Policy CSP1 - Development Strategy

Object

Representation ID: 10575

Received: 18/08/2021

Respondent: Mr Stephen James Pratt

Policy BCP1 and the BCP is not sound or legally compliant with the Duty to Cooperate since it does not indicate how the identified shortfalls in housing (28,239) and employment land (210ha) will be met. No Statements of Common Ground or Memoranda of Understanding have been prepared with neighbouring authorities indicating how these shortfalls will be met. Furthermore, the BCP does not allocate all the relevant strategic growth locations recommended in the 2018 GBHMA Strategic Growth Study, which sought to demonstrate how the current shortfall in housing provision from the GBHMA could be met. The BCP is therefore unsound.

Support

Representation ID: 10975

Received: 19/09/2021

Respondent: Jonathan Browning

2f - the default for any development must be to maintain and preserve existing buildings, listed or otherwise, to reduce the carbon impact of demolition and new construction. Developers should be required to justify why existing buildings should be removed (eg modern warehouse to residential) - things like asbestos or costs related to repair a Victorian brick structure should not be valid. We should protect the character of the Black Country and heritage assets whilst reducing environmental impact of development.

Comment

Representation ID: 11485

Received: 04/10/2021

Respondent: Woodsetton Charitable Trust

Working to a single figure of housing needs to be provided during the plan period.If one thing is true it will be wrong.
A range of housing needed would be more resiliant.
Also in deciding what and how to provide housing consideration needs to be given to what might be housing needs post 2039.
For example if significant areas of Green Belt in Dudley are to be used up to 2039 what does this mean for development options for 2040 onwardss.Does it mean all remaining Green belt then has to be Used.?

Comment

Representation ID: 11542

Received: 05/10/2021

Respondent: Ms Penelope Ladd

Please prioritise using existing properties that are vacant and/or rundown. Please use all possible routes to ensure absentee landlords restore and renovate buildings that have fallen into disrepair. This will also improve the appearance of town centres and local neighbourhoods.
Any new housing must be as environmental/low energy as possible.

Comment

Representation ID: 11571

Received: 06/10/2021

Respondent: David and Marilyn Goode

We need our open spaces to walk and enjoy the countryside - we do not want more houses to look at!!
We do not want any more houses - we want the fields and open land for people and wild life in the area.

Support

Representation ID: 11598

Received: 07/10/2021

Respondent: Mr Paul Hickman

I agree with the aims and objectives in this chapter as being reasonable and necessary.

Object

Representation ID: 11824

Received: 09/10/2021

Respondent: Mr Richard Knight

It is not clear why there is a requirement for over 47000 homes. This needs to be justified.

Comment

Representation ID: 11949

Received: 10/10/2021

Respondent: Emmie Cooney

Have these figures been re-reviewed in light of both Brexit and Covid? How much house stock has been released due to Covid death rates? Do we need to take another look at the numbers before doing irreversible damage to our greenbelt?

Comment

Representation ID: 12010

Received: 10/10/2021

Respondent: Miss Emma Thompson

The term Neighbourhood Growth Areas refers to large-scale developments on greenfield sites
and this should be clear. It should also be clear that these allocations are predominantly in the existing green
belt

Comment

Representation ID: 12015

Received: 10/10/2021

Respondent: Miss Emma Thompson

I agree with the Wildlife Trust: WTBBC support the recognition of the valuable contribution that surrounding countryside and the network of green wedges and corridors provides the Black Country. WTBBC do not support the use of
‘where practical and possible’ in reference to the landscape, nature conservation and agricultural land being
protected and enhanced. This caveat allows for the redrawing of green belt boundaries as proposed
elsewhere in the plan, but its use here weakens the BCA’s assertion that the green belt and the network of
green wedges and corridors is valued for the benefits it provides the Black Country.

