Object

Draft Black Country Plan

Representation ID: 45413

Received: 11/10/2021

Respondent: Ms Phyliss Hale

Representation Summary:

Site reference: DUH217

Objection
I am writing to object to the plan to build on the land between Hyperion Road and the Kingsway in Wollaston (DUH217), as the proposals go completely against almost everything Dudley Council have told us are their priorities with the Black Country Plan:
Strategic Priority 1: To mitigate and adapt to climate change to protect the people, environment and economy of the Black Country and meet wider national and international obligation.
You do not mitigate climate change by building yet more houses. This is a green field site, currently covered with trees, bushes and grass. Its net carbon output will currently be negative, as it absorbs CO2 from the atmosphere. As it stands, the site is helping achieve Strategic Priority 1.
The total carbon output of building a new house is 56 tonnes (http://www.carbonconstruct.com/pdf/comparative_carbon_footprint_analysis.pdf) .
You’re building 90 homes here – that’s 5,040 tonnes of extra carbon from the houses alone, not including the new infrastructure that will be required – roads, schools, public transport, doctors surgeries, hospitals, car parks. With building and construction responsible for 39% of worldwide climate emissions, you cannot build your way to mitigate climate change.
No matter how “green” the houses are that are built, these are carbon emissions you will never get back. Houses give out carbon; they do not remove it from the atmosphere. The 5,040 tonnes you’re emitting will only be the start. The average house gives out 8.1 tonnes
of CO2 a year – that means these 90 houses will be outputting an extra 729 tonnes. It’s hard to see how you can fight climate change while increasing your carbon emissions.
Strategic Policy 6: To provide a built and natural environment that protects health and wellbeing through minimising pollution (air, noise and other forms), providing healthy homes, reducing the negative health effects of climate change and providing streets safe for active, low emission travel for all.
You do not “provide a built environment that protects health and wellbeing”, or minimise pollution, by increasing housing density.
It has been repeatedly shown that increasing population density decreases air quality https://www.sciencedirect.com/science/article/abs/pii/S0166046220302817?dgcid=rss_sd_
all, including higher concentrations of nitrous oxide, particulate matter and O3 (ozone).
Ozone has major effects on humans, causing permanent damage to the lungs, and is a major component of smog.
Nitrous oxide contributes to asthma and susceptibility to respiratory infections – something we should be particularly cautious about in the current climate.
At the moment, this land provides an essential buffer, significantly reducing the total housing density of the local area. Building 90 homes on this site will dramatically increase population density, which will directly lead to poorer quality air, poorer outcomes, more
pollution – whether air, noise or light – and increase the rate of health conditions linked to poor air quality and toxic air pollution, in direct contravention of strategic policy 6.
Strategic Priority 2: To adapt to and minimise the impact of Climate Change by reducing carbon emissions, maximising the use of low carbon energy solutions, seeking to reduce the impact of flooding, and enhancing the Black Country's Green and Blue Infrastructure
Building on DUH217 will lead to increased flooding, not reduce its impact.
It has been repeatedly shown that rapid urbanisation of the sort this development is planning will lead to increased flooding.
https://www.ukconstructionmedia.co.uk/features/flooding-uk-housing/
In their words, “One factor that has contributed to the rise in flooding is the increase in impermeable surfaces with rapid urbanisation. Higher impermeable cover leads to increased surface runoff, a driver of flooding. More and more houses being built will only increase the
percentage of impermeable cover, which will continue to exacerbate the issue. The land can no longer absorb rainfall if it is built over; instead, water runs off impermeable surfaces into
drains which can become overwhelmed, and into rivers, increasing the flood risk in multiple
areas.”
 Constructing 90 houses on this green belt land will lead to more flooding, both in the
