Object

Representation ID: 4849

Received: 21/12/2022

Respondent: John Davies Farms ltd.

Agent: Berrys

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy SA5 of the Publication Plan proposes a number of site allocations that, as detailed in the Green Belt Study (2019) (table 7.1), would result in ‘moderate-high’, ‘high’ or ‘very high’ levels of harm to the Green Belt.
Such sites include sites 224 Codsall, 523 Cheslyn Hay, 536a Great Wyrley and 582 West of Wolverhampton. The release of these sites will therefore result in a weakening of the Green Belt, for example by leaving a narrow
gap between towns, increasing its containment by urban areas or by isolating an area of Green Belt that makes a stronger contribution (as detailed in paragraph 6.23 of the Green Belt Study).
Given the above, it is considered that growth proposed on allocations that would result in significant levels of harm (moderate-high and above) to the Green Belt, should be directed to sites where a lesser degree of harm
would arise and where the level of growth would ensure that the Plan:
- plans positively for the provision of housing sites of less than one hectare through the allocation of land (in accordance with paragraph 69 of the NPPF), as detailed in the representor’s objection to policy DS5;
- meets housing needs of lower tier (tier 4) settlements (in accordance with paragraph 78 of the NPPF), as detailed in the representor’s objection
to policy DS5; and
- maintains and enhances the vitality of rural communities and their local services (in accordance with paragraph 79 of the NPPF), as detailed in the representor’s objection to policy DS5.

The Plan is therefore considered to be unsound as it not justified (is an appropriate strategy, taking into account the reasonable alternatives).