Object

Representation ID: 16587

Received: 09/10/2021

Respondent: Mr Kevin James

COMMENT 5b: LGS APPLICATION FOR THE THREE FIELDS, STOURBRIDGE
Document: Draft Black Country Plan Site assessment Report... Appendix A - Dudley
<https://blackcountryplan.dudley.gov.uk/media/18569/comp_appendix-adudley.pdf?fbclid=IwAR0yuByEkO9Xceyrb8M1iE9bsrEn8HIse7jSHAsuBL96PkX9C6z76cgScP8>
Section: A-6 Sites Assessed for Local Green Space
Comment type: OBJECTION
I object to the following site not receiving a Local Green Space (LGS) Designation
• ID 10511*, The Three Fields, Norton, DY8 3LS
(*as so designated in the Draft Black Country Plan Site Assessment Report... p. 534).
for the following reasons:
• I believe that, due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.
• The Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application. The site is
extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity, seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to
future generations.
• The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of
the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’. It forms part of a wider green corridor and offers walkers access to the wider
countryside. It is used by dog walkers, and encourages a ‘sense of community’ amongst the socially isolated. It is very popular with children, for informal recreation, games, and nature study. The site has been used in the past for organised social activities and could be used
again for similar activities as well as by local schools and community groups in activities related to the local natural environment.
• The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p.
537 of Appendix A). However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise… the
community value of land” (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘green belt’. This site should therefore be granted a Local Green Space designation.
• This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields. It is
possible to enjoy sunrise and sunsets, and because of dark skies, the stars at night. There are extensive views over local countryside, fields, woodland and distant hills. The dominant soundscape is that of birdsong. 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 is 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).
• The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).
• In addition, the site, which abuts the ancient county boundary, may contain sub-surface archaeology relating to the Wollaston Ridge boundary dykes to the north (James, 2019a: 1–6).