Object

Draft Black Country Plan

Representation ID: 46210

Received: 11/10/2021

Respondent: Mrs Anu Sahota

Representation Summary:

[Three Fields - LGS]

I/WE OBJECT TO THREE FIELDS NOT BEING DESIGNATED AS A ‘LOCAL
GREEN SPACE’ FOR THESE REASONS: Site reference number: Site ID 10511, The
Three Fields, Norton, DY8 3LS (site ID number 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, which was assessed for a LGS Designation
in the Site Assessment Report.
Local Green Space: This site meets all of Part A criteria, and sufficient of Part B
criteria (Beauty, and Recreation) to meet national criteria for a Local Green Space.
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). Green Belt designation itself
does not recognise any additional value to the local community which a site may have
above the five stated purposes of the green belt. Specifically, “green belts do not
recognise... the community value of land” (Neighbourhood Planning, 2019, para.134).
A LGS designation would demonstrate the importance of this site to the local
community and its local significance beyond that of being simply ‘green belt’.
Designations: The site has mature hedgerows which should be surveyed. Other
hedges in the locality recently received SLINC protection (Racecourse Lane SLINC,
Norton).
Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil
areas as it fulfils the criteria listed above.