Object

Representation ID: 18140

Received: 10/10/2021

Respondent: Miss Tracy Hickinbottom

I would like to object to the following sites being taken forward in your Black Country Plan: DUH 031 Majors Paddock, Straits Road DUH218 Guys Lane Paddock DUH 210 Viewfield Crescent Paddock
Whilst I appreciate the need to identify areas for development in order to meet current housing targets, I strongly feel that the development of the aforementioned sites is inappropriate for many reasons, details of which are outlined below.
CPRE has shown that there is space for over 1 million homes on brownfield land across the country- this is not a static figure, for brownfield sites become available all the time. By building houses on brownfield sites, you can ensure that homes are located where there is existing infrastructure and that people are more likely to live closer to where they work etc. This has many benefits, including vehicle pollution and people having to drive less or take shorter journeys thus decreasing traffic and congestion.
Since the start of the pandemic, we have become more aware of our appreciation of our local green spaces. These areas have been vital for lots of people, providing an open, safe space for us to exercise and take a breather during these hard times. We are more aware than ever, how much our communities would suffer if these spaces were no longer accessible.
The government released an updated version of their 25 Year Environmental Plan in May 2019; stating that they aim to: ‘ improve the environment within a generation and leave it in a better state than we found it’. It also states that one of the targets is to ‘increase woodland in England in line with our aspiration of 12% cover by 2060: this would involve planting 180,000 hectares by end of 2042’. With this in mind, reclassification and development of already established green belt land seems counterintuitive and contradictory.
One of the biggest current global threats is the climate emergency; as declared by the UK government in May, 2019. In the Campaign for Rural England’s report, Green Belts: a greener future, it states that undeveloped land plays a vital role in helping to tackle the impacts of climate change. In addition, The 25 Year Environmental Plan promises to ‘make sure that all policies, programmes and investment decisions take into account the possible extent of climate change this century’. The UK is already one of the least wooded areas of Europe, with just 11.7% woodland cover, compared to a European average of 37% . These statistics suggest that we should not only be safeguarding our existing green belt, but we should also be making plans to extend existing sites.
In the government’s National Planning Policy Framework , point 137 states that: ‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development’; with this in mind I feel that we should only consider brownfield sites an option for development. Our need for protected greenbelt is no less now, than when the policy was first introduced. These spaces are the lungs of our country.
Woodland Wildlife Tool Kit have developed an interactive map, which lists the Priority Species in an area using data from: the Bat Conservation Trust, British Trust for Ornithology, Butterfly Conservation, Botanical Society of Britain and Ireland, People’s Trust for Endangered Species, and the National Biodiversity Network. This map indicates that the aforementioned sites consist of the following land types: lowland meadows, deciduous woodland and grazing marsh. Woodland is useful for regulating air quality, climate through carbon sequestration and flood regulation. The map also suggests that there could be Priority Species on, or near the sites in question, as well as European Protected Species. The species that are listed as living on or near the sites are: [redacted], which are rare in the coun ty. Local planning authorities have a statutory duty , according to UK and EU legislation and policy, to consider the potential impacts of a development on protected and priority species and their habitats, and yet surprisingly, since 1970, the indicator of abundance for the 214 Priority Species has declined by 60%. I would argue that the development of any of the aforementioned sites would result in significant harm to local biodiversity, and would contribute to the further decline of our European Protected and Priority Species. We are fortunate to have the abundance and diversity of species in our local area, and the local community are committed to ensuring it’s protection for years to come. As well as the species stated above, we are aware that the proposed sites are occupied by [redacted]. The act of protecting our British Wildlife is synonymous with protecting our heritage and our local and national identity. The sites are closely located to Himley Hall and Baggeridge country park, and I feel that loss of the green belt in question will affect the identity and character of the area significantly; it is this character that makes the area a desirable location in which people wish to live, and visit.
As a resident [redacted], I am also concerned about the impact that development of these spaces will have on local infrastructure. including but not limited to, roads, schools, GP and dental services. I despair at the waiting time for an appointment at my local doctor’s surgery, and I fear that this is just going to get worse with the added pressure. Driving in and around Gornal is notoriously hair-raising, as the highstreet is narrow and there is a high number of vehicles passing through. This is especially bad during the week in the day time, and afternoon rush hour. Trying to exit Gornal in a morning (between 7am-9am) is time consuming; High Arcal and Brick Kiln Lane are particularly busy if heading towards Himley or Dudley. Traffic also bottle-necks by High Arcal School if travelling towards Sedgley. This is also another environmental concern as there is already a high volume of vehicles sitting stationary, contributing to air pollution.
To conclude, I absolutely cannot support the decision for the green belt to be reclassified. I am very concerned that both the strain on amenities and loss of the green belt would be a devastating loss for the area and will have a major impact on the physical and mental health of the local community. The proposed development contradicts NPPF in that in order to protect and enhance biodiversity and geodiversity, plans should promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species. I feel that the development of this land would be deeply regrettable at a later date; and unfortunately, once established woodland and green fields are gone, they are gone forever. I urge Dudley council to take a more ‘natural capital’ approach to the environment and consider the irreversible loss and damage to valuable soils, mature trees and natural wildlife habitats.