3 Spatial Strategy

Comment

Representation ID: 11747

Received: 08/10/2021

Respondent: Mr John Hemming

The map shown below is totally inadequate & meaningless, local centres like Brownhills, Pelsall etc that are most affected are not even shown !

Object

Representation ID: 11823

Received: 09/10/2021

Respondent: Mr Richard Knight

The spacial strategy is provisioning housing within both areas of high pollution i.e. along the M6 corridor and within the green belt. This will have a negative impact on strategic priorities 5, 6, and 11.

Object

Representation ID: 11826

Received: 09/10/2021

Respondent: Mr Richard Knight

Section 3.33 appears to be incorrect in that Walsall does not appear to be investing in housing in its local centre.

Support

Representation ID: 12009

Received: 10/10/2021

Respondent: Miss Emma Thompson

Agree with the proposal to ensure the Black Country benefits from the right development in the right place at the right time, and that this will meet the needs of people living and working in the Black Country, while protecting and enhancing the environment and the unique character of the area.

Support

Representation ID: 13572

Received: 07/10/2021

Respondent: Mrs Barbara Pritchard

All brownfield sites should be built on before considering building on green belt.

Comment

Representation ID: 13614

Received: 09/10/2021

Respondent: Mrs Sylvia Jackson

1. Greenbelt should be preserved at all costs
2 Has anyone carried out a survey with regard to our ability to feed the population without importing food?
3 Climate change concerns make preservation of Green Belt a top priority
4 Young people should not be confined to huge areas of urban jungle they need clean air
5 Pollution - Newtown and surrounding areas of Brownhills Castings is a major source of pollution in this area. Who receives the disgusting odours/ chemicals is subject to wind direction, weather conditions etc
We also have traffic using the A5 and the Toll Road on the other side of Newtown, Quatro using the rail sidings.
6 Local people are concerned at what appear to be high numbers of cancer cases in our area
7 We have [Redacted-sensitive information] living in our area as well as birds. You can't expect them to discover where they can exist in the future. There are a lot of horses - they need fields and hay. Leave the countryside alone and look at town centres where shops are closing with a view to providing homes

Object

Representation ID: 13696

Received: 09/10/2021

Respondent: Miss Jane Edwards

I moved into Aldridge from Rushall [Redacted- sensitive information] I have noticed since that time the decline in quality of life yes it is a lovely part of Walsall to live and unfortunately this seems to make it the go to place to build at the expense of the residents my objections are in no particular order
- an extensive amount of green space has gone over the years reducing places for children to play and wildlife to be
- The infrastructure is so congested it is very difficult to move around. Aldridge is bumper to Bumper traffic most times of the day
- Morrison's for much longer than the current situation was approved has had empty shells and Sir are too many people trying to shop shops won't cope with more people please don't build these too
- how will gp's schools dentists cope
- I am worried about the effects of car fumes etc due to the amount of traffic. I don't go out during school hours as it is So difficult to get out of Aldridge
- the community I believe in the main are extremely upset and angry about this
By building in Aldridge you are not addressing the inequalities in the rest of the borough the town centre lots of Bloxwich, Darlaston etc have lots of deprivation if there is a new build then build these luxury family developments there. Put more money into those areas change the balance of the population give them a chance to see their areas improve. also more footfall to shops
- you are keeping the haves and have nots in the borough
- Look for more black sites to build it might be more expensive to make safe but worth it in the long run
- I don't believe for a second this is being done for the good of residents but is a decision made on greed this will be terrible for residents the only interest is money for developers.
- The builds in other areas of the borough are tokenistic we might look like we have a lot of green, empty land but this is being used
- local councillors do not support this

Object

Representation ID: 13763

Received: 10/10/2021

Respondent: Ms Linda Cross

This is a a horrible disgusting and dangerous plan to take away the only remaining green places our children will see growing up in the black country. You seem to just focus on the business side of things and not from the people's side. More and more of our vital green fields are disappearing and ugly identical buildings are shooting up, hiding nature and blocking views. All we see will be houses, factories and carparks. Where will our children get to enjoy nature and see their environment anymore.

The number of cars will rise, pollution will be above accepted levels meaning more people will suffer health conditions and need NHS care. I refuse to accept the need for homes outweighs the distruction of natural environments that make our lives pleasent and keeps our air breathable.
Think again about this decision. We are already full and taking away our only green places will impact on every aspect of our vital needs concering our mental health, medical needs and appearance as the black country becomes an ugly built-up carpark.
We deserve better and I beg you to look elsewhere for houses to be built, as always choosing poorer areas such as ours will have a knock on effect for the worst on everyone. We want to look at trees, grass and nature nearby. We shouldn't have to get on a bus and travel to a licensed park to enjoy what God intended, it should be on our doorstep.
Thanks for reading this and I hope it has a bit of a help in pursuading the council to do the right thing and rip up this terrible proposal.

Object

Representation ID: 13775

Received: 25/09/2021

Respondent: Mrs Leslie Ann Harris

Too much land is being spoiled by new housing developments. We are supposed to be protecting our green spaces for the environment and mental health. More housing etc means more transport more cars and nowhere to walk in peace and park lands, without fear of cars belching all sorts into the environment also lorries use brownfield sites surely

Object

Representation ID: 14595

Received: 10/10/2021

Respondent: Ms Catherine Nelson

I was really sad to see how much of the plan covered green spaces, often well known beauty spots.
I would like more transparency about who profits from these new builds, which conservative donors are being rewarded by MPs passing their plans. One would like to think that this is not happening but it does seem that big housing companies are also donors.
I am very against building on farmland and green spaces. This never ending programme of covering the land with tarmac has had such an effect on our environment. Lack of drainage due to the concrete affects flooding. We are also seriously affecting our eco system.
Building on the farmland reduces our capacity to produce food and we are becoming more reliant on imports, again affecting the climate with long journeys and complex production systems.
Finally these green spaces are hugely important to people’s well being and this has been even more apparent during the lockdowns.
I appreciate that building on used land, old factory spaces etc is more expensive and can be complex due to its previous land use, but I think that this should be always done before building on our green spaces.
I hope that the plans around the green spaces are not passed.

Object

Representation ID: 14651

Received: 09/10/2021

Respondent: Collette Henry

Do not build on any more green belt

Object

Representation ID: 14704

Received: 09/10/2021

Respondent: Jamie Perks

I am sending this email in order to register my objection to the plan to permanently remove yet more local green belt land for housing. This process is irreversible and should not be taken just because it is the easy option.
All around us there is plenty of brownfield sites that can be developed for housing without the need to remove more of our green spaces. I’m sorry but I don’t buy the argument that there isn’t enough brownfield sites to cover the housing needs; all around us there are empty warehouses, factories, shops & even town centres! You need to be more creative in your thinking and save some green spaces for our future generations as once it’s gone it’s gone forever!

Comment

Representation ID: 14834

Received: 10/10/2021

Respondent: Alison Wilkes

3 Spatial Strategy
3.1 Figure 2 Key Spatial Diagram
All allocations should be depicted as points to ensure a true depiction of the impacts of development allocations.

Object

Representation ID: 16488

Received: 10/10/2021

Respondent: Ms Elizabeth Clark

I am objecting because we need to keep our green spaces safe. The loss of these green spaces will be devastaing to wildlife. Also the roads around these spaces already struggle under traffic conditions now it would be even worse with more houses being built the schools are already under strain to take in new pupils and drs surgeries are under pressure coping already with new houses being built there will be an increase indemand for drs spaces spacea for schools and more traffic on the roads which are already an absolute nightmare as it is.

