Object

Draft Black Country Plan

Representation ID: 11467

Received: 03/10/2021

Respondent: Mrs Rebecca Cockerton

Representation Summary:

These comments apply to Black Country site Assessment Report - Dudley Appendix A, Page 79. The Triangle SA-0025-DUD (DUH 211) and Holbeache DUH 208. It is far better to use old factory sites (Brownfield) and re-develop inner cities to revive town centres. Developing green belt means the loss of access to countryside. The enormous increase in vehicles will mean increased pollution with obvious road safety consequences. The area struggles to contain the volume of traffic already running through it and there are insufficient doctors surgeries, schools, shops and emergency services within Dudley to serve the area. The proposal to build 533 new houses on the triangle alone would increase the local population by 1279 (Office of National Statistics occupation rates are 2.4 people per household. Local Health services are already over-subscribed and unsustainable. Providing more 'high value' housing does not solve the problem of a lack of affordable or social housing, which would also need a more sustainable infrastructure of health facilities, education, mass transit and employment centres.
We stand to lose ancient trees, natural habitats and biodiversity. There will be a loss of wildlife and an impact on the fields and meadows. An increased flood risk affecting drainage of the area and ground water. The housing proposals do not meet affordable housing targets with expensive housing within areas of green belt.
The National Planning Policy Framework states that 'where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality should be preferred to those of higher quality and identifies that:
Sites of biodiversity should be protected and any impacts minimised (para 170);
Land with the least environmental or amenity value should be considered for development and habitat networks and green infrastructure should be maintained and enhanced (para 171);
Protect and enhance biodiversity and geodiversity and safeguard local wildlife-rich habitats and priority habitats and species, and ecological networks (para 174);
Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances (para 147