Publication Plan April 2024

Comment

Representation ID: 5958

Received: 29/05/2024

Respondent: Walsall Council

The new plan will replace rather than alter the previous local plan. The penultimate sentence which begins "The Green Belt boundary is altered" should therefore form part of the supporting text rather than be part of the policy itself. The revised Green Belt boundary will be defined on the amended policies map as referred to in the first sentence of the policy.

It is considered that an alternative to the term "damaged and derelict land" should be used as it could provide justification for development on land that has been damaged intentionally. It might be preferable to use the term "previously developed land" as this is defined in national policy.

Comment

Representation ID: 5959

Received: 29/05/2024

Respondent: Walsall Council

This policy should refer to the specific sites that the policy will apply to.

Comment

Representation ID: 5961

Received: 29/05/2024

Respondent: Walsall Council

The employment types to be allowed on the listed sites should refer to class E(g)(ii) and (iii) and exclude offices within class E(g)(i), as offices are a main town centre use.

Comment

Representation ID: 5962

Received: 29/05/2024

Respondent: Walsall Council

The term "major housing development" should be defined to ensure that the policy is sound. We recommend that it should refer to developments of 10 or more homes in accordance with the definition of major development in the GDPO.

Object

Representation ID: 5964

Received: 29/05/2024

Respondent: Walsall Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Strategy is largely as proposed in letter dated 24 October 2023. NPPF paragraph 35 still stands and that plans are 'sound' if they are positively prepared and meet, as a minimum, the area's objectively assessed needs and the unmet need from neighbouring areas is accommodated where it is practical to do so.
Note the wording in paragraph 145 of the December 2023 NPPF. However, national planning policy should be viewed as a whole. The proposal to reduce the number of homes proposed to contribute to meeting the needs of neighbouring authorities from 4,000 to 600 does not align well with the test of soundness requiring plans to be positively prepared.
Birmingham and the Black Country do not have capacity to accommodate housing or employment land needs. South Staffordshire have taken an active role in the preparation of evidence which supports this. The December 2023 NPPF revision does not alter this need or the supply shortfall.
The draft SoCG acknowledges significant shortfalls in housing arising from the Black Country and therefore Walsall remain to be convinced how it can then be concluded that "SSDC no longer considers that all of the previous proposed Green Belt sites are justified by exceptional circumstances". The need for changes to Green Belt boundaries should be established by the evidence of housing need at the strategic level, and there has been no demonstrable change in the evidence to justify exceptional circumstances that might support detailed amendments to boundaries in relation to individual sites.

Comment

Representation ID: 5965

Received: 29/05/2024

Respondent: Walsall Council

Note that the duty to cooperate paper submitted as part of the evidence base for the local plan includes a statement of common ground with Walsall. It is marked as draft but it has not been endorsed either by Walsall's officers or members.