Draft Black Country Plan

Object

Representation ID: 10641

Received: 28/08/2021

Respondent: Nicola Oswald

It costs more for house builders to develop brownfield sites so of course they want to build on easy green belt fields purely for the sake of profit. Residents do not want this. An extinction event is in progress globally and every piece of greenbelt is ecologically irreplaceable once built upon. Choose life on earth over house builder profits today, it is that simple.

Comment

Representation ID: 10654

Received: 30/08/2021

Respondent: Mrs Jayne Dwyer

Multiple studies have shown that access to green spaces reduce stress and boost mental and physical health. Green spaces are also associated with better air quality, reduced traffic noise, cooler temperatures, and greater diversity. It is therefore completely understandable that residents and community groups would support focus on 'brownfield sites first' and wish to protect green belt

It's obvious that developers/landowners prefer removal of land from the 'green belt' for development, as expensive costs and longer construction times associated with brownfield sites can eat into profit margins

A dangerous precedent is being set by removal of green belt!

Object

Representation ID: 10863

Received: 16/09/2021

Respondent: Mrs Dawn Bissell

I do not believe green belt should be built on. PLEASE use the brown field sites first as they are usually in areas with much better facilities for a growing population.

Comment

Representation ID: 11482

Received: 04/10/2021

Respondent: Walsall Group of the Ramblers

Please see attached file

Object

Representation ID: 11897

Received: 10/10/2021

Respondent: Land and horse owners

USE BROWN SITES and other housing before destroying green belt

Object

Representation ID: 12076

Received: 11/10/2021

Respondent: Mr Gary Flint

The plan and the how to consult especially online can be a difficult site to navigate, not everyone has had access weather paper version or online and the vulnerable are still fearful of engaging due to the pandemic I hope this maybe reflected upon

Comment

Representation ID: 12300

Received: 30/09/2021

Respondent: Cllr Lorna Rattigan

On looking in the Black Country plan booklet, it is identifying only Coronation Road and mob lane, within Pelsall and Shelfield. Does this mean that the area shaded in Greenfields and stubbers green and Barns lane in Rushall and Shelfield are no longer being looked at or deemed not suitable?
Kind Regards
Clrr Lorna Rattigan.

Object

Representation ID: 13203

Received: 08/10/2021

Respondent: Mr Brad Tutts

n/a

Object

Representation ID: 14046

Received: 04/10/2021

Respondent: Ms Amanda Kahsin

no text provided

Comment

Representation ID: 14066

Received: 01/10/2021

Respondent: Mr Frank Bishop

Believe this consultation has been poor in accessing those that do not use on-line or in surrounding areas that will be affected. The on-line forms were not easy hence the use of printed version. No access to letter boxes for drop off in the council buildings

Comment

Representation ID: 14551

Received: 10/10/2021

Respondent: Alison Wilkes

1.43 e) Climate change and protecting and enhancing the environment
Comment: Enhancing the natural environment is key and explicit reference should be made to this.

