Object

Draft Black Country Plan

Representation ID: 11242

Received: 24/09/2021

Respondent: Jane Lewis

Representation Summary:

I am objecting to Black Country Site Assessment Plan, Dudley, Appendix A, Policy DSA2 DUH211 The Triangle and Policy DSA1 DUH208 Holbeach Lane/ Wolverhampton Road
I object for the following reasons:
1. Loss of Greenbelt
Local and regional councillors, as well as the West Midlands Mayor, are all opposed to development of Green Belt and have said they have a "Brown Site First" policy. In a time of environmental crisis, Green Belt Should never be a consideration for development. The Black Country area has significant amounts of disused industrial, factory and office sites which are much more suitable for use to meet housing needs and I would suggest that until these have been exhausted no Green Belt should even be considered for development.

The National Planning Policy Framework states "Land with the least environmental or amenity value should be considered for development and habitat networks and green infrastructure should be maintained and enhanced" . This is a government planning policy but the opposite seems to be being proposed for the Dudley area which is completely unacceptable.

The two areas above are important in preventing urban sprawl along the Western Edge of the Black Country. This Green Belt area is also under significant threat from the South Staffordshire Local Plan earmarked for substantial development along the A449, By the Black Country themselves choosing to build here it undermines any objection to the SSCC plans.

The land is useful agricultural land, graded 3 and above.

Housing built on Greenbelt land is almost always "High value" - expensive properties aimed at the top end of the housing market - and this is no exception. this type of build does not help to meet the region's housing need for affordable, entry level and family housing.

2. Pressure of local facilities
This are has already playing its part in providing new housing with developments still under construction on several sites locally within a 2-mile area - specifically at Himley View (Taylor Wimpey). Stalling's Place (Keepmoat), Himley Meadows (Bloor) and Fletcher's Rise (Bovis) with planning for more properties to the North of Stallings Lane on Oak Land the Development of Ketley Quarry. None of these sites have any provision of infrastructure improvements. The impact of thee incomplete developments cannot yet be fully measures but even before these are finished the local facilities are already under strain. Adding even more homes is completely unsustainable
* Current doctors' surgeries are already oversubscribed,
* Local Schools are already at full capacity with no spare places, with The Triangle having no local primary school. The majority of local school sites are physically constrained by residential areas and so the suggestion within the proposal that they could expand to meet demand is not realistic
* The road infrastructure is already struggling with high levels of traffic and congestion. The A449 and A491 and regularly gridlocked at peak time and leading to increased air pollution and road safety concerns.

Adding a total of 883 new households into this, which based on ONS average occupancy would add 2120 to the local population, is not realistic. The infrastructure simply cannot cope.

3. Traffic and Transport
There are no significant areas of employment local to these proposed developments and so residents would be commuters adding significant pressure to the road network.
There is a lack of public transport of cycle route provision. Hansen already rates this area as having the worst commuting score from homes to places of work - this would further worsen.
There is no rail access, with the nearest station being 30mins drive away
All this will result in even more pollution, health and road safety issues.

4. Destruction of important local environments
Local green spaces have been incredibly important to the local population, particularly during the recent pandemic, to maintain and boost mental and emotional wellbeing of residents. In an urban area such environments are particularly important and should be protected.

These areas provide wildlife corridors linking green spaces and habitats for countless British Wildlife and include a SLINC, "Ashwood Haye Fields" the perimeter and internal hedgerows of the Triangle site. This site is also part of the Mid Severn Sandstone Plateau, which is important for habitat conservation, and next to Ridgehill Woods an important woodland that would be significant disrupted by any development of this kind.

Not to mention the contribution to climate change and the increased risk of flooding that urbanisation of green belt inevitable brings.

I cannot understand how any council can support the destruction of these important areas against the wishes of so many parties and a backdrop where "Green" issues at the forefront - especially when alternatives are available, and so I wish to object wholeheartedly to these proposals.