Object

Draft Black Country Plan

Representation ID: 23571

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Representation Summary:

It is quite strange that the Black Country Local Plan has not given proper Spatial Land Use Planning Consideration for Employment or Economic Development. It is unfortunate and untimely that the Black Country Employment Area Review Or BEAR will not be available until August.

It has premised growth through Housing but not materially considered alternative perspectives.

For instance, it would not be out of the question to adopt a thriving no growth strategy which is about making Black Country capable of standing alone in a sustainable local economic development model. Such a strategy being more akin to current vectors of change and not positioned on continuous sustained consumption.

It might also have been a strategic decision to promote micro-enterprises and venture capital investment which fostered business that were not dependent on travel to and from the major business hubs. After all the networked world has demonstrated the potential for different kinds of business and, during Covid shut down, the attractiveness of working from home.

This refreshed option builds upon the strength of adding a more current and real employment perspective which seeks to broaden the economic base. This needs to be interdependent, agile, far-sighted, current and inclusive rather than orthodox, rigid, myopic and exclusive.

The fallacy of linear projection of employment applies in the current Local Plan and its preparation, this is where agencies such as the Council act as institutions of continuity as they show themselves loathe to innovate, preferring incremental change of a known order rather than violent transformations in line with emerging trends.

The Black Country plan demonstrates the popularity and longevity of the dominant paradigm regarding unchecked growth which may not prove sustainable.

Local Planning was meant to take on sociological, technological and economical change

The whole point of a Local Plan for the Black Country is to provide an integrated and comprehensive series of policies which draws together the inter-related aspects of a complex world. For instance, to consider Homelessness (which is not given proper consideration) is to treat a problem of inequality which is multifaceted and not just a matter of buildings and availability. Local Plans are meant to go beyond simple Land Use Planning considerations.

Likewise, providing the right dwellings at the right time is not about providing, for instance, building 4 bedroom luxury homes at points unconnected to future growth points, technological assets and demands created by changing sociological characteristics.

Much of the Black Country Local Plan appears a ‘gold rush’ to release the national treasure of the Green Belt and important greenfield sites without a comprehensive consideration of inter-related aspects that determine quality of life, real life chances and opportunities for all.

Planning, simply is about making decisions and taking actions, now or in the very near future, to make sure total future benefits are maximised and / or the overall direct and indirect costs are reduced.

When applied to Land Use, it seeks to consider the allocation, benefits and costs of Town Planning Classes of Use to meet interdependent activities required by individuals, groups, communities and populations within a Local Authority Area or, as in this case, four Local Authorities.

Many of options and considerations within the Black Country Local Plan do not attempt to draw together the interconnected aspects of service provision with the broadest possible set of features arising from the 4 Council’s corporate organisational policies. To do this would be to ensure the best of all futures and quality of life for its stakeholders.

The Plan simply considers Land for Housing but does not consider how to ensure its service or those of the sub-region and neighbouring areas can be better focused with Land Use Planning to enrich the area. For example, Widening Participation and Life Long Learning can be perspectives that bring education, training and learning relationships with economic development and local planning for the benefit of an area.

Local Planning should extend corporate planning, amenities and wrap round services around major new residential build. Briefly, but relevant here is an understanding of Local Plans which depends to some extent on its genesis. It arose out of the knowledge that Land Use Planning was linked to sociological, economic and technological change. There was a clear link between Economic Development and Planning. These grew out of a disaffected population pressure to ensure that the public ought to participate in the process - as there was disenchantment with planning generally. Development control had been a success when it avoided development in the wrong places and when better results were achieved than would otherwise be the case. There was in many cases a lack of correspondence between the Development Control and Development Planning.