1 Introduction

Object

Representation ID: 23343

Received: 11/10/2021

Respondent: Bloor Homes

As aforementioned, for the BCP to be found sound, the plan needs to meet the four tests as required by paragraph 35 of the NPPF 2021 i.e. the plan needs to be positively prepared, justified, effective and consistent with national policy. BHL consider that some policies in the BLP are unsound because they fail the four tests of soundness. Before the BCP pre-submission consultation, the following Development Management policies should be modified:

• Policy HOU3- Delivery Affordable, Wheelchair Accessible and Self Build/ Custom Build Housing
• Policy DEL3- Promotion of Fibre to the Premises and 5G Networks
• Policy TRAN8- Planning for Low Emission Vehicles
• Policy ENV9- Design Quality
• Policy ENV3- Nature Recovery Network and Biodiversity Net Gain
• Policy CC2- Energy Infrastructure
• Policy CC7- Renewable and Low Carbon Energy

Comment

Representation ID: 23541

Received: 11/10/2021

Respondent: Historic England

The Plan references HS2 a few times within the consultation document. How does the Plan assess the impacts of any HS2 proposals that are safeguarded/ protected through the Plan? Are there any implications for the historic environment that need to be assessed? We have made comments to previous transport strategies for the area, how are these comments being incorporated? We note that the main vehicle for delivery will be the West Midlands Strategic Transport Plan and we are available for comment if there are any forthcoming consultations.

Comment

Representation ID: 43808

Received: 11/10/2021

Respondent: Burrowes Street Tenant Management Organisation

General Comments

2. The Consultation: sorry to say, but the language used isn't all that accessible to many people, and people cannot be expected to wade through 730 or so page to find what they're looking for - so my experience is that awareness has been poor and many, many people don't
know what is being proposed at all!

I would suggest that consideration should be given to an extension of time, a further awareness campaign (and a bigger take-up of the tens of thousands of items of consultation material sitting unused in Room 9 of Walsall Council House)

Object

Representation ID: 44794

Received: 23/09/2021

Respondent: Mr Dean Wenn

Objection to the Draft Black Country Plan

Object

Representation ID: 45390

Received: 10/03/2022

Respondent: Mrs Novelette Aldred

Objection to Black Country Plan in General + Please see attached sheets. For objections to 1 site in particular

Local Authority - Walsall Council
As a resident of [Redacted-GDPR], Aldridge [Redacted-GDPR], I wish to raise the following objections to the Black Country Plan 2021, as outlined below.
Several residents have been in contact with local MP Wendy Morton and Walsall Councillor John Murry about this matter since it was raised during the Covid-19 restrictions in 2020. Assurances have been given in writing, there will be no building in Aldridge on the Green Belt land, this has been reiterated today by the Prime Minister and supported by the Mayor of West Midlands, Andy Street, that building on green-belt land is now not on the Governments agenda.
The wedge of green belt land on the junction of Middlemore Lane West and Bosty Lane, which is bounded by Daw End railway cutting, is unsuitable for development for the following reasons:

1. The site is adjacent to a Site of Special Scientific Interest (SSSI), please see attached Defra plan below.
This is an ancient site as documented on Walsall Council's website, please see -
https://go.walsall.gov.uk/parks_and_green_spaces/conservation_and_the_environment/sites_of_special_scientific_interest_sssis/daw_end_railway_cutting
'The old quarry and railway cuttings at Daw End provide excellent exposures on Wenlock Shale (Coalbrookdale Formation) and the overlying Wenlock Limestone which were deposited during the Silurian Period about 410 million years ago.
These are the best exposures available in Britain for this particular group of rocks. During deposition of the Wenlock Limestone marine organisms grew in patches on the sea bed trapping sediment and forming low mounds or reefs. These patch reefs are well seen in the Wenlock Limestone at this site. This is an important geological locality for the study of the Wenlock Series in Britain.

2. Any development on this important sensitive site would comprise the existing delicate eco­structure and be extremely detrimental to the wildlife and to the historic flora and fauna of the site and area generally.

3. Heavy industrial goods traffic on the roads bordering the site, makes access to the site difficult. Access to the Middlemore Lane Industrial estate from Bosty Lane is restricted and can only be accessed by a single-track bridge. This already causes significant tailbacks along the section of Middlemore Lane West onto Bosty Lane.
Furthermore, the use of this route by heavy goods traffic is set to increase when the proposed Council recycling centre on Middlemore Lane opens.

