Object

Representation ID: 16155

Received: 07/10/2021

Respondent: Mrs Anna Partridge

Title of document: Draft Black Country Plan To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley

Nature of comment: ‘Objection’

I object to the allocation of the following four sites in the Draft Black Country Plan:

DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
DUH217, Grazing Land Wollaston Farm, Stourbridge.

I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.

Reasons for objections:

Sites: 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 a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mitigation for this.

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.

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.

I object to the allocation of the above site for development on the following bases:

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 by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it 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 (Site Assessment Report).

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.