Comment

Representation ID: 19225

Received: 10/10/2021

Respondent: Mr Robert Bevan-Jones

Title of document: Draft Black Country Plan To which part of document: 1: Sub-Areas
and Site Allocations, A. Dudley

Nature of comment: ‘Objection’

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 SA0076-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 being 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).