Object

Representation ID: 15069

Received: 30/09/2021

Respondent: Lynda and Colin Bateman

We write to lodge our formal objections to certain aspects of the Draft Black Country Plan released for consultation on 16" August 2021 and to put forward alternative proposals to those particular aspects.

Our concerns centre around

A. Proposals to utilise Green Belt land in Dudley for residential Development
B. Use of the three specific 'sites' of Green Belt land in Worcester Lane Pedmore for provision of 115 properties.

A.Proposals to utilise Green Belt land for residential development

l.The loss of any green belt land has an immediate and devastating negative impact on:

- Animal wildlife; flora and fauna; loss on natural habit for many species
- Resources for local communities to enjoy for walking/cycling/exercise etc
- Health and weilbeing of local people
- Air pollution in the area
- Our future children's wellbeing
- Biodiversity

2.The justification to use Green belt land is fundamentally flawed. Whilst the future need for the quantity of properties has to be taken as read - given that it appears to be based on a Government calculation - the assessment carried out to justify the need for Green Belt has -by it's own admission in paragraphs
1.1.1 to 1.1.4 of Fl of the draft plan - only been at a 'baseline' level. This means that for all of the sites put forward in the Call for Sites process only a relatively cursory exercise against the 11 SA objectives has been done. Few informed local circumstances have been fully considered for each site to enable a true and fair assessment to be made. This has resulted in over 60 of the sites being rejected.

Of these rejections one has no reasons provided (27); others rejected for access issues (e.g. 222 ,114) ; viability (59); employment area (
64,186,227);Iand adjacent to school(109); Topography or difficult to develop(109,173,181,182,188,189,191,205). The numbers in brackets are the reference numbers in the SA in the plan documents.

In total these could amount to around 1000 properties.

Whilst we realise some of these may ultimately prove not suitable for development we believe that these ALL need full and detailed appraisal beyond the baseline one the draft plan acknowledges is all that has been carried out BEFORE any Green Belt land is flagged as potential.

Only then can we at least safeguard ALL our Green Belt prior to a full and detailed justification to loose any of it

3.There are also a number of Brownfield sites within the Borough that have been removed from the process due to 'landowners engagement exercise' which we understand means the landowners will not cooperate e.g. 0082; 00102; 00104; 00105 00114 ;00115 (ref to Brownfield sites register). Surely the 15 year life of the plan gives adequate time for some of these to be brought back into negotiation and made use of- this has to be a better strategy than loosing Green belt land on day one of an approved plan. A simple trawl of local estate agents can also identify vacant commercial and industrial sites that have potentially 'fallen through the net' - again effort must be put into identifying and using these within the plan no matter how difficult development may be . We must not allow Green belt to be used simply because it is virgin land and easy and profitable for developers.

4.Once Green Belt sites are in the plan they will be lost on the day it becomes 'live' - with the prime sites on Green Belt put forward developers will immediately start the process. Whereas if some of these other sites (albeit they may appear to have development issues) were in the plan instead, then time is on the owners and Council's sides to sort out the difficulties and build on those instead. The plan covers 15 years - that gives time enough to work with these other sites to sort the difficulties and thus provide the properties needed. No evidence has been seen that says the shortfall in properties has to be addressed at the start of the plan period - therefore time should be taken to bring these others forward and NOT the Green Belt sites which will be lost on day one of the plan and can never be recovered.

In addition the proposal directly goes against Council Policy CSP3 of Dudley Development Strategy (P37 of Draft BCP) To go against the policy when options exist (above) is wrong