Object

Draft Black Country Plan

Representation ID: 17732

Received: 11/10/2021

Respondent: Ms Heather Davies

Representation Summary:

This is an firstly an objection to the following:
- BCP REF DUH213 - Lapwood Avenue Open Space
- BCP REF DUH216 - Bryce Road Playing Fields
- BCP REF 203 - Ketley Quarry (policy DSA3)
- BCP REF DUH222 - Severn Drive Open Space
1. Traffic impact on site (DUH213 Lapwood). The selected site Lapwood Avenue open space is directly opposite a primary school, on a road that is already severely congested, and parking takes up both sides of the road and surrounding roads, several times throughout the day. Building 45 houses on this field would cause further difficulties for parents accessing the school, and residents of the estate. The site assessment for this site suggests, there would be no "impact on the wider road network", but a significant effect will happen on the more local road network, several times a day, outside the school.
2. Effect on road safety (DUH213 Lapwood/BCP REF 203 Ketley). It is not yet confirmed whether a through road will be built from Lapwood Avenue through the new Ketley Quarry development; this would create a cut through shortcut between Bromley Lane and the main Dudley Road, which would likely cause a significant increase in traffic moving through the estate not only at peak times, but at all points throughout the day, and further problems leaving the estate at the Bromley Road junction. This would significantly increase traffic, and decrease road and pedestrian safety on the estate, especially at peak school times. This is a strong objection to this and would expect a specific consultation on this if it was proposed.
3. Effect on road safety and car parking for schools (DUH213 Lapwood). A new housing estate on Lapwood Avenue would reduce availability of car parking for the school which is already over congested, and decrease road safety, with more cars travelling through, increasing the risk of an accident.
4. Traffic impact on site DUH216 Bryce Road. Bryce Road is a narrow cul-de-sac road, and Blackwater Close is similar, both of which will have to take significantly more heavy traffic during construction of a housing site, and ongoing increased traffic when the site is built. This is unsuitable for the style of road here.
5. Effect on road safety (DUH222 Severn Drive, DUH216 Bryce Road) Increased traffic through Corbyns Hall estate from Bryce Road, including Severn Drive would increase the risk of an accident happening on the estate. Cars from 100+ houses on Bryce Road would need to leave somewhere - either through a small access road at Bryce Road, or into another housing estate at Blackwater Close. There are not assisted crossings in any of these sites, due to their quieter nature, which would no longer be the case.
6. Ketley Quarry (BCP REF 203): Generally, residents support the development of houses on the Ketley Quarry site, as it's expected this will decrease anti-social behaviour from individuals and groups unlawfully using the quarry for recreation at present, and remove what is considered locally to be a considerable eyesore, and also supports building on brownfield sites. However, residents strongly do not support the provision of a through road through to the Crestwood Estate, are concerned about access to the Ketley Quarry site from the proposed road over Dawley Brook from the Ploverdale Estate, and do not support the building of such a large number of houses on the quarry site.
7. Effect on school admissions (all sites). There are insufficient school places for children across the area. For September 2021 admissions, the only secondary school with places for year 7 is Wordsley. Most other year groups are full. There are no places for Reception in Wall Heath for 2021; only one school in Kingswinford with places. Creating spaces by enlarging existing schools will change the character of them, or force buildings that take away car-parking, play areas or fields.
8. Effect on NHS (all sites).
- There are not enough local doctors and dentists in the local area. Residents are being forces to travel out the area to access care. Wall Heath and Kingswinford have a number of elderly residents who cannot physically do this - due to their own capabilities and lack of public transport
- Pre-lockdown, the average waiting time at Russell's Hall was over 4 hours (2019). April '21 inspections show it still 'requires improvement'
- Longer ambulance wait times (In 2020, the turnaround times reached 60 mins)
-Further delays in local health services, mental health services (rapidly growing), hospital treatment and operations for serious illness
9. Effect on Mental Health (all sites). The BCP calls out that Kingswinford South and Wordsley specifically have a below standard quantity of public open space. These spaces are very important to local residents, for many uses, but frequently including dog walking, and safe spaces for children of all ages to play and socialise, specifically they (DUH213 and DUH222) are within sight of many of the local houses, and considered safe by older residents too. Many residents purchased houses on these estates specifically because of access to this space, and over the pandemic lockdowns the use of this space increased even further. Green spaces are proven to have a significant benefit on mental health, particularly for those who may not have gardens themselves, and they are providing more benefit than ever before.
a. The BCP identifies Ketley Field Open Space as a suitable alternate space to allow for loss of Lapwood Avenue; however, this site frequently floods (hence the recent planting of many young saplings across the field) and although it has a playground, it is of poor quality, with very little equipment for younger children, and much of the equipment that is there is damaged and broken.
b. Residents generally disagree that Ketley Fields is of higher quality and value.
c. For older residents at the opposite end of the estate, this may be too far to walk.
d. The Lapwood field is generally always a busier space than the Ketley Fields space, with more residents using it for a variety of purposes.
e. The open space review for Severn Drive (DUH222) failed to identify any activities taking place yet they it is very often used and any resident could have helped identify this, so the green space assessment is flawed.
f. The open space identified in the site assessment as replacements for Severn Drive (DUH222), Mayflower Drive and Derwent Close open spaces, together make up about a quarter of the space to be lost on Severn Drive, and neither are suitable in terms of terrain or shape to many of the activities carried out on Severn Drive. Neither of these sites were large enough to be audited in the Open Space Review 2017, so the council obviously is not aware of the quality of these spaces and should not propose them as alternatives.
g. Each of the open space reviews identify that the open spaces in question suffer in their quality / value rating solely due to lack of council investment in them rather than lack of resident usage, which happens in spite of the lack of investment!
10. Loss of biodiversity (all sites). Although not designated as SLINC or similar, there are frequent sightings of foxes, and bats over Lapwood Avenue, Bryce Road, and Severn Drive sites, owls are heard over all the sites every year, and numerous species of birds are observed. Loss of the sites would lead to loss or displacement of these animals.
11. Local flooding (DUH213 Lapwood Avenue) Alongside the field, Fitton Avenue floods on a fairly regular basis, and it is expected that building houses on the field will not contribute positively to drainage issues locally.
12. Impact on children and adults with disability and the loss of the accessible green space in the community - would not be able to walk to a green space further away.
13. (DUH213 Lapwood Avenue) I believe this is not in accordance with the original agreement of the use of the land which had restrictions placed in house deeds and on green spaces.
14. The National Planning Policy Framework (the government's planning policies) says "where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality should be preferred to those of higher quality" and identifies that:
-sites of biodiversity should be protected and any impacts minimised (para 170)
- Land with the least environmental or amenity value should be considered for development and habitat networks and green infrastructure should be maintained and enhanced (para 171)
- Protect and enhance biodiversity and geo-diversity and safeguard local wildlife-rich habitats and priority habitats and species, and ecological networks (para 174)
- Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. (para 147)
10. The government is stating that brownfield sites should be used and not Green Belt sites. This should be considered across the whole of the region before ANY green belt site should even be considered for development.