Object

Draft Black Country Plan

Representation ID: 45951

Received: 11/10/2021

Respondent: Ms Jan Norton

Representation Summary:

There are lots of reasons why Dudley should not be building on green spaces or green belt.

Informal green spaces are precious areas in which our children can play, especially if they are not near a park. If we are going to support our children to become healthy adults, it is key that they have opportunities to exercise both in and out of school. These spaces also support adults taking exercise and are positive for everyone’s mental health and wellbeing.

My concern is that once green belt land is developed, it will be followed by more and more erosion of green belt. I am also concerned about the potential erosion of the Borough’s precious other green spaces.

I live on a brownfield site which was developed with a mixture of homes including those for rent, some with affordability schemes, and those for people with disabilities. It works, and there is an expectation of all developments that a mix of homes and tenures are likely to be needed (BCP, p98)

Kingswinford and other areas along the A449 corridor are what some people would describe as semi-rural. The proposal to build on Holbeache and the Triangle will impact on the nature of the area and has been described as “urban creep”.

There is a direct relationship between our health and well-being, the quality of the air we breathe and having access to green spaces. (BPC, 3.74 Strategic priority - Improving the health and wellbeing of residents and promoting social inclusion). Dudley Borough faces health challenges because of low rates of physical activity, high rates of obesity, depression and social isolation. If the proposals in the plan go ahead, this will impact negatively on wellbeing through lack of green space as a social amenity. It will also bring poor air quality (BCP, 4.24, 5.12e, p 72 fig 3) noise and traffic, particularly during any building work.

I hope that the Council is constructively able to use any funding made available by the West Midlands Mayor to regenerate brownfield sites and that this can be factored into the next planning stage.

I recognise that green sites are “appealing to developers” – they are appealing to residents too!

When was it agreed that Holbeache and the Triangle sites were suitable for release from green belt for development? I would like to see the minutes of the meeting, a list of people present and a summary of the discussion. Was there local consultation about this?
Could you explain what is a Core Expansion Zone and what is the difference between Zone 1 and Zone 2.

Has there been an audit of derelict sites which could be compulsorily purchased so that green spaces can be retained?

Can you explain the process by which sites may have come into the Plan then disappeared, may be in the Plan and then taken out or may not have been in the Plan but may come in as new sites?

I understand that the sites of at Holdbeache and the Triangle are useful agricultural land, grade three and above.
How do you define "High Quality" and "High Value" arable land in order to explain the difference?

In relation to a number of sites (Severn Drive / Bryce Road , Triangle, Holbeache) residents have raised questions about the risk of flooding. Once land is cleared, the potential for soil erosion increases.
Has the Borough assessed the risk of flooding or specific drainage needs in relation to all proposed sites?
What plans do the Council have for mitigation?
I have seen no independent environmental impact assessment (which also involves speaking to local people who know the area from their own experience, flooding risk, local wildlife etc)

What is the Borough policy on maintaining ancient trees and woodland?

Retaining trees is vital to the environment, to air quality and for as part of a community’s amenities. They are part of the character of the area. Ancient trees cannot be replaced by saplings.

Wildlife, in particular protected species, wildlife corridors, hedgerows, meadows and fields should not be put under threat. It is essential that Sites of Local Importance for Nature Conservation and ootpaths are preserved. Wildlife Trusts will strongly oppose any development that will damage or destroy sites that are important to wildlife. https://www.bbcwildlife.org.uk/blackcountryplan

Proposals for house-building
Members of the public raise concerns about the types of houses that are planned. Many point to the possibility that there is an under-estimate of quality, affordable homes that people can afford to heat (BCP, 5.12 c – “a key priority for tackling health and wellbeing”; “an increased proportion of being affordable or in the social housing sector”)
I have heard the Black Country Plan described as both a “speculators’ charter” and a “landlords’ charter”.
Do the numbers reflect prioritisation of quality, affordable homes?
Is there an increased proportion in the plan of homes which are affordable or in the social housing sector?
How will a range of homes including affordable to buy, to rent, shared ownership and those specifically built for families with people with disabilities?
What horizon-scanning has been done regarding the changing / likely future population of Dudley and their housing needs?

Infrastructure
The Plan proposes significant developments. Many local people are concerned about pressures on education, health services and smaller, more local roads where there is already congestion.
I’m old enough to remember the concept of an “inverse care law” – the fact that in wealthy areas, articulate residents can put pressure on agencies for better quality or more services. The residents with the most and often most complex health and social needs often have to make do with a poorer quality service, less services or no service at all. Food for thought for the Council and
its partner agencies. Where are the proposals for improved public transport, walking and cycling? (BCP 3.74 Strategic priority – promoting sustainable transport)

[45946]


Draft Black Country Plan
Object Development Allocations, Development Allocations

has attrachmentsHas attachments
Respondent: Ms Jan Norton [7887]

Received: 11/10/2021 via Email

Summary: Severn Drive - DUH 222

There are lots of reasons why Dudley should not be building on green spaces or green belt.

