Object

Draft Black Country Plan

Representation ID: 22385

Received: 11/10/2021

Respondent: Mr Sean Clegg

Representation Summary:

Site: ID 10511, The Three Fields, Norton, DY8 3LS

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 SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is 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 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’.

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).

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.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).