estate, and in all of the areas around it - the exact opposite of Strategic Priority 2.
Strategic Priority 11: To protect and enhance the natural environment, biodiversity, wildlife corridors
geological resources, countryside, and landscapes, whilst ensuring that residents have good access
to interlinked green infrastructure
 You do not protect and enhance the natural environment by tarmacking over it.
 You do not enhance access to interlinked green infrastructure by removing it
 You do not protect or enhance a natural landscape by cramming in 90 living spaces.
Strategic Policy 5: To provide a built and natural environment that supports the making of healthier
choices through provision for physical activity and recreation, active travel, encouraging social
interaction and discouraging harmful behaviours.
 You do not support people to make healthier choices for physical activity and recreation
by removing the fields they use for that physical activity and recreation.
 Throughout the pandemic, this route and these fields have been a vital lifeline for the
residents of the Kingsway and Wollaston itself. This is the way to the countryside. When we
were all told we could only leave our house once a day, it was these fields that kept us sane.
 The one field here is home to horses from a local riding school. The riding school provides a
vital service to the local community, not only allowing young people the mental health
benefits of being able to look after an animal and help out with maintaining the land
(something which was essential during the pandemic’s many lockdowns), but also providing
some much-needed relief to local residents in the local areas. Interaction with animals has
been proven to lower cortisol levels (which in turn reduces anxiety and stress), reduce
feelings of lonilness, reduce blood pressure, and even help people live longer.
https://newsinhealth.nih.gov/2018/02/power-pets
 Building on this land will rob local residents of a vital link to nature, leading to poorer
outcomes, worse health choices and less physical activity, increasing stress and loneliness
which in turn leads to more serious health conditions, increasing costs to the NHS and
council.
 Additionally, there’s a complete lack of access to the site. The fields are currently accessed
via a narrow dirt path, which isn’t wide enough for a car to traverse. If an estate is to be built
here, you’ll need a two way road to get people in and out. There are two houses at the
bottom of the entry from the Kingsway that go right up to the track. Widening this road to
make it two-way would mean either, or both of them losing their home. As both are semis,
you wouldn’t be able to knock down just half a house – you’d be robbing four families of
their home – possibly five, as one appears to have some sort of granny flat adjoining. The
fact you’d have to upend five families to even try and build on this site makes it a price not
worth paying.
I also have concerns about the procedure that’s been followed with the consultation. The website
that lists the Black Country Plan is not exactly user friendly, to say the least – it’s convoluted,
awkwardly designed and not at all easy to find, yet alone figure out how to comment. The fact the
website seems to hide the objectives of the Black Country Plan (it’s far from easy to access) means
many objections from the public will not have been received simply because people were unaware
of quite how much it the proposals against what Dudley Council claim to be intending to do.
Considering all of the above, there can be no solid argument for building on the land in DUH217.
Building 90 houses on the land will be in direct contravention of almost every objective of the Black
Country Plan, and if the council are true to their words and values, the project simply cannot go
ahead.
If the council were to go ahead with this project, despite the objections raised, it would have a
seriously negative effect on public-political trust. Forging on with a project that flies in the face of
every value the council claims to hold dear would only serve to make the council look dishonest and
two-faced - as for all the heady morals, when push came to shove, and money came to changing hands, those same morals would go out the window.
With local election coming in 2022, the residents of Wollaston will be sure to let residents across the county know what the council decides.