4.The junction of Middlemore Lane West and Bosty Lane has been the cause of numerous serious accidents, with some incidents involving the deployment of the air ambulance service. Development on this site will increase traffic at this junction and would be likely to create a high number of incidents without significant improvements to the highway, including the potential to construct a new double-track road bridge over the railway.

5. The development of this green belt site will create additional environmental air pollution and exacerbate the existing noise pollution from the container base.

6. Very limited public transport services in the area, with the local bus service providing a­ maximum service of two busses per hour. There are currently no public rail links in the area.

7. The green belt creates an important natural division-between the parishes of
Aldridge and Rushall and prevents coalescence. This land provides a much-needed haven for wildlife, and currently includes a haven for several horses which graze the pasture and provides a buffer zone to the SSSI.

MAP - SEE ATTACHMENTS

Comment

Representation ID: 45422

Received: 11/10/2021

Respondent: Lichfield District Council

To whom it may concern,
LDC Representations to Draft Black Country Plan Review

Thank you for consulting Lichfield District Council on the Draft Black Country Plan 2018-2039 (BCP) Regulation 18 consultation. Lichfield District Council welcomes the opportunity to provide comments on the BCP at this emerging stage. Lichfield District Council welcomes the continuing, positive dialogue with the Black County Authorities through the Duty to Co-operate process as
the Black Country Plan progresses.

Housing requirement and delivery:
Lichfield District Council notes that the proposed housing requirement figure for the plan period (2020- 2039) for the Black Country area is 76,076 homes or a need for 4,004 new homes each year as detailed within Table 2 of the BCP. This is based on the standard method used to calculate Local Housing Need (LHN) for the four Black Country authorities which includes the
35% uplift to the Wolverhampton housing need figure as a result of the changes to the standard method in regard to the country’s largest cities and urban centres that were made in December 2020.

The May 2021 Wolverhampton SHLAA outlines that 19,646 net homes would be required to meet the LHN for the current Black Country Plan review period (2020-39). It is acknowledged that the BCP aims to deliver 12,100 homes in Wolverhampton with 11,083 of these homes within the urban area of Wolverhampton and included within this is a target for 4,838 homes to be delivered within the city centre itself.

This leaves a shortfall of 7,546 homes that cannot be delivered within Wolverhampton’s own area and will need to be exported via the Duty to Co-operate. However, 5,092 homes (268 per annum) of this figure is the urban uplift for Wolverhampton. The Planning Practice Guidance sets out where the cities and urban centres uplift should be met (Paragraph: 035 Reference ID: 2a-035-20201216). This states that “This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised and, on these sites density should be optimised to promote the most efficient use of land. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the service they rely on, making
travel patterns more sustainable”. This makes clear that a proportion of the unmet need relating to this uplift should therefore not be included within the shortfall numbers to be exported to other authorities.

It is noted that the BCP, through policy HOU1 – Delivery Sustainable Housing Growth, will provide sufficient land for at least 47,837 net new homes over the plan period within the area. It is noted that this creates a housing shortfall of 28,239 that is to be exported through the Duty to Co-operate of which 5,092 homes come from the uplift applied to Wolverhampton’s LHN. This housing shortfall represents 37% of the housing need for the Black Country area. This is a significant figure given neighbouring authorities need to meet their own LHN and demonstrate their Local plans are realistic in terms of delivery. There is therefore concern as to whether this
level of export of growth to neighbouring authorities is realistic in respect of delivery or that such an approach meets the need where it is most needed.
It is nevertheless acknowledged by Lichfield District, along with other authorities within the HMA that they should seek to provide a proportionate and meaningful contribution toward the unmet need arising from the Black Country HMA. Lichfield District Council has progressed in the review of its Local Plan. The Local Plan 2040 was subject to consultation in July and August 2021 and is scheduled for submission before the end of the year. The draft Local Plan 2040 proposes a
contribution of 2,665 homes between 2018 – 2040 towards the Greater Birmingham and Black Country Housing Market Area shortfall, of which 2,000 homes are to assist with the unmet need arising from the Black Country and will be delivered from 2027/28. Lichfield District Council considers this to be a significant and proportionate contribution to unmet needs, equating to an
additional 37.7% on the District’s LHN. Accordingly the District Council would like to stress the importance of the Black Country Authorities proactively seeking the absolute maximum within their own borders and to identify any further potential sites from Urban Capacity work and from robust consideration of additional Green Belt release where these are evidenced and appropriate.

The District Council notes the Green Belt Review and acknowledges the methodology used. The District Council concurs with the BCP that exceptional circumstances exist to merit the release of Green Belt within the area noting the level of growth required for the Black Country Authorities over the plan period. The District Council would like to reiterate that sites that serve a lower significance to Green Belt purpose need to be robustly and purposefully assessed considering
the unmet need. Such consideration could identify further allocations within the BCP area to meet the housing and/or employment requirements of the plan.