Object

Representation ID: 12131

Received: 11/10/2021

Respondent: Mr nicolas crombie

1. the spatial strategy should include a policy describing Sense of place outcomes

2. the spatial strategy should include an objective :- 1.d) : achieve a biodiversity net gain ( BNG)across the BCA

This objective cannot be achieved through measures 2.e and f. alone
and requires additional crosscutting measures across all policies to achieve BNG
-adoption of the proposed Nature Recovery Network (NRN)spatial plan advocated by the Wildlife
Trust for Birmingham and the Black Country

-development and adoption of a Rivers and Canals corridors SPG
- ensuring off site contributions to (NRN) for housing, economic and employment and infrastructure development

Comment

Representation ID: 12206

Received: 11/10/2021

Respondent: Mrs Karen Shaw

You cannot build houses without providing the infrastructure needed to support the influx of residents. Our road network is already congested, the schools are over-subscribed and the healthcare system cannot cope with any additional users.

Comment

Representation ID: 12343

Received: 01/10/2021

Respondent: Christine Leahey

Document Ref. Strategic Allocation WSA3, Site WAH237/ WAH235
The plans state that decisions in planning applications for these sites should be made in accordance with the specific policy requirements. I object on the grounds that this proposal is not taking into account your own policy requirements and design principles as well as these laid out in the Nation Planning Policy Framework.
The policy states proposals for reveloping existing uses within the green belt will only be permitted if very special circumstances can be demonstrated.
The land is currently used of agriculture and should not be changed as per statement above. There are no special circumstances which suggest this designation should be changed nor would it be in line with the framework principles.
Your policy document states that one of the design principles is "improvements to local facilities to support residents & to enhance the sustainability of the existing area, in particular improved capacity at the primary schools and local health centre". The existing area will not be enhanced as there is no infrastructure for transport and schools are oversubscribed as well as the local health centre. Widening the local roads will have a significant negative impact to the local residents, increased traffic, air pollution, noise all of which are identified as factors that would not have an adverse affect on the local area.
There are no existing drainage amenities suitable for such an extensive development and any development will directly contradict your principles of delivering landscape, biodiversity and amenity benefits.
The development will directly and negatively impact your strategy for landscape and habitat creation that provides enhancement, retention and mitigation for established trees and hedges. Any development will have a significant adverse impact on visual amenity and character on aminal species.
The site is in a Mineral Safeguarding area and should be safeguarded as per the National Planning Policy Framework Section 17 "Safeguard mineral resources".
There is a huge need to safeguard our natural resources and this land should be retained for its original designation, agriculture and mineral.
All developments should be based on the "presumption in favour of sustainable development" and the above factors do not comply with this.
The proposals to allocate the site for housing directly contradict your Strategic Priority II which is to protect and enhance the natural biodiversity, wildlife corridors, geological resources, countryside and landscapes. The land is used for agriculture Grade 3a and is consistently producing crops each year. Any change will significantly affect the livlihood and economical well being of the people involved in this valuable food production system.
The proposal to allocate the site for housing directly contradict Strategic Priority 12 which is to protect, sustain and enhance the quality of the built and historic environment whilst ensuring the delivery of distinctive and attractive places. Our area is a very distinctive and attractive place which will be completely decimated and the landscape ruined with development. Visual amenity will be lost and economic detriment on house values for all the local residents.

Comment

Representation ID: 12846

Received: 07/10/2021

Respondent: Ms Sally Franks

I have lived in this area for 58 years and in that time there has been many changes, not many for the better for example the redevelopment of St Margaret's Hospital to Netherhall Park and the fact that Great Barr Hall has been left to "rot", just a ploy to get planning permission for the development. This should never have been allowed to happen.

The area will be transformed into one vast conurbation, any development will wipe out a precious green space, kill off wildlife habitats and pile untold pressure on local infrastructure including schools and health services. I am concerned about the environmental impact of the plans, which will destroy the natural habitats of [Redacted-sensitive information] and several bird species, plants and insects.

Comment

Representation ID: 13582

Received: 27/10/2021

Respondent: Lanpro Services

Comments on Specific Policies
Policy CSP1 - Development Strategy and Policy GB1 - The Black Country Green Belt
For both these policies, the introduction of a caveat is necessary, to stipulate that whilst the general principle that inappropriate
development in the Green Belt will be resisted, this would not be the case where Very Special Circumstances exist. For Policy CSP1 ,
additional wording to point '2e' should be added to cover this. For Policy GB1, similar wording should be added to point '3'. Clarity on
National Policy requirements in this regard is important to guide decision makers in applying the policy.

