears reliant on Green Belt/landscape factors in part for discounting. Areas of lesser Green Belt harm with 20ha of non-SINC land; unclear why trees scattered
throughout site cannot be designed around/mitigated.


Norton SA -0018 -DUD - B 167

Appears reliant on Green Belt/landscape factors in part for discounting. Partial coverage of SINC/SLINC within the site but given the large site size (167ha) it is
unclear why impacts cannot be mitigated through scheme design. Intervisibility with SAM and archaeological factors given, unclear from information provided why
these would be prohibitive towards development or whether there would be substantial harm to heritage.

Gornal SA -0059 -DUD 10.6

Unclear from the information provided why the site is considered not deliverable within the plan period, despite the site proforma otherwise indicating that site
issues can be mitigated.

Cradley and Wollescote SA -0027 -DUD 6.87

Appears reliant on Green Belt/landscape factors in part for discounting. Given the site size it is unclear why the loss of a limited area of SLINC (hedgerow) loss could
not be mitigated within the wider site.

Gornal SA-0243-DUD 50.18

Appears reliant on Green Belt/landscape factors in part for discounting. Majority of the site (between Cotwall End Rd and Sandyfields Rd) appears to be a golf
course and it is unclear why this use precludes redevelopment.
Lye and Stourbridge North SA -0227 -DUD 2.13 Appears to be listed as a rejected site but is allocated elsewhere in the Draft Plan (but only for part of the site area - see DUH025)

Comment

Representation ID: 22489

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Appendix 2 – South Staffordshire comments on Walsall Green Belt site delivery [table] [See attachment]

[Table headers:] Site Reference/Address/Claimed delivery
potential (Black Country)/Estimated delivery potential (South Staffordshire)/Comments [appear below these]

WAH232 Yieldsfield Farm
(sometimes recorded as
Yieldfields farm), Stafford
Road, Bloxwich

978 (600 dwellings
by 2039)

978 by 2037 This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 dpa build rate



WAH234 Land between Queslett
Road, Doe Bank Lane and
Aldridge Road, Pheasey

1426 (960 dwellings
by 2039)

1426 dwellings by
2039

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 – 200 dpa build rate on sites significantly above 500 dwellings (implying a maximum potential
capacity of between 1,200 – 2,400 dwellings up to 2039)



Based on the above assumptions, the site only needs to achieve a 118 dpa build rate to be delivered
fully in the plan period. Given the site’s size and the recommended range of 100 – 200 dpa given in
the May 2021 report for such sites, it seems realistic to assume the site will be completed within the
plan period.



WAH235 Home Farm, Sandhills,
Walsall Wood

1417 (800 dwellings
by 2039)

1417 dwellings by
2039

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 – 200 dpa build rate on sites significantly above 500 dwellings (implying a maximum potential
capacity of between 1,200 – 2,400 dwellings up to 2039 on large sites in the Black Country)



Based on the above assumptions, the site only needs to achieve a 118 dpa build rate to be delivered
fully in the plan period. Given the site’s size and the recommended range of 100 – 200 dpa given in
the May 2021 report for such sites, it seems realistic to assume the site will be completed within the
plan period.



WAH238 Land at Vicarage Road /
Coronation Road, High
Heath

504 (400 dwellings
by 2039)

504 dwellings by
2035/36

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (3 years lead-in time, reflecting greenfield site)
- 50 - 60 dpa build rate (assuming one outlet)



WAH242 Calderfields West,
Aldridge Road, Walsall

592 (442 dwellings
by 2039)

592 dwellings by
2036 - 2038

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (3 years lead-in time, reflecting greenfield site)
- 50 - 60 dpa build rate (assuming one outlet)