The District Council notes the Urban Capacity work and acknowledges the loss of surplus occupied employment land that had previously been allocated as housing land and the impact this has had on supply. It may be that further demonstration of evidence is required at Publication stage of the BCP as to the justification of this loss given the plan period runs until 2039. It is not unreasonable to consider that some of these surplus employment sites may reach the end of their commercial life within this plan period and assist with meeting development needs towards the medium to end of the Black Country Plan period.

Housing Allocations
The District Council notes the allocation of Sites WAH235, WAH 237 and WAH 253 in the West Midlands Green Belt in Walsall to the east of Brownhills and Leighswood and sites WAH230, 246
and 254 north of Hardwick.

We would like to make the Black Country Authorities aware of the Air Quality Management Area (AQMA) at the A5/A461 Muckley Corner junction in Lichfield District. Further to this, Chasewater and Southern Staffordshire Coalfields Site of Special Scientific Interest (SSSI) is also located in relatively close proximity. Proposals within 15 Km of the Cannock Chase Special Area of
Conservation (SAC) will also need to be informed by the partnership work being undertaken and the evidence base work being prepared.

Such considerations along with any detailed transport assessments should be taken into account when assessing the suitability of these allocations alongside their potential suitability in Green Belt methodology terms.

Employment
The District Council notes that the BCP, through Policy EMP1 – Providing for Economic Growth and Jobs, will seek the delivery of at least 355 hectares of employment land within the Black Country through allocated sites and redevelopment, intensification and enhancement of existing employment areas and premises. It is noted at paragraph 7.12 of the BCP that there is an employment land shortfall of 210 hectares that is to be exported to authorities through the ongoing Duty to Co-operate process and secured through Statements of Common Ground.

This employment land shortfall represents 37% of the overall employment land need. The 2021 Urban Capacity Review Update paper at paragraphs 2.2.4 and 2.2.5 make reference to; a ‘desired economic situation’ and to the ‘economic growth aspirations of the Black Country… past trends plus some growth scenario’. The District Council would question whether this aspirational level of economic growth and increased provision of employment land is realistic given the need to export 210 hectares of employment land to neighbouring authorities through the Duty to Co-operate. Again, LDC would suggest further consideration is given as to whether this aspirational level of growth is an appropriate growth option for the Black Country
Authorities having regard to deliverability, meeting need where it is most needed and the high level of dependency of exportation of the growth.

Lichfield District is unable to assist in meeting any unmet employment need. The emerging Local Plan seeks to meet the Districts own employment needs. The emerging Lichfield District Local Plan 2040 makes clear that evidence demonstrates that there is only sufficient employment land within the District to meet our own requirements with limited potential further options beyond
those allocated. Therefore, the District Council will be unable to assist in meeting unmet need for employment land arising from the Black Country.

Minerals
Lichfield District also notes the identification to the north east of Walsall of a Sand & Gravel Mineral Safeguarded area and a preferred area for sand and gravel extraction and would like to emphasise the importance of the thorough assessment of the environmental and traffic
implications of any future proposals and the appropriate site restoration where any mineral operations take place.
Lichfield District Council welcomes continuing a positive dialogue with the Black County Authorities through the Duty to Co-operate process as the Black Country Plan progresses.

Yours faithfully
S W Stray
Stephen Stray
Spatial Policy and Delivery Manager

Object

Representation ID: 45842

Received: 08/10/2021

Respondent: Mr Joseph Aldred

I wish to make two points. First, how debilitating and alienating it is to engage with the Black Country Plan. I fear that as a resident being asked to engage with this huge amount of information advantages professionals and massively disadvantages mere residents for whom planning is a foreign language... particularly voluminious information on this scale.

Object

Representation ID: 45854

Received: 11/10/2021

Respondent: Mr Lawrence Bright

Dudley Council has not informed or made residents aware of these plans and not given them time to raise any concerns. This is a local community not a national target zone.

