Object

Representation ID: 18023

Received: 11/10/2021

Respondent: Mike Wood MP

Please find enclosed a copy of my response to the consultation on the draft Black Country Plan, with regard to sites reference DUH208 at Holbeache and DUH211 at the Triangle in Kingswinford.

I object to the proposal to release these sites from the Green Belt, and have particular concerns relating to:

• Loss of green space and recreational facilities
• Impact on local wildlife and natural habitats
• Impact on local main roads that area already congested and have high levels of
air pollution
• Impact on local schools and health services
• The site is poorly located for the parts of the Black Country that are expected to
experience highest population growth over the course of this plan.

I do not believe that these proposals meet the statutory threshold for releasing Green
Belt land for development and hope that you will reconsider

Ref: DUH208 (Holbeache) and DUH211 (The Triangle, Kingswinford)

I am responding as the local Member of Parliament for Dudley South to object to the proposals for sites DUH208 and DUH211, two of the few remaining Green Belt sites in the constituency that I represent.

For generations these spaces have provided a place for people to exercise and relax and their importance has only become more apparent in the last two years as they have proved vital to people’s physical and mental health throughout the pandemic.

The proposed release of this green belt land is completely inappropriate and unacceptable. The National Planning Policy Framework makes clear that Green Belt boundaries should only be altered under limited and fully evidenced exceptional circumstances. This threshold is not met in this case, and there are no such exceptional circumstances that would warrant the inclusion of Holbeache and The Triangle in this Plan and so the Green Belt designation should be retained.

If these sites were released the effect on the local community would be wholly negative.

As well as the damage caused to the local environment, and to natural habitats, developing these two Green Belt sites would have an unbearable impact on local infrastructure and public services, many of which are already stretched to their limits.

My office already receives regular complaints about congestion on the roads of Wall Heath and Kingswinford. With a UK average of 1.2 cars per household, an extra 863 homes would result in at least 1,035 additional cars on local roads. In reality, because of poor public transport connections serving the two sites, it is likely that most of the new houses would have at least two cars each.

Our local road network is simply unable to cope with this increased traffic. The main roads around these developments – the A4101 between Kingswinford and Russells Hall Hospital, and the A491 Stourbridge-Wolverhampton road – are both very busy roads, suffering from heavy congestion during peak times and with little opportunity to relieve existing pressures through road improvement works. The parts of the A491 around Wordsley High Street – less than two miles from these two sites – already have some of the worst levels of air pollution anywhere in the West Midlands. Building nearly 900 more on houses on these two sites – on top of the more than 1,000 other homes within two miles of the sites that are either proposed under this plan, are under construction or have been completed in the past few years – would bring our local highways to a standstill.

Our public transport system likewise could not cope with 863 new homes. Largely limited to buses without ready rail access, increased demand will impact reliability and availability. At a time when pressing environmental concerns mean the Government is encouraging anyone who can to use public transport making our service more crowded and less reliable would be a backwards step.

There would also result in increased pressure on our local schools. The majority of schools in the area are already oversubscribed, without a significant investment in our local schools they will be unable to support new pupils.

Our local NHS services, whether Russells Hall Hospital or our GPs, would also struggle with the increased pressure. Already people struggle to see a Doctor face to face, this would only become harder if this plan were to go ahead. Reducing ready access to necessary medical treatment could have long-term health impacts on my constituents that I find unacceptable.

With mounting concerns about sustainability and biodiversity, destroying this natural habitat on the edge of our communities would be a mistake. We must protect this natural inheritance, acting as stewards so that future generations can witness protected species like red kites and enjoy the sight of blooming poppies at the Triangle and daffodils at Holbeache.

The methodology underlying the draft Black Country Plan is fundamentally flawed. Instead of recognising the need to link areas for development with levels of population growth in different parts of the region, the draft plan is indifferent to where in the Black Country sites are located. This has led to the perverse - and illogical - proposal that very large numbers of houses (including those that have either recently been completed or which are currently under construction) ought to be developed in a small area around Kingswinford and Pensnett even though ONS project very low levels of population growth in those parts of the region, while boroughs with far higher projected population growth are due to build far fewer new homes than Dudley. This is enormously unfair on residents in Dudley who face the loss of precious green spaces so that homes can be built that are not needed by local people, but it is also unfair on those families in areas of the Black Country that will need many more houses but will be expected to move miles away to the other side of the region.

There is a clear need for decision-makers to make renewed efforts to secure additional brownfield sites, to invest in any land remediation necessary to make them suitable for housing development, and to avoid development on important green spaces such as these.

I very much hope that these objections are not only noted but that these sites are removed from the draft plan at the first opportunity.