Object

Representation ID: 16145

Received: 11/10/2021

Respondent: Mrs Anu Sahota

Comments on Draft Black Country Plan
Reference: BCP-SGR-2021: Stourbridge group response to Draft Black Country Plan
SUMMARY
I object to the allocation of the following green belt sites for the reasons listed:
Sites: DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane
Central, Stourbridge DUH209, Worcester Lane South, Stourbridge Objection to
allocation because:
Sites lie in an Area of High Historic Landscape Value (AHHLV) Sites are adjacent to a
Site of Local Importance for Nature Conservation (SLINC) Release would constitute
unacceptable harm to the green belt.
Site: DUH217, Grazing Land Wollaston Farm, Stourbridge Objection to allocation
because:
Site should be used as a public open space.
Site falls in an area of high Landscape sensitivity Site should be protected due to
Tranquillity We object to the following site not being designated as a Local Green
Space (LGS)
Site: ID 10511, Three Fields, Dunsley Road, Norton.
Objection to this site not being designated as LGS because:
The site meets all criteria for a Local Green Space (LGS) LGS designation would
demonstrate its significance to the community.
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I OBJECT TO THE ALLOCATION OF THE THREE WORCESTER LANE SITES FOR
THESE REASONS:
Site reference numbers: DUH206, Worcester Lane North, Stourbridge; DUH207,
Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV.
Strategic Priority 12 is to "protect, sustain and enhance the quality of the built and
historic environment." See also Policy ENV5, p. 230. All three are green field sites
with grade 3a agricultural land situated in a strongly rural landscape and contain
public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation,
agricultural and nature conservation value”, these sites should not be allocated.
Proximity to Site of Local Importance for Nature Conservation (SLINC): There is an
adjacent SLINC, as well as mature trees and hedgerows, and I/we believe that no
mitigation would be sufficient to be considered sustainable.
Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green
Belt harm for these three sites. There would be no clearly “defensible boundary” to
this development (Policy GB1, and para 3.16). Development would also encroach on
the open countryside between Hagley and Pedmore, going against at least three of
the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted
sprawl, (b) preventing neighbouring towns merging into one another, and (c)
safeguarding the countryside from encroachment.
I/WE OBJECT TO THE ALLOCATION OF GRAZING LAND WOLLASTON FARM
FOR THESE REASONS: Site reference number: DUH217, Grazing Land Wollaston
Farm, Stourbridge.
Public open space: The site is located within Community Forum 7, where there is a
below-average quantity of open space. It was well-used in the past, before the public
were excluded from the site. I/we believe the site should be re-opened to provide a
much-needed green space in this area which could additionally be developed as a
wildflower meadow.
Landscape sensitivity: This is a green belt, green field site, which although having no
agricultural rating and defined as ‘urban’, falls within area S17 having high landscape
sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity
Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be
considered to constitute “significant planning constraints which cannot be mitigated",
despite the high levels of housing land which the BCP is seeking to meet.
Tranquillity: The NPPF states that planning policies should "identify and protect
tranquil areas which have remained relatively undisturbed by noise and are prized for
their recreational and amenity value for this reason" (NPPF 2019, para 180(b)). The
government guidelines on what constitutes a tranquil place are that it is "relatively
undisturbed by noise from human sources that undermine the intrinsic character of
the area" with a positive soundscape for e.g. of birdsong. ("Guidance: Noise", HMG
2019, para. 8). This site should be assessed for tranquillity and protected under
Policy GB1 (4) on protecting tranquil areas.