Object

Representation ID: 13761

Received: 10/10/2021

Respondent: Ms Linda Cross

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.

Support

Representation ID: 13835

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space support the inclusion of the housing figure as a minimum with the wording of “at least 47,837 net homes”. As per the National Planning Policy Framework (NPPF), strategic policy-making authorities should establish a housing requirement figure for their whole area. This figure is required to ensure that the identified housing need (and any need arising from Neighbourhood Area) can be met over the plan period1. The Black Country is part of the Greater Birmingham & Black Country Housing Market Area (GB&BCHMA) and it is commonly accepted that there is severe unmet need in both Birmingham and the Black Country. Table 2 within the draft Plan details that the minimum requirement of 47,837 dwellings is the requirement for Black Country alone, with an additional 28,239 dwellings arising through the Duty to Cooperate. Therefore, the Black Country Authorities should be seeking to maximise their housing numbers over the Plan period to ensure that the complete need of 76,076 is met.

Living Space agree that the spatial strategy should focus around delivering the majority of development in the existing urban area, as this will maximise the opportunity for sustainable development.

Comment

Representation ID: 14569

Received: 08/11/2021

Respondent: Mrs Lynda Webb

I oppose any loss of greenspace and Green Belt designated areas. Brownfield sites must be utilised to meet housing needs as all residents need access to green space for physical and mental health benefits.

Object

Representation ID: 14572

Received: 10/10/2021

Respondent: Caroline Day Bailey

The projected rise in population informs the number new homes that will be required – considering current data these may be inflated and need re-visiting
1. The plan appears to be based on outdated concepts of domestic development. New builds should reflect employment changes (working from home, commuting trends, work-life balance with local leisure & exercise provision and the social benefits of age diversification
to promote community), and should ideally be placed within existing urbanisations, thereby having minimal need for additional infrastructure.
2. Allocation of 19% of new homes to green sites could be accommodated on brownfield sites and remodelling and regeneration of areas with poor accommodation. The green areas around the Black Country provide employment (much of which requires specialist skills and experience); the areas contribute to our personal and national heritage, support our physical and mental wellbeing (as residents and as commuters journeying to/from the concrete constraints of the built environment).

Object

Representation ID: 14650

Received: 02/10/2021

Respondent: Colin Turley

Firstly I believe there is a flaw in the projections that underpin the plan. The projections come from the Office of National Statistics and are based on the average growth of the previous 20 years. The ONS stated that 86% of the growth in population in this period was largely due to free movement within the EU. We have now left the EU and free movement of populations has ceased. The Black Country Plan will be forcing us to build over precious green belt land for homes that are not needed!

Object

Representation ID: 14682

Received: 11/10/2021

Respondent: Debbie Perrens

Whilst the conservative government is destroying our beautiful landscape at a fast rate with the likes of HS2 and various land grabs to 'restart the economy', these proposals of further reducing our greenbelt don't make allocations for greener and nature enriched areas which are desperately needed. Where are more trees being planted that the government claims they will achieve by 2050 (which are needed much sooner) and green corridors so that our near extinct native species are able to roam freely?

Object

Representation ID: 14712

Received: 08/10/2021

Respondent: Mr Dave Morris

I am very concerned that the assumptions and forecasts on which the whole Black Country plan is based are already out of date, thereby making the housing targets invalid before we start.
Recent figures show that birth rate in the UK is now only 1.5 /woman, life expectancy has dropped and the Government insist that ‘the days of unfettered immigration are over’. There also appear to be many EU citizens who have not registered to remain in UK, and these at some point will be leaving. So the population will either be static or even decline – so we don’t need 76000 houses built in the borough, and the 41000 planned on brownfield sites will be more than adequate. So we don’t need to select DUH217 for building

Object

Representation ID: 14745

Received: 09/10/2021

Respondent: Enid Hands

Number of people: 2

I strongly object to the use of green belt land used for housing especially when that land is farm land as is the case in Wolverhampton. We need all our farms so we are not so reliant on imported foods.
Also about 5 years ago Northycote Secondary school was demolished. If this plan goes ahead there are not sufficient schools or doctors and the roads are very busy now at peak times so will not cope with extra traffic.
I hope you comply with the Prime Minister’s speech when he said no building on green fields.
Use brown field sites.

