Object

Representation ID: 45414

Received: 11/10/2021

Respondent: Mr Stephen Newman

Dear Sirs,
Re: Comments on Draft Black Country Plan

Title of document: Draft Black Country Plan
To which part of the document: 1: Sub-Areas and Site Allocations, A. Dudley

Nature of comment: 'Objection'.

I object to the allocation of the following four sites in the Black Country Plan:

DUH206, Worcester Lane North, Stourbridge
DUH207, Worcester Lane Central, Stourbridge
DUH209, Worcester Lane South, Stourbridge

Reasons for objections:

Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV. Strategic Priority 12 is to "protect, sustain and enhance the quality of the build and historic environment". See also Policy ENV5, p230. All three are green field sites with a grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way. Given the emphasis in Policy CPS3 on "heritage, recreation, agricultural and nature conservation value", these sites should not be allocated.

Proximity to Site of Local Importance for Nature Conservation (SLINC): There is a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mitigation for this.

Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green Belt haem for these three sites. There would ne no clearly "defensible boundary" to this development (Policy GB1, and para 3.16). Development would also encroach on the open countryside between Hagley and Pedmore, going against as least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another, and (c) safeguarding the countryside from encroachment.

Traffic flow and environmental impact: The proposed site has no local amenities, including shops, within easy walking distance and would therefore add to the already significant problems with traffic flow in the Hagley / Pedmore / Kingswinford area.

The site sits in a triangle formed by Kingswinford, Hagley Village and the traffic lights at the bottom of Hagley Hill , an area that has already been adversely affected by the recent completion of a large number of new homes on the Cala Estate development in Hagley. Traffic flow is extremely poor in this area ad the completion of 115 homes on the proposed site on Worcester Lane will only add to this congestion and its consequent damage to the environment.

Yours faithfully,
Stephen Newman