- 17/08/2022
- Posted by: Valerie Vaz MP
- Category: News
A new site was added to the Black Country Plan which would be situated east of Skip Lane and north of Woodfield Close. In my view the proposed development of 135 houses on the site is in breach of several policies, which includes protecting Green Belt. The ownership of the the land is still unclear I would urge the removal of the proposed site from the BCP. The Site Assesment raised a number of red flags in relation to this Site. Residents should send their views to BCPA by:
- Completing the consultation form: https://blackcountryplan.dudley.gov.uk/media/20432/bcp-reg18-ii-comments-form-july-22.pdf. You will need to email the completed form to: [email protected] or send it to: Planning Policy, Walsall MBC, The Civic Centre, Darwall Street, WS1 1DG.
- Alternatively, you can use the online portal to make your comments: https://blackcountry.oc2.uk/document/65
My letter in full is set out below:
Dear Sir/Madam
Re: Black Country Plan (BCP) Ref: WAH276
Additional Site East of Skip Lane and Woodfield Close (the Site).
I refer to the above proposed development for 135 houses (the Development) on the Site as an additional site to the BCP which is in breach of the following policies:
1. Consultation
I am concerned that there is a limited consultation period which runs from 11 July-5 September 2022 which in my view is inadequate as it takes place during the Summer when many constituents will be away and I would request an extension until the end of September 2022. In addition, the links for the consultation are inaccessible and difficult to find on the webpage.
2. Green Belt
The NPPF states at para 147 that “inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.” In my view there are no Very Special Circumstances to outweigh the harm to the Green Belt:
(i) NPPF para 149 states, “A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are: limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites)” There is no mention of affordable housing and therefore no very special circumstances to outweigh the harm to the Green Belt.
(ii) A recent report by WMCA “Assessment of the Potential for Additional Brownfield Land Development Capacity” published on 30 June 2022 concluded that brownfield land in the Black Country has not been fully utilised for development and half of the 7700 homes, currently marked for the Green Belt, could be built on brownfield.
3. Sustainability of the Site
a. Sustainability Appraisal (June 2022)
(i) The BCP’s Sustainability Appraisal, page 51, table 3.1, sets out concerns with the proposed Site as having “issues around accessibility to health care and primary schools that need to be resolved. The character of the surrounding area is lower density than we are looking to use in BC Plan. Conservation Area issue needs to be resolved.”
Given these issues need to be resolved, the Site should be withdrawn.
b Site Assessment – July 2022
The Site Assessment lists multiple concerns with the Site’s sustainability regarding environmental and service issues:
(i) At page 660 the Site Assessment rates the damage to the Green Belt as “high harm” if development proceeds.
(ii) A red rating is applied for biodiversity, owing to the significant threat to local wildlife if development goes ahead as page 661 states “Loss of trees could result in a loss in protected species which is a significant issue. Record of protected species found near to the site. The hedges along Skip Lane are a designated SLINC. The habitats present support a good diversity of flora and fauna, which have resulted in the sites SLINC status”.
(iii) There are environmental concerns which are set out in the Site Assessment which states, “loss of protected trees and ecology SLINC status are significant constraints to developing this site, in addition the site is within the Conservation Area.”
(iv) A red rating is given for primary school access, owing to the fact its “predominantly not within 15 mins pedestrian access” and the closest high school is 25 minutes by local transport.
(v) The Site has a red rating for GP/Health Centre/Walk In owing to “no access to GP by public transport or pedestrian methods.”
3. Site Allocation Document (SAD) – January 2019
(i) The SAD states in section 7.2, “Most types of development, except for a limited list set out in the NPPF, are inappropriate in the Green Belt.” This development does not meet any of the requirements of the NPPF as restated in the SAD and therefore is not an appropriate site.
(ii) the Development conflicts with Section 7.8.1 of the SAD which states, “The Council has a duty to preserve or enhance the character and appearance of conservation areas.”
(iii) As the site is in the Great Barr Conservation Site, the development conflicts with policy EN5. “The Council will seek to ensure that development preserves or enhances the significance of conservation areas, including their setting, character and appearance”.
4. Unitary Development Plan (UDP) 2005
(i)The UDP states in 3.104: “The Council has a duty to preserve or enhance the character and appearance of conservation areas” The Site’s location in the Great Barr Conservation Area fails to comply with para 3.104 and para 3.12; “development proposals should not destroy, damage, or adversely affect nature conservation interests.”
(ii) Policy ENV2 states that “In the Green Belt there will be a presumption against the construction of new buildings,” and the development of the Site would fail to meet any of the exemptions outlined in Policy ENV2, to justify construction on the Green Belt.
5. Land Ownership
WMBC have confirmed that the applicants may not be “in full control” of the Site. There is uncertainty as to who are the responsible owners of the Site and the Site should not have been put forward for Development.
Conclusion:
The Site is inappropriate for the Development, as it fails to meet any criteria for building on the Green Belt and should be withdrawn as:
(i) no special circumstances exist to outweigh the harm to the Green Belt;
(ii) the sustainability of the Site is not met as there is a lack of access to services, such as a GP or primary school;
(iii) the Site assessment confirms there will be significant environmental damage, harm to biodiversity, harm to local wildlife and habitats, including the removal of trees and a loss of protected species; the hedge at Skip Lane is a SLINC;
(iv) this development is in breach of the SAD and the UDP;
(v) there are adequate Brownfield sites in the Black Country to develop the necessary housing; and
(vi) the ownership of the Site is unclear.
Therefore, the Site, new site land East of Skip Lane and Woodfield Close should be removed from the BCP.
Yours ever
Valerie Vaz
Rt Hon Valerie Vaz MP