Object

Representation ID: 14755

Received: 02/10/2021

Respondent: Gary Bills

its not fair to the people of the community to give planning permission for so many house to be on greenbelt land just for money ,,it should have proper
consultation of the people it affects ,, not everyone uses computers to find out information about what's going to happen in their area ,,, letters should be sent our to every house hold within that area it affects , not just nearby but the whole of Kingswinford or which ever area its affecting ,,, its disgusting you knock down schools sell playing fields ,, schools are already got more pupils per
classroom than ever !!! Yet no new schools being built ,,,, so where are the children from all these housing developments going to be educated ????

Object

Representation ID: 14759

Received: 11/10/2021

Respondent: Gemma Starkey

I feel that our green spaces are so important. It is a place to get away from all the traffic and pollution. A place to exercise and appreciate nature.
So many people are suffering with their mental health nowadays and green spaces play a vital part in both the physical and mental health of communities. The less green spaces we have, the worse our quality of lives will be.
Personally I find it a necessity [redacted] to be able to go out into the local green spaces with my dog and get away from it all, particularly from traffic noise and overcrowding and just to be able to hear the birds sing and see squirrels running up the trees. These things are priceless and can never be replaced if they become places of development.
I fear in the future we will have less and less places to visit in nature due to green spaces being built upon. We will have less trees to purify our air and more traffic to pollute it! Also, even more housing estates will put tremendous extra strain on our already stretched services and roads.
Please listen to what the people need, and I can hazard
a guess, it’s not more housing in this area.

Comment

Representation ID: 14762

Received: 04/10/2021

Respondent: John Pusall

Stop using our green spaces.there are loads of brown fields site not being used,build on them instead

Object

Representation ID: 14835

Received: 10/10/2021

Respondent: Alison Wilkes

Policy CSP1
2d
Object: It should be clear both that the term 'Neighbourhood Growth Areas' refers to large-scale development on greenfield sites and that these sites are predominantly in the greenbelt.
3.5
Comment: It should be made clear in whose view it is that the sites allocated for development are sustainable, deliverable and will not breach the environmental capacity of the area. What is the evidence for this?
3.7
Comment: the Spatial Options Paper oversimplifies the spatial options available, e.g. Balanced Growth should not and does not exclude Urban Greening. All options should enable the Nature Recovery Strategy.

Object

Representation ID: 14877

Received: 05/10/2021

Respondent: Katherine Baker

With the current climate changes Getting worse and everyone, from environmentalists, gardeners and yes, even central governments throughout the world, why does Dudley council think it’s a good idea to sell of our precious green spaces wherever they are for
building, yes I am aware that we need more houses, but again these need to be affordable ones, not luxury ones that 1st time buyers can’t buy.
The developers are thinking about profit, the green spaces are easier and cheaper to develop and
luxury homes bring in more money for them, at everyone else’s expense.

Object

Representation ID: 14891

Received: 07/10/2021

Respondent: Keith Harrison

Objection to Black Country Plan. What improvements are going to be made to roads, schools,hospitals.

Comment

Representation ID: 15357

Received: 08/10/2021

Respondent: Mr Thomas Collier

Green field sites should NOT be used whilst there are so many empty premises.
Priority should be:
1. Use empty houses, find legal ways to stop profiteers keeping property empty just for financial gain.
2. Relax "change of use" rules. Convert empty shops to residential property. Convert any building to residential or business use e.g. churches, old admin buildings, derelict buildings.
3. Make good "brownfield" sites for commercial or residential use.
4. Provide affordable opportunity for people living alone in buildings where there could be multiple occupancