Object

Draft Black Country Plan

Representation ID: 11879

Received: 30/09/2021

Respondent: Mr Roger Evans

Representation Summary:

OBJECT
The plans state that decisions on planning applications for these sites should be made in accordance with the specific policy requirements. We/ I object on the grounds that this proposal is not taking into account your own policy requirements and design principles as well as those laid out in the National Planning Policy Framework. The policy states proposals for redeveloping existing uses within the green belt will only be permitted if very special circumstances can be demonstrated or the proposal meets the criteria set out in national planning policy.

The land is currently used for agriculture and should not be changed as per the statement above. There are no special circumstances which suggest this designation should be changed nor would it be in line with the framework principles,

Your policy document states that one of the design principles is "Improvements to local facilities to support residents and to enhance the sustainability of the existing area, in particular improved capacity at the primary school and local health centre". The existing area will not be enhanced as there is no infrastructure for transport and schools are already significantly oversubscribed as well as the local health centre. Widening the local roads will have a significant negative impact to local residents, increased traffic, air pollution, noise all which are identified as factors which should not have an adverse impact on the local area.

There are no existing drainage amenities suitable for such an extensive development and any development will directly contradict your principles of delivering landscape, biodiversity and amenity benefits.

The development will directly and negatively impact your strategy for landscape and habitats creation that provides enhancement, retention and mitigation for established trees and hedges. Any development will have a significant adverse impact on visual amenity and on animal species.

The site is in a Mineral Safeguarding Area and should be safeguarded as per the National Planning Policy Framework, Section 17 "safeguard mineral resources". There is a huge need to safeguard our natural resources and this land should be retained for its original designation, agriculture and minerals.

All developments should be based on the "presumption in favour of sustainable development" and the above factors do not comply with this.

The proposals to allocate the site for housing directly contradict your strategic priority 11 which is to protect and enhance the natural environment, biodiversity, wildlife corridors geological resources, countryside, and landscapes. The site is used for agriculture, grade 3A and is consistently producing crops each year. Any change to this will significantly affect the livelihood and economic well being of the people involved in this valuable food production system.

The proposals to allocate the site for housing directly contradicts strategic priority 12 which is to protect, sustain and enhance the quality of the built and historic environment whilst ensuring the delivery of distinctive and attractive places. Our area is a very distinctive and attractive place which will be completely decimated and the landscape ruined with development. Visual amenity will be lost and economic detriment on house values for all the local residents.

The proposed allocation of this site wholly and significantly contradicts your policy CSP 3 which states “A defensible green belt to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents; with the landscape safeguarded and enhanced where possible for its heritage, recreation, agricultural and nature conservation value” and “the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible”.

The further areas of the national planning policy framework which are contradicted include:-
Section 11- recognise that some undeveloped land can perform many functions, such as for wildlife, recreation, flood risk mitigation, cooling/shading, carbon storage or food production;

By developing this land you are not giving suitable recognition that this land is already performing several of the above (wildlife, recreation, food production) without the need for development.

Section 13- protecting green belt land. Strategic policy making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the green belt boundary, towards towns and villages inset within the green belt or towards locations beyond the outer green belt boundary. Where it has been concluded that it is necessary to release green belt land for development, plans should give first consideration to land which has been previously-developed and/or is well- served by public transport.

The land has not been previously developed nor should it as being in a MSA. It is not served well by public transport and would be considerable investment in infrastructure.

Section 15 - conserving the natural environment. Planning policies and decisions should contribute to and enhance the natural and local environment by:
a) Protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services- including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;

Any proposal to develop this site for housing does not conserve or enhance the environment, it will be completely destroyed. The valued landscape will disappear as well as all the current biodiversity generated from the agricultural operations. Our beautiful countryside will be removed and as stated previously the economic benefit from versatile agricultural land will be lost. This is simply unacceptable and wrong to affect so many livelihoods and extended beneficiaries of the ecosystem especially when it is perfectly and reasonably possible to use suitable brownfield land which all authorities need to give substantial weight to as well as using other suitable sites which can be remediated and developing underutilised land and buildings to meet housing needs where available sites could be used more effectively.

Our local MP also considers that the proposals do not explore enough the brownfield first policy and she has launched a petition to support the fact that we must promote regeneration on derelict and neglected urban sites in the Black Country and we have won millions in government funding to do just that. As it stands, Walsall's housing allocation can be met for the next five years without any building on our green belt