Comment

Draft Black Country Plan

Representation ID: 19272

Received: 11/10/2021

Respondent: Mr Roy 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


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.

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 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.


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