Support

Representation ID: 14630

Received: 23/09/2021

Respondent: Mrs Freda Taylor

No text submitted

Object

Representation ID: 15362

Received: 10/10/2021

Respondent: Mr Kenneth Wall

Number of people: 2

We strongly object to this plan and any other plan which we consider:
1. Risks the devastation of our Green Belt/spaces within existing communities and boroughs.
2. Risks further urban sprawl within existing boroughs and communities.
3. Risks further loss of local Green Belt/spaces which penalises local communities by increasing population of those communities to share smaller local Green Belt/spaces.
4. Imposes further congestion and strains on local services, roads, etc, to what could be construed to be overstretched at present.
We have never, nor will ever, supported anyone who is in favour of developing or using Green Belt or spaces for housing factories (or other use) other than public use and recreation until every last inch of Brownfield sites is exhausted. Therefore we strongly oppose the Black Country Plan which in our opinion, propose the mis-use, as stated above.
We are aware of the Governments position to build 300,000 new homes each year for the next decade (present plans which could be extended). We are also aware of current government figures of net immigration which show 312,000 for 2020.
This is somewhat more than a coincidence, and in reality shows that each year, for the next decade at least, we would need to build 2 towns the size of Walsall. At present we find the population of Walsall is 286,700 people, within a total of 107,000 homes. This equates to 2.65 residents in each home. Therefore having to build 300,000 homes within the borders of existing boroughs is not sustainable. The Black Country Plan recommends that Walsall Borough builds some 7,100 homes (in the first phase) which equates to approximately further residents of 19,000. So we end up loss of Green Belt/spaces with a greater population to share it with. This not only penalises the existing communities but also the new residents.
In attempting to cram new residents plus their homes, employment, etc into the existing boroughs will have massive effect on current services (Doctors surgeries, hospitals, police, fire, schools, etc.) which are already struggling to meet current workloads and commitments which are only to aware of. It is simply not enough for this Plan to speak of additional services to provide for the additional population, but as we are only too aware of the excuses bandied about locally now about lack of funds, lack of bodies in response to our reasons as to why we have to wait for action.
We are also aware that the congestion on local roads will only be added to by the simple fact that current situation within the four boroughs concerned have certain heavy areas that struggle with the increasing traffic burdens thrust upon them.
Upon planning for future requirements on the scale as per the governments figures mentioned earlier, it surely cannot follow that the homes, employment, services, roads, population cannot be shoe-horned into existing boroughs to the detriment of both existing residents and new residents benefits.
We surely have enough space within the United Kingdom to facilitate the homes and services required without creating massive urban sprawls by drawing in different boroughs such as Dudley, Sandwell, Walsall and Wolverhampton as one, which this Plan would eventually do.

Object

Representation ID: 15367

Received: 08/10/2021

Respondent: Mr Kenneth Green

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 Middlemore Lane West, Aldridge WS9 8DR, 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 the 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 eco-structure 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

Object

Representation ID: 17498

Received: 10/10/2021

Respondent: Mrs Rebecca Stanier

Regarding the Black Country Plan: Draft Plan Regulation 18 Consultation
I am logging my very strong objections to this plan.
Firstly I believe the communication regarding this plan has been over complicated and also discriminatory by lack of publication to local residents whom this impacts.
It has centred on website information but you have left out members of the public who either choose not to use or do not have access to the internet. While there has been information provided at libraries and public centres if people were not made readily aware in the first place they cannot access the information and have the right to respond.
With this proposed build there will be irreversible damage to the greenbelt which in itself contradicts the governments plan that the green belt is preserved and maintained, and also to help stop climate change and plant more trees.
There is already established hedgerows and trees in this area which provide oxygen and homes for endangered species ,11 REDLISTED BIRDS are found in this area along with bats and insects all vastly in decline. This will only speed up their journey to extinction.
The mental well being of communities will also suffer, again the government recognise the advantages of greenbelt land has on communities even more so after the past 18months . this will be taken away from existing communities and wont be an option for new communities made in this area after the build.
The present Infrastructure WILL NOT COPE with anymore people in the area.
Schools are already oversubscribed...will any more be built?
Doctors and Dentist already struggle....will there be more surgeries to cope with the influx of patients, all while the NHS is already at breaking point?
Supermarkets are already open 24 hours a lot the time the shelves need replenishing as cannot cope with the customers they have...where will people get their shopping?
Congestion in this area is already high, will the roads be able to cope let alone to mention an increase in pollution, bigger commute times, maintaining of highways.
Building these houses will have negative impact in the area especially with air and noise pollution not only while they are being built but forever afterwards.
Green belt land is in place to stop neighbouring towns merging, assist in the safeguarding of the countryside from encroachment, this build will do the opposite of this nor will it assist in urban regeneration by encouraging recycling or urban or other derelict land. There is also historical facts and buildings within this area which will be lost forever, again very damaging.
There is also a natural water feed with an underground overflow pipe running from Barr Beacon Reservoir next to Doe Bank Lane which the surrounding fields are a flood plane to, if this was built on surely it would be unsafe and cause major problems if it was ever burst/flood.
I strongly believe that you re consider the development in this area and allow it to remain protected, not only for us but for future generations too.

