Object

Representation ID: 16915

Received: 05/10/2021

Respondent: Darren Ford

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.

Site: ID 10511, The Three Fields, Norton DY8 3LS
Objection to The Three Fields, Norton DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation, 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.

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.

Tranquillity: 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).

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton)