Comment

Draft Black Country Plan

Representation ID: 22074

Received: 11/10/2021

Respondent: Kinver Parish Council

Representation Summary:

Proposed Site Allocation DUH211:

We find the following:

• Please explain the reason behind the coalescence.
• The considerations for this site fails to reflect the impact on adjoining areas outside of the plan boundary. There is no reference to how this site fits with the South Staffs development strategy.
• Removal of green belt how does this comply with NPPF framework?
• Eroding the defensible and policy boundaries (such as green belt to prevent against urban sprawl).
• We would encourage the A449 to be established as the defensible boundary to protect any further impact on removal of additional green belt.
• A design brief in policy that should be created to ensure that the edge of any new development against the A449 boundary is loose in urban gain, maintains the existing established hedgerows and provides a soft transition into the open countryside from the urban area to the east.

Proposed Site Allocation DUH217:

• Any proposed site allocation that includes land to be released from the green belt must demonstrate how other sites of previously developed land have been discounted and what the rationale is to release this directly.
• Make clear how this site fails the 5 purposes of the Green Belt to enable the site to be allocated.
• It is an important green barrier between the two counties.
• The site includes substantial trees, mature established hedgerows.
• There is no existing vehicular access to the site to enable the development. How are you intending to gain access?
• High biodiversity value and wildlife within the green wedge in an urban area.
• Mature hedgerows are important to wildlife and must be maintained