Comment

Representation ID: 18218

Received: 11/10/2021

Respondent: Mr Trev White

Please note: I have tried to submit my comments on the plan via the web site.
However, I have not received confirmation of receipt. I am therefore sending a copy to your email address.
My concerns are as follows:
1. The dire attempt at consultation. The closing date has meant that this is a rushed response

Object

Representation ID: 18396

Received: 10/10/2021

Respondent: Mr Raymond Lamb

[Objection without comment]

Comment

Representation ID: 19264

Received: 08/10/2021

Respondent: Ms Ruth Watton

I would also like to take this opportunity to raise concerns about the inadequate consultation period. I'm sure that the Council is only to aware that the vast majority of residents strongly object to greenbelt development and can only assume that this is the reason that the Council has sought to let the draft plan be approved unnoticed by the general public. The leaflet posted by the Council was obviously an after thought due to the outcry about the poor consultation. It was distributed far too late in the process and most residents will mistake it for a pizza menu and bin it accordingly. All residents should have been formally written to months ago, the Council is not reticent to use this approach when collecting Council Tax and statistics for calculating council tax.

Object

Representation ID: 23242

Received: 11/10/2021

Respondent: Member of Parliament

Whilst acknowledging that the current consultation has worked within the framework of the statutory guidelines set down, I do not believe that it has worked within the spirit.
A more rigorous communication plan should have been in place to raise the spectre of the importance of this consultation particularly in areas which could potentially be most affected by any future plan to implement.
In my own constituency Councillors alongside volunteers have been left to play their civic role in seeking to encourage large-scale participation, but we all believe that this should have been backed up with greater central co-ordination.
There is widespread understanding amongst residents from my Aldridge-Brownhills constituency that we need to plan new homes for future generations, the only question we would ask is do we have to facilitate these whilst destroying some of our most precious Green Belt and Open Spaces?
The latest iteration of this Plan is unacceptable to me as the Member of Parliament for Aldridge-Brownhills and to large numbers of my constituents who have contributed to this consultation.
In responding to your consultation, I am insisting, on behalf of the constituency of Aldridge­ Brownhills, that the Black Country Plan lives up to its own aspiration to promote a development policy of Brownfield First.
As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.