Comment

Representation ID: 45879

Received: 11/10/2021

Respondent: Mr John Chorley

[Consultation Process]
Black Country plan Walsall Longwood lane and
Aldridge road

Yesterday was the first me I became aware of the plans for 220 and 440 homes respectively, despite living just off [redacted - GDPR] and within easy walking distance of both areas. I think that this is a shocking failure of Walsall MBC and the consultation period should be extended
for the following reasons;
it is clear that there has been no attempt to consult with the immediate neighbourhoods
...
This is a brief complaint based on the poor communication process of Walsall MBC and I formally request an extension to this consultation period

Object

Representation ID: 45912

Received: 07/10/2021

Respondent: Peter Kendrick

[Consultation Process]
REF WAH242 Calderfields Farm
I would like to express my disgust and dismay that as a person resident [redacted sensitive information] where the above development is proposed with one of the potential accesses [redacted sensitive information] the first notification I had of this was from a third party. In my experience people adjacent to or within a close vicinity have always been made aware of potential developments. I have had people coming to me and asking if I have heard anything because [redacted sensitive information]
There have been no notices posted that I am aware of and it has been left to local residents to advise everyone in the area of the proposal.
I assume the lack of council action is down to the pandemic and everyone working from home!

In view of the lack of consultation I would explore you to ensure the deadline for making representations at present the 11th October 2021 is extended and would be grateful if you would confirm you will do this.

Comment

Representation ID: 45913

Received: 05/10/2021

Respondent: Ms Joanne James

[Consultation Process]

I have submitted my objections to BCP but the consultation process is flawed and discriminatory. Communication of this plan has been extremely poor and over complicated meaning people are either unaware of it, or don't know how to respond.

Councillor Nawaz said "If the council can send a council tax bill to every house in the borough, then they can let every house in the borough know about the proposals'

Object

Representation ID: 45929

Received: 31/03/2022

Respondent: Walsall Labour Group

Agent: Cllr Aftab Nawaz

[Consultation Process]

First and foremost the consultation has been left wanting and has not engaged with the residents of Walsall. I accept that all that is required statutorily has been done but nonetheless the mark of a good consultation is that people feel that that they have had a fair opportunity to respond. I have found that in Walsall this has not been the case and that the people of Walsall feel disenfranchised of their democratic right.
The process needs to carry the confidence of the people in order for them to feel, whether they agree with the proposals or not, that it has been an honest, transparent
and appropriate consultation. I am afraid the people of Walsall, in my opinion, do not feel that this is the case and have no confidence in the process that has been followed.
The method by which this process moves forward also needs to be more than a cabinet approval. The people of Walsall, through their elected representatives, need
to have a deciding vote on whether to accept these proposals or not. Allowing only a nine member group to decide the fate of our greenbelt will not be seen as
democratically sufficient by the public – and their opinion MUST be respected.

Object

Representation ID: 45930

Received: 11/10/2021

Respondent: Cllr Aftab Nawaz

[Consultation Process]
10. Lack of awareness of the Black Country Plan Proposals
The proposals set out in the plan have not been sufficiently communicated to the residents of St Matthew’s and the wider borough. Many residents in St Matthew’s have openly commented on the lack of awareness, communication and advertisement about the plan and its implications. An unsatisfactory and unengaging consultation will and does lack public confidence. The plan came out during a period where residents were still concerned with the pandemic and although it was extended by two weeks, this in my view has been insufficient and wholly disrespectful process. It seems that the powers that be do not wish to have an extensive and engaging consultation and wish to get the proposals through without opposition. This being the case I feel the Calderfields and all the other proposals should be withdrawn and the process re-started in order to maintain a confidence and to ensure the people of Walsall are not disenfranchised from their democratic right.

Comment

Representation ID: 45944

Received: 11/10/2021

Respondent: Ms Jan Norton

I recognise that Government planning changes are under review.

How might any changes impact on the procedures required to move this plan forward?

To what extent is the plan linked to the Boundary Review proposal to remove Dudley South as a constituency and incorporate Kingswinford with South Staffordshire?

When was it agreed that Kingswinford should become a strategic development area? I would like to see the minutes of the meeting, a list of people present and a summary of the discussion. as there local consultation about this?

I recognise that Government planning changes are under review/

How can the Councils demonstrate that is it giving equal consideration to the requirements of developers and the challenges from objectors?

Has there been a broad-brush analysis of the impact of this level of development on the wide range of services the Council provides?

How does this plan mesh with the reinvigoration of High Streets in, for example, Dudley and Brierley Hill?

To what extent has there been a search relating to protection of certain sites through former donations of land for public use?

To what extend has there been a search relating to sites which may be on former mining land and therefore unsafe? Why have the latter been included in the plan, causing potentially unnecessary stress for residents?

Object

Representation ID: 46068

Received: 11/10/2021

Respondent: Mr Rob Bytheway

[General Greenfield]

I object to any greenfield sites being built on before all brownfield sites have been exhausted, in many greenfield sites valuable wild life prolificates without these insects, pollinators and animals life cannot exist consequently these greenfield sites must be preserved at all costs.