Comment

Draft Black Country Plan

Representation ID: 16552

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Representation Summary:

Housing: (BCP pg. 87-119):
Greenhouse gas emissions contribute to global temperature rises and we already
know we must reduce them to avoid 1.5°C of warming. 42% of greenhouse gas
emissions in Dudley Borough come from housing.
Sustainable homes are vital to protect the most vulnerable people from climate
breakdown. In Dudley Borough only 31% of homes are well insulated and
13% of households are in fuel poverty. Poor insulation contributes to this
problem. The Council should develop a heating and energy efficient strategy by 2025
for the borough. Action plans must include improved regulations regarding new
builds in the private and rented sectors as well as schemes to carry out retro fit in
both council stock and private homes. Planning permission should require all homes
built in Dudley Borough to be extremely energy efficient, using the Passivhaus
standards.
• We want Dudley MBC to ensure 100% of homes are well insulated to
minimum EPC C level, eradicate fuel poverty as fast as possible.
• Retro fitting and upgrading the insulation of 9,513 homes per annum
within the Dudley area will ensure all homes are properly insulated by
2030, lifting as many people as possible out of fuel poverty.
• Only 22 existing eco heating systems have been fitted in the Borough to date.
Dudley’s official government target is 25,383 but the FoE Target for Dudley
is to fit 55100 heat pumps by 2030.
The Borough has 64 neighbourhoods with high social flood risk for surface
flooding (Nov. 2019) taking account a range of vulnerability factors.
Trees and green biodiverse community spaces clean up air pollution as well as
mitigating against both flood risk and heat islands in residential or built-up areas
with no green space or shade. All housing developments and refurbishments should
ensure that community green space and tree planting are a priority for all future
development as well as a reduction in the density of houses and roads to reduce
flood risk.
Spatial Strategy and Infra Structure: (BC Plan pg.20 – 70) and Black Country
Centres (BCP pg. 140 – 173)
Economic, housing, leisure and cultural development need to be reviewed holistically
as part of the spatial development strategy. An innovative regeneration of our town
centres should take into account people’s changing work patterns, reduced need for
office space and retail space, working from home, health, well-being, encouraging
people to shop locally, provide educational, leisure and cultural opportunities near to
people’s homes supporting both community and family life.
Friends of the Earth Stourbridge: 11.10.21:
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Town centre buildings should be re-purposed to provide a mixed economy of use but
building on what is already there rather than demolishing good functioning
businesses. At the time of writing a row of thriving local businesses are proposed for
demolition at no. DUH008 14 Colley Gate for housing development; whilst a row of
abandoned buildings are left standing next to the proposed development. This
appears to make little sense and a waste of resources and good businesses.
We would like to see town centres including Tiers 1,2 and 3 with more pedestrian
and cycle friendly. For example, Stourbridge High Street is currently congested with
traffic and has poor air quality from the High Street and also the Ring Road. We
would like to see the High Street pedestrianised with limited traffic flow for deliveries
and greening of the streets as in other of Dudley’s towns. We would like to see the
ring road have better traffic calming measures and more accessible crossings. The
subways are dingy and dangerous after dark and should be removed.
Pedestrianisation and greening should be extended further in the other town centres
and greening of the streets with trees and planters to increase bio-diversity as well
as shade. This will improve local environments for community interaction, increased
health well-being in open social green spaces.
On residential streets we would also like to see more limits on traffic flow for
example the Street Play initiative uses existing council powers to close a street to
traffic for several hours, allowing children to play together in the street. This is a
brilliant initiative for building community and is particularly beneficial for
disadvantaged communities with no gardens and limited access to parks. Play
streets today could be accompanied by an initiative to green the street with trees
and planters, and some of the closures could even be made permanent.
As well as supporting retro-fit for people working from home the Council could
encourage the development of shared working spaces or hubs, in the town centres
of Tiers 1, 2 and 3. This would enable people to use of good quality, accessible and
well-equipped spaces close to home as well as to meeting spaces for formal and
informal interaction. Free wi-fi should be a feature. If these spaces were no more
than 10 minutes walking distance of people’s home then it may well reduce
commuter traffic and improve air quality. Libraries provide some of these facilities
but there are not enough in the borough.
Creating good quality jobs near to where people live will also ease road congestion
in the am/pm commute and improve air quality. Town centre development in Tiers
1,2 and 3 should be included in this and developments made alongside leisure,
cultural, social and retail facilities (not just food retail) included. Green space and
green corridors should also be a feature of exciting and innovative plans so that no
urban area is too far in walking distance from open green space.