Object

Representation ID: 19273

Received: 11/10/2021

Respondent: Mr Roy Davies

Objecting to Black Country Site Assessment Report
Dudley Appendix A, Page 79. The Triangle SA-0025-DUD

1. Loss of green belt
• It is better to use old factory sites (Brownfield) and re­
develop inner cities to revive town centres.
• This is useful Agricultural land graded 3 and above.
• The Visual Amenity and Character of the Area would
dramatically change.
• This is an important and strategic tract of Green Belt
preventing urban sprawl along the Western Edge of the
Black Country. If the proposed A449 Kidderminster Road
forms the amended Green Belt boundary then all the
Greenfield sites encompassed by that on the boundary and currently vulnerable from the South Staffs Local Plan would be at risk from development as a precedent would be set for a new boundary.

2. Quality of life
• Developing green belt means loss of access to
countryside, once it's gone, it's gone.
• Higher noise levels impact of adjoining residents and
wildlife.
• Increase in light pollution in a much needed area of
tranquility.
• Poorer air quality impact of adjoining residents and wider area, particularly from increase in traffic.
• Impact of building from construction noise and traffic.

3. Impact on traffic and transport
• Increasing numbers of vehicles will mean increased
pollution, road safety consequences.
• Road traffic congestion in the area is already high. A449 and A491 gridlocked in a morning. Nor do we want more roads eg 'Western Strategic (Orbital) Route' destroying more green belt.
• Lack of public transport or cycle routes. Hansen rate this area as having the worst commuting score from homes to places of employment.
• Poor rail access. Time taken to reach the rail network to
Wolverhampton/Birmingham is much longer than 30 minutes.
• There are also at least two other major development sites at Stallings Lane and Ketley Quarry(within 2 miles) which do not have any infrastructure improvements either.

4. Pressure on local facilities
• There are not enough doctors surgeries, schools, shops, emergency services in Dudley to serve the area. The proposal to build 533 new houses on the triangle would increase the local population by 1279 (Office of National statistics average occupation rates are 2.4 people per household)
• Local Health Services are already over subscribed and un­sustainable.
• Primary Schools over 15 minutes walk away.
• Road Infrastructure already struggling to cope at present with high traffic levels. Impact on the wider road
network particularly Kingswinford and Wallheath junctions.
• No suitable or regular bus routes or cycle network.
• No nearby employment sites or network.
• Providing more 'High Value' housing does not solve the
problem of lack of affordable or social housing, which would also need a sustainable infrastructure of health facilities, education, mass transit and employment centres.

5. Destruction of the local environment
• Loss of ancient trees, natural habitats, biodiversity.
• Loss of SLINC (Site of Local Importance for Nature
Conservation) hedgerows to create access.
• This will contribute to climate change .
• Loss of wildlife, impact on the fields and meadows.
• Loss of wildlife corridors linking green spaces.
• Flood risk affecting drainage of the area and ground water.
• Contributing to rapid loss of species in Britain in recent
decades eg moths, butterflies, bees have declined significantly.
• Replanting schemes do not replace ancient habitats and features.

6. Important locally
• Local people love and appreciate this green belt area, and want it for future generations
• Important local green space, valuable trees, hedgerows and open fields. Many trees have Tree Preservation Orders
• Site of Local Importance for Nature Conservation (SLINC) -'Ashwood Haye Fields' - hedgerow around the perimeter of the site and some within the site
• It contains Important local green space, valuable trees,
hedgerows and open fields.
• There is an important network of footpaths (rights of way) across the area including links to Monarchs Way, Staffordshire Way, linking to Cheshire Gritstone Trail, the Heart of England Way and the North Worcestershire Path.
• It is next to an important woodland Ridgehill Woods, which will be hugely impacted. Disrupting the wildlife corridors and surrounding habitats for these would be irreversible.
• It is part of the Mid Severn Sandstone Plateau-important for habitat conservation.
• In addition, it is an important habitat for declining British
wildlife (list species where known).
• Disrupting the wildlife corridors and surrounding habitats for these would be irreversible.
• Historic character of Prestwood.
Prestwood is a locally designated Historic Landscape area. A collection of Scheduled Ancient Monuments associated with the Greensforge Roman Camp are situated in the area between Swindon and Prestwood to the west of Kingswinford.

7. Huge opposition by the local community
These housing proposals are not meeting affordable housing targets with expensive housing in the Green Belt.

8. 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)

9. 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