Comment

Representation ID: 46265

Received: 11/10/2021

Respondent: Walsall Group of the Ramblers

Walsall Group of the Ramblers wish to make the following comments in the consultation phase of the Black Country Plan. (BCP).
[Our remarks focus on the perceived impact of the BCP on the Walsall Borough - other boroughs in the Black Country have similar Ramblers groups who may wish to comment with respect to their particular areas].
Introduction.
The recent pandemic has clearly illustrated how valuable open spaces are for the health, (physical and mental), of people everywhere. With the Black Country’s already identified lower rates of physical activity, higher rates of obesity, alcohol abuse, depression and social isolation, opportunities for exercise and outdoor outlook changes are vital as the population expands and issues relating to social support within the community are further increased.
Naturally enough we anticipate the erosion of green space that will occur as the Plan is implemented, especially in the strategic building areas bordering on the Green Belt, but look forward to observing the commitments in the Plan that not only aim to preserve trees, woodlands and hedgerows, but also to develop canal towpaths to enable links to other cycle and walking routes. We also look forward to the proposed changes that will lead to multi-functional green spaces and greenway systems. The use of Green Belt land for public open space, sport and recreation appears, to us, a good use of the asset - providing it is done with appropriate care. We welcome resources aimed at furthering the protection of the local natural environment, (SSSIs, etc), whilst also utilising funds to bring these areas nearer to the public, (sensitively), via an enhanced system of cycle and footpath routes.
Footpaths and Byways.
From the footpath perspective we see an opportunity to have footpaths in local boroughs planned/implemented in association with those who might use them. (We have seen enough paths ‘wedged’ into development plans that have proved to be not only unsuitable for users involved, but also prone to ASB and damage).
There is also the further possibility of an expansion of Black Country-wide footpaths - that were popular some years ago - linking boroughs, but which have declined more recently and need refurbishment/improvement, (e.g. The Beacon Way, The Wulfrun Way).
[Four years ago we re-labelled the Beacon Way from Sandwell Park Farm to Castle Ring on Cannock Chase, but lack of resources within Walsall Council has meant we have been unable to publicise this on a local web-site].
Our Concerns
We do however, have significant concerns that there are some of the areas of the Plan which may work to generate a negative effect on the Borough. Having such a considerable amount of open space in the east of the Walsall Borough, we cannot but feel it is inevitable that these areas will be impacted by future housing/employment demands in the Black Country, especially as more brownfield locations are occupied.
However, acceptance that this must be the case does not necessarily mean we are at all complacent about the revised National Planning Policy, nor are we unconcerned about the percentage of building land across the borough which is protected by Mineral Safeguarding Area, (MSA), restrictions.
Instinctively we feel that with some many houses planned in strategic areas, (3710), and also (515), in brownfield sites standing on MSA locations, that there will be an advancement of mineral extraction activities ahead of the building deadlines that not only have the potential to disrupt local existing footpaths for several years, but also indirectly impact on any proposed ones.
We also fear that the revised National Planning Policy will generate inappropriate building developments that whilst being contained within the confines of the Plan will generate areas of rapid urban decline/inaccessibility in the short-term thus further reducing available space to those wishing to actively travel in the borough.
Proposal.
As a Ramblers group committed to furthering the interests in walking for both health and social motives, [at the same time as supporting fully the Plan’s strategic policy 11- to protect the natural environment, wildlife corridors, countryside landscapes, etc including an interlinked green infrastructure protection/maintenance of the countryside], we would wish to see introduced a separate Black Country-wide Footpath Development Plan, that is clearly documented and approved.
We would see this running in parallel to the wider BCP timescales and fully accessible to all interested parties. On a positive note, however, we feel that as far as Public Rights of Way, (PROWs), are concerned the implementation of the BCP should be used as a means of expanding the footpath network in both Walsall and across the other boroughs of the Black Country.
Black Country-wide Footpath Development Plan, (BCFDP).
We seek a coordinated development of this network expansion between the BCP itself and reviewed/updated Rights of Way Improvement Plans, (ROWIPS), in all boroughs. We see this operating via a Black Country ROWIP, (created from individual borough ROWIPs), that is monitored via Local Access Forums, (LAFs), whose members are drawn from ROW user groups, (e.g. walkers, horse riders, cyclists, canal boat owners, etc).
As in the BCP itself, the current Walsall ROWIP places much emphasis on the maintenance and development of public open space and hence the ROWIP/BCFDP should work in parallel over the entire duration of BCP to ensure a long-term strategy for footpaths and adjoining spaces is produced and enacted.
(The Walsall ROWIP is already being prepared for an overdue review and we hope to have some input into that once more).
However, recent reductions in resource levels with ROW Teams throughout the Black Country suggests that currently this might be unattainable and that cost-saving will continue to dominate this area allowing an uncertain and likely unplanned development of leisure services in this section.
(Walsall Situation).
Ramblers volunteers in Walsall have worked closely with Walsall MBC Rights of Way team for some years to help keep footpaths and byways in order throughout the borough, but whilst being exceptionally grateful for their commitment, we are acutely aware of their limitations.
We are working closely with the ROW Team in Walsall Council, both in monitoring footpath situations and actively volunteering to help keep local routes open and viable. (This is particularly important in an urban area where paths are somewhat limited, but as a result our more rural footpaths are heavily used by the general population).
Our own LAF has been operating in ’background’ mode owing to pandemic restrictions, but we are seeking to reinstate it shortly. We see this function as a means of keeping abreast of the BCP’s progress whilst also permitting representation of implicated Council departments for discussion along the way.
Like many other areas of the Council, the ROW Team is under-resourced and consequently all project and proposals take a long time to move forward – especially since COVID restrictions.
[We are currently attempting a DMMO to formalise the route of Sutton’s Drive on the Great Barr Hall Estate, but progress is particularly slow further and exacerbated by delays incurred by continued remote working by the MBC].
In Conclusion.
Footpaths and opportunities to take exercise in the wider environment have already demonstrated their benefits and will continue to do so. We therefore need to understand the changes implied by the BCP to make sure that in future our ROWs are not only preserved, but wherever possible expanded and developed. These are assets which all community members within the Black Country have a right to understand and access whenever they wish.