Object

Representation ID: 16957

Received: 11/10/2021

Respondent: Kerrie Richards

Can you please post a copy back to me to ensure receipt.
I want to raise the following objection to the Local Plan
I have lived and worked within the Black Country and surrounding area all my life and wish to object to the Black Country Local Plan methodology and process as follows:
1. Local Plans should safeguard areas that have local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity. There are sites selected that are disregarding this policy.
2. Building on green belt takes away high quality accessible natural greenspace which is a necessity to reduce pollution and help in the global fight against climate change. Building on green belt areas should only be considered as a last resort when ALL other sites have been identified. Not all brown sites have been proactively identified in this process, you have used a call for sites and this is not proactive.
3. Local mental and physical needs have not been assessed when selecting sites, these accessible green areas are vital to our communities health and wellbeing.
4. Not all of the designated sites are in areas where employment is increasing or growth is identified. The policy is a “finger in the air” policy that looks at sites put forward and doesn’t assess the economical or growth needs of each individual area. Assis ng other authorities with housing needs because they are not providing the houses is just widening the issue of unnecessary building on green belt.
5. The process of asking for feedback on sites once the preferred options are already identified is not democratic.
6. There should be a study made of all land and buildings that would benefit the communities if they were developed. I.e., brownfield, derelict, businesses looking to close or relocate, buildings that have potential to be re-classified. Only when all of these have been studied should there be any consideration of building on green sites.
7. The housing target numbers are outdated. The empty homes haven’t been taken into consideration, neither has the impact of Brexit or Covid which are key considerations at this current me.
8. The consulta on process is difficult for lay people to understand and therefore gives the developers an unfair advantage. There is not enough opportunity for the non-technical person to object to sites.
9. The current government is calling for a re-working of policy against building on green belt sites. The continuation of the local plan is therefore a “local officer led” initiative not government led, and thus once more is undemocratic.
10. There is no incentive in this process for developers to put forward brown field sites if green belt sides are under consideration.
11. The quality of life of existing residents has not been considered. The stress and worry and reduction in house value of proper es bordering green belt sites.
12. The process encourages land banking.
13. Not enough adequate studies on the infrastructure on land put forward as preferred by neighbouring authorities or within neighbouring authorities.
14. The green belt provides easy access to the countryside for local residents. The plans wording allows for the re-drawing of green belt and doesn’t value for the benefits it provides for current residents.
15. No rail networks will force more commuters to use cars and further gridlock the roads.
16. The doctors and schools are already over subscribed, or will not be able to cope with the planned extra housing - there is no joined up plan to take into account the extra strain on amenities and infrastructure that will be also caused by the South Staffordshire plan that has preferred sites on the Black Country Border. ie Lower Penn.
17. There is already congestion on the roads, which is adding to pollution, however consideration should also be given to the increased risk of accidents with more vehicles being pushed to use local village roads.

Comment

Representation ID: 17151

Received: 11/10/2021

Respondent: Worcestershire County Council

Emerging Spatial Strategy
As set out in previous Regulation 18 consultation responses to the Draft Local Plan, we have concerns about the potential cumulative transport impacts of the growth set out in the Plan on the network within Worcestershire. It is clear that several proposed development areas could have an impact on the county’s transport network.
Previous responses have confirmed that the specific issues that should be considered are:
• Key transport routes in and around north Worcestershire including access to M5 junctions 3 and 4, and M42 junction 1.
• Some local roads are currently at capacity and transport modelling is necessary to understand the capacity of the local roads to accommodate further traffic generated from new development. In terms of the relationship between growth in the Black Country Plan area and Worcestershire’s highway network, these impacts will primarily be along WCC’s network into Bromsgrove.

Comment

Representation ID: 17629

Received: 07/10/2021

Respondent: Mrs Julie Leavesley

Number of people: 2

Fundamentally I think the government are wrong to ask individual councils to meet a quota of housing needs. We have limited green areas in the Walsall borough and if this progression continues, we will not have any. I moved to Pheasey, paying higher house prices, to have the countryside on my doorstep and now this is potentially at risk.
Wouldn't it be a better idea to develop new towns in larger open areas to meet the housing crisis as we did with Tamworth & Milton Keynes in the past.

I'm concerned that once this land gets built on it won't take long before all the fields are gone.

Comment

Representation ID: 17651

Received: 07/10/2021

Respondent: Mrs Patricia Rabone

I am sure that there must be plenty of brownfield sites to use first. I believe that building on Green belt is the easy option.

Comment

Representation ID: 17786

Received: 04/10/2021

Respondent: Mr Keith Allen

In deciding upon which sites throughout the region will be developed, it is essential that all brownfield sites are used first before any further incursion into the Green Belt. It appears far too easy for councils or developers to find 'reasons' not to build on brownfield sites. Developers appear to want an easy ride, to be able to build, sell and leave as soon as possible and with the maximum profit. Builders should be required to develop a brownfield site before they are given permission to build elsewhere and an incentive to develop brownfield sites could be permission being granted for a choice site only when the brownfield sites have been developed.

Support

Representation ID: 18504

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.1
Support: WTBBC support the aim of the plan to ensure the Black Country benefits from the right development in the right place at the right time, and that this will meet the needs of people living and working in the Black Country, while protecting and enhancing the environment and the unique character of the area.
WTBBC are of the view that this aim would be stronger and more impactful if this read …protecting and enhancing the natural and built environment and the unique character of the area.

Comment

Representation ID: 18505

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Figure 2 - Key Spatial Diagram
Comment: On the Key Spatial Diagram it is difficult to distinguish Core Regeneration Areas from the Black Country Green Belt. Furthermore, the diagram depicts only selected development allocations, which doesn’t make the cumulative extent of the impact of these on the landscape clear. It should be made clear in the key that the diagram only shows a selected number of allocations, or alternatively all allocations should be depicted as points.