Informal green spaces are precious areas in which our children can play, especially if they are not near a park. If we are going to support our children to become healthy adults, it is key that they have opportunities to exercise both in and out of school. These spaces also support adults taking exercise and are positive for everyone’s mental health and wellbeing.

My concern is that once green belt land is developed, it will be followed by more and more erosion of green belt. I am also concerned about the potential erosion of the Borough’s precious other green spaces.

I live on a brownfield site which was developed with a mixture of homes including those for rent, some with affordability schemes, and those for people with disabilities. It works, and there is an expectation of all developments that a mix of homes and tenures are likely to be needed (BCP, p98)

Kingswinford and other areas along the A449 corridor are what some people would describe as semi-rural. The proposal to build on Holbeache and the Triangle will impact on the nature of the area and has been described as “urban creep”.

There is a direct relationship between our health and well-being, the quality of the air we breathe and having access to green spaces. (BPC, 3.74 Strategic priority - Improving the health and wellbeing of residents and promoting social inclusion). Dudley Borough faces health challenges because of low rates of physical activity, high rates of obesity, depression and social isolation. If the proposals in the plan go ahead, this will impact negatively on wellbeing through lack of green space as a social amenity. It will also bring poor air quality (BCP, 4.24, 5.12e, p 72 fig 3) noise and traffic, particularly during any building work.

I hope that the Council is constructively able to use any funding made available by the West Midlands Mayor to regenerate brownfield sites and that this can be factored into the next planning stage.

I recognise that green sites are “appealing to developers” – they are appealing to residents too!

When was it agreed that Holbeache and the Triangle sites were suitable for release from green belt for development? I would like to see the minutes of the meeting, a list of people present and a summary of the discussion. Was there local consultation about this?
Could you explain what is a Core Expansion Zone and what is the difference between Zone 1 and Zone 2.

Has there been an audit of derelict sites which could be compulsorily purchased so that green spaces can be retained?

Can you explain the process by which sites may have come into the Plan then disappeared, may be in the Plan and then taken out or may not have been in the Plan but may come in as new sites?

I understand that the sites of at Holdbeache and the Triangle are useful agricultural land, grade three and above.
How do you define "High Quality" and "High Value" arable land in order to explain the difference?

In relation to a number of sites (Severn Drive / Bryce Road , Triangle, Holbeache) residents have raised questions about the risk of flooding. Once land is cleared, the potential for soil erosion increases.
Has the Borough assessed the risk of flooding or specific drainage needs in relation to all proposed sites?
What plans do the Council have for mitigation?
I have seen no independent environmental impact assessment (which also involves speaking to local people who know the area from their own experience, flooding risk, local wildlife etc)

What is the Borough policy on maintaining ancient trees and woodland?

Retaining trees is vital to the environment, to air quality and for as part of a community’s amenities. They are part of the character of the area. Ancient trees cannot be replaced by saplings.

Wildlife, in particular protected species, wildlife corridors, hedgerows, meadows and fields should not be put under threat. It is essential that Sites of Local Importance for Nature Conservation and ootpaths are preserved. Wildlife Trusts will strongly oppose any development that will damage or destroy sites that are important to wildlife. https://www.bbcwildlife.org.uk/blackcountryplan

Proposals for house-building
Members of the public raise concerns about the types of houses that are planned. Many point to the possibility that there is an under-estimate of quality, affordable homes that people can afford to heat (BCP, 5.12 c – “a key priority for tackling health and wellbeing”; “an increased proportion of being affordable or in the social housing sector”)
I have heard the Black Country Plan described as both a “speculators’ charter” and a “landlords’ charter”.
Do the numbers reflect prioritisation of quality, affordable homes?
Is there an increased proportion in the plan of homes which are affordable or in the social housing sector?
How will a range of homes including affordable to buy, to rent, shared ownership and those specifically built for families with people with disabilities?
What horizon-scanning has been done regarding the changing / likely future population of Dudley and their housing needs?

Infrastructure
The Plan proposes significant developments. Many local people are concerned about pressures on education, health services and smaller, more local roads where there is already congestion. One key issue which has been raised by members of the public in Pensnett (Severn Drive / Bryce Road) is the fact that there is no local GP practice to serve the local population. It seems bizarre that there is a plan for new homes to be built when the basic local primary care infrastructure is not in place.
I’m old enough to remember the concept of an “inverse care law” – the fact that in wealthy areas, articulate residents can put pressure on agencies for better quality or more services. The residents with the most and often most complex health and social needs often have to make do with a poorer quality service, less services or no service at all. Food for thought for the Council and
its partner agencies. Where are the proposals for improved public transport, walking and cycling? (BCP 3.74 Strategic priority – promoting sustainable transport)