Black Country Plan Consultation
Email to blackcountryplan@dudley.gov.uk

Resident
Title of Document – Draft Plan
Reference of Site – DUH217
Nature Of Comment – objection
Comments as below:-
1/ I am very concerned that the assumptions and forecasts on which the whole Black Country plan is based are already out of date, thereby making the housing targets invalid before we start.
Recent figures show that birth rate in the UK is now only 1.5 /woman, life expectancy has dropped and the Government insist that ‘the days of unfettered immigration are over’. There also appear to be many EU citizens who have not registered to remain in UK, and these at some point will be leaving. So the population will either be static or even decline – so we don’t need 76000 houses built in the borough, and the 41000 planned on brownfield sites will be more than adequate. So we don’t need to select DUH217 for building.
2/ Everyone (population generally, Government, more specifically the West Mids Mayor Andy Street and Prime Minister Boris Johnson, insist building should not be on green belt until all Brownfield sites are built on – so the ONLY way to make this happen is to simply not approve any greenfield ites until all the brownfield is used. Once greenfield sites are allocated for building, as they are cheaper and more profitable to build on, they will be used first not last, and the brownfield sites will remain empty eyesores. There are figures which show developers prefer greenfield sites as they make 5 times the profit. Our greenbelt must not disappear for monetary reasons. DUH217 should not be even considered for selection for building until all brownfield sites are actually built on.
3/ This is even more relevant to the so called ‘unviable’ brownfield sites, which will only be built on when all the other brownfield sites have gone. If we want to see these eyesore and polluted sites treated and developed, then we have to firmly resist calls to build on any green sites. Science and industry will then have the incentive to find a way to treat the ‘unviable’ sites, removing the pollution for the greater benefit of the whole population. It is wrong to build on, or select for building, DUH217 until all brownfield sites are fully developed.
4/ Once we have built on greenfield sites we have lost the amenity forever. So we must not make any greenfield sites available for building at all, including DUH217, until all brownfield sites are used up.
5/ During Covid this site was a godsend. Its use as a recreation and exercise site increased dramatically. We are being told that we will have to learn to live with covid, so it seems further lockdowns etc will be inevitable, and we will need this site for taking exercise and breathing clean air in the future.
6/ This sites location is crucial, as it gives the local residents access to the countryside, very near their homes (by virtue of its location, built up on 3 sides). Once into site DUH217, the residents are ‘in the country’. Otherwise they will have to walk an extra half mile or more to reach the country side. This will be a disincentive to many, and a problem for others with mobility problems. This site is not just a green corridor for wildlife, it’s a green corridor for residents too. Plus its used to graze horses, which not only will have nowhere else to go if its built on (so may be ‘put down’), but which the local residents love to see as they demonstrate clearly that once into site DUH217, you are ‘in the country’. DUH217s location, built up on 3 sides, is a virtue, and makes it more even valuable as a green space near homes and people, which needs to be preserved. Not a feature which should be used to select it for building.
7/ We have a right to access green open spaces like these, and this site is vital to my wellbeing and that of other locals. This site gives locals a green space to exercise reducing risk of diabetes, obesity etc., and for socialising in the fresh air, reducing spread of Covid. After the recent pressure put on the nhs by covid, giving us the green sites the experts say is crucial to our health and wellbeing will lessen the future pressure on the nhs.
8/ The loss of DUH217 would be detrimental to my health.
9/ There is a bridleway, which will be lost. It’s a pleasant grass/earth bridle way, and a definitive path. Whilst it would be retained as a right of way if built on, this would no doubt be simply as a path down a road, through an estate. This is not so good for walkers or cyclists, but especially for horse riders and particularly young/inexperienced horse riders who are much safer on a bridleway such as presently exists than on a tarmacked road. Yet a further reason to refuse to consider this site for building.
10/ There is no existing road access into DUH217 making it an ‘unviable’ site. From Hyperion Rd, the access is currently only via a stretch of private road, and I am assured that the residents will not allow any further access. From Kingsway, there is only a narrow track. To create access here would mean demolishing 2 houses at the very least (as the nearest house is a semi). This alone should make it a site to refuse to consider for building.
11/ Further to point 10, once access to DUH217 is created, this opens adjacent greenfield sites to prospective development, which is clearly one of the reasons green belt was created following WW2 in the first place - to restrict urban spread and ribbon development. Allowing building on DUH217 would open up still further green spaces to building, giving a further reason to not select DUH 217 for building.
12/ The extra traffic on Kingsway would cause severe problems, its currently a bus route, with very steep gradients and is heavily parked on, causing obstruction at even the existing traffic levels, more traffic would place even more burden on the road. There is a school on Kingsway and it’s particularly congested in the whole vicinity at certain times of day. The extra traffic would be an increased hazard to the children. The bus route is not served by many buses and if DUH217 is built on, there would not be enough capacity on the buses. Similar problems would be caused by access through Hyperion Rd. The only entrance to which is just across the Staffordshire border and already a dangerous junction on a blind bend. There was a serious crash there recently. With more traffic turning in and out it would be even more dangerous.
13/ The local health infrastructure already fails to cope. The only local GP practice is Lion Health centre, which currently seems to have a poor reputation, and does not seem to cope with its existing patient numbers. I understand the local MP gets lots of complaints about this heath centre.
14/ The local school, St James C of E primary school, is already oversubscribed. So could not take extra children.
15/ There are already local traffic jams at every major junction in the vicinity, which would get worse.
16/ These infrastructure and access issues are not solvable, demonstrating that building on DUH217 is not viable.
17/ This site DUH217 is an important wildlife corridor (not a piece of low grade land), and also an important wild life habitat. It houses (I have seen myself), , Foxes, rare birds such as woodpeckers, Grass snakes (a protected species), amphibians such as frogs, toads (including I believe natterjacks) and newts and many more species. This wildlife habitat needs preserving not building on.
18/ There are trees and bushes, cleaning the air we breathe. New housing will simply increase pollution whilst removing this cleaning facility. We are supposed to be embracing a green lifestyle –building on DUH217 will negate this.
19/ The local children need to be able to see and play in the countryside, close to their homes. Building on DUH217 prevents this for existing local children.
20/ There is a high pressure sewerage pipe beneath the field which the water companies will not want built over, as they may need access. This will make development difficult too, as it will restrict the layout of the housing, making DUH217 even less viable.