Object

Representation ID: 20829

Received: 04/10/2021

Respondent: Mr Richard Butler

Objects to Greenbelt proposal sites, esp. in relation to Wolverhampton.
Grounds cited are: very limited amount, precious, sufficient brownfield sites exist & should redeveloped.
Also cites loss of nature conservation/biodiversity sites & habitats,
cites overcrowded urban area already, proposals will exacerbate this, and that more nature conservation sites/habitats are req, not less, esp. for communities and childern.

Support

Representation ID: 21239

Received: 11/10/2021

Respondent: Newlands Developments

Spatial Strategy (Section 3)
The Spatial Strategy is set out in Draft Policies CSP1, CSP2, CSP3 and CSP4, and illustrated on the Key Spatial Diagram (Figure 2), which provides the overarching basis for the Plan’s proposals for growth and infrastructure improvements. We are supportive of the Key Spatial Diagram, as this accords with Paragraph 23 of the NPPF, which requires broad locations for development to be indicated on a key diagram, and land-use designations and allocations identified on a policies map.
The Site, located in Walsall, is identified on the Key Spatial Diagram as an employment development site (EMP1) located within a Core Regeneration Area (CSP2).

Development Strategy
Draft Policy CSP1 (Development Strategy) provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039. Part 1 of this policy seeks to deliver at least 355 hectares of employment land. Part 2 explains that the spatial strategy seeks to deliver this by focusing growth and regeneration into the Growth Network that comprises the Strategic Centres and Core Regeneration Areas. We are supportive of this policy, which seeks to direct growth to the most sustainable locations and to sites which have been assessed as most suitable by the Black Country Authorities’ site selection process and as part of the Sustainability Appraisal (SA).

The Development Strategy, set out under Draft Policy CSP1, has been developed through a comprehensive assessment of a range of alternative options, as set out in the Spatial Options Paper. The SA also includes an assessment of eleven spatial options identified by the Councils. Each option has been assessed for its likely sustainable impacts.

The Preferred Spatial Option selected is Option J (Balanced Growth), which focuses growth within existing Strategic Centres, Core Regeneration Areas and Towns and Neighbourhood Areas in the sub-region. The strategy takes advantage of their existing infrastructure capacity, in addition to a limited number of new growth areas near to the edge of settlements that take account of environmental, climate change, accessibility and socio-economic requirements. Spatial Option J ensures that development within the Green Belt is only located in the most sustainable locations with good access to help reduce reliance on private car usage. This approach, along with Spatial Option J, is fully supported.

The Site benefits from a sustainable location with good access to surrounding sustainable modes of transport. There are two bus stops located immediately adjacent to the north of the Site along Bentley Lane. From this stop, services connect the Site to Walsall and Wolverhampton with regular 30-minute services seven days a week. The Site’s good public transport links are also important in the context of Paragraph 142 of the NPPF, which identifies that where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land that is well served by public transport.

With regard to the local road network, the Site is located along Bentley Lane, which provides direct links to M6 Junction 10 via Bloxwich Lane, and is suitable for use by HGVs. The Walsall to Wolverhampton Core Regeneration Area is based around the Black Country Route and M6 Junction 10 road corridor, which is located approximately 2km to the south of the Site. This sustainable location, which is also in close proximity to a large labour force, means that it is suitable for high quality industrial and logistics development. It is therefore considered that the Site is suitable and deliverable and could be released from the Green Belt to provide much-needed employment land. This would be in accordance with the aims of the NPPF and would also assist in meeting the employment land need of the District and the unmet needs of the FEMA.

Object

Representation ID: 21605

Received: 11/10/2021

Respondent: Ms Christine Pugh

I wish you to know that I strongly object to t e removal of any land from our green belt at this time and to the justification given by the council.

My reasons are as follows

1) Land can only be removed from green belt under exceptional circumstances. These are not
exceptional circumstances.

So you or your planning department have taken exceptional circumstances to mean unreliable targets
from government and almost certainly out of date assessments and then proposed a plan which,
according to Marco Longhi MP, will result in 1000 more homes than necessary being built.

Green belt legislation serves 5 purposes according to the National Planning Policy Framework, 3 of which are checking unrestricted sprawl, safeguarding the countryside from encroachment and assisting in urban regeneration by encouraging use of derelict and other urban land.

It would be reckless in extreme to remove more land from our green belt before government has had time to review its position and further up to date assessments of need and brownfield sites have been carried out.

2) Use of green belt flies in the face of the Government's other big idea of protecting and improving the natural environment.

3) There is concern in many quarters that inadequate consideration of use of, and incentives for, brownfield sites has given developers the upper hand, using their preferred easier options instead.

4) That the draft plan, which is both controversial and out of date, has lacked proper public scrutiny throughout the process so far with this current consultation being launched at an inappropriate time, apparently full of mistakes which had to be rectified during the consultation
and likewise a system for engaging with it which did not work properly and discriminated against many residents.

My evidence for the above

1) on the number of houses needed

2) Contrary to the Government's idea of protecting and improving the natural environment and access to it
Sacrificing 3% of our green belt for housing we do not need is a move in the opposite direction

3) inadequate use of brownfield sites

4) on the process

The evidence here is my personal experience and that of neighbours plus what I have read in the press. I heard about the plan from a neighbour who heard about it from the postman.

Although I oppose the use of all green belt, I am particularly incensed by the decision to include Land off Viewfield Crescent, which is more correctly called land in Cotwall End Valley. On that I definitely have more to say.

Comment

Representation ID: 21622

Received: 11/10/2021

Respondent: Councillor Richard Body

It is claimed that there are exceptional circumstances now regarding the need for housing and commercial premises, I believe that there is no justification for removing the protection on greenbelt and greenfield land. It can never be replaced as a source of pleasure and enjoyment for the community. It is not sustainable to build on our countryside, resulting in loss of farmland, natural habitat for wild life, hedgerows and trees.

There are many brownfield sites that remain unused because builders prefer new, easy to develop sites that bring greater profits.The homes built on these greenfield sites are not affordable for most people. More recently many shops and offices are closing whose sites would provide extra capacity for homes in towns and cities which are in need of revival and redevelopment.

Large developments on the edge of our communities bring extra traffic to roads that are already over busy, and extra pressure on local services such as schools and health centres.This lowers the quality of life for the existing population and brings the same problems for the new residents that they may not have anticipated. I do not support any loss of green space, greenbelt land or
greenfield land.

Comment

Representation ID: 22045

Received: 11/10/2021

Respondent: Ms Jan Norton

I have seen no impact assessment regarding equality issues, in particular, considering the needs of people in poverty (BCP, 5.10), unemployed adults, children, young people and families, the elderly and people with mobility issues or disabilities and other vulnerable people who struggle to obtain housing which meets their needs. (BCP, 3.74 Strategic Priority – housing that meets all our needs)

Was there an offer to support people with physical problems, for example, visual problems to access the information they needed?

Has anyone, as part of this process, checked out the needs of the most vulnerable in our society, for example, elderly people living along in what was a family home; homeless people; refugees; former prisoners?

Has there been any feedback from children regarding informal green spaces which might inform us of the benefits from their perspectives?

Comment

Representation ID: 22046

Received: 11/10/2021

Respondent: Ms Jan Norton

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 Boroughs precious other green spaces.

Comment

Representation ID: 22047

Received: 11/10/2021

Respondent: Ms Jan Norton

Has there been an impact assessment on the potential for the Dudley Borough to move towards net zero carbon within the timeframe of the Plan and meet ongoing COP objectives? Aren’t these plans likely only to accelerate a carbon excess? (BCP, council plan to achieve recommendation that 100% of new housing will be carbon neutral by 2030)

Comment

Representation ID: 22076

Received: 11/10/2021

Respondent: Kinver Parish Council

Removal of Green Belt:

• Eroding the defensible and policy boundaries (such as green belt to prevent against urban sprawl) has a detrimental impact on the wider area.
• Do all the proposed strategic allocations that necessitate green belt release fail to meet the 5 purposes of green belt set in the NPPF? The evidence base does not make clear how the sites to be released fail part or all of the purposes.

Support

Representation ID: 22265

Received: 21/01/2022

Respondent: Miss Jodi Stokes

3.0 SPATIAL STRATEGY

3.1 The Spatial Strategy is set out in draft Policies CSP1, CSP2, CSP3 and CSP4, and illustrated
on the Key Spatial Diagram (Figure 2 of the Draft Black Country Plan consultation document dated July 2021). This Spatial Strategy provides the overarching basis for the Plan’s proposals for growth and infrastructure improvements. This Key Spatial Diagram is also supplemented by thematic key diagrams for housing, economy, transport, environment, waste and minerals. This therefore meets the requirement of paragraph 23 of the NPPF that “broad locations for development should be indicated on a key diagram, and land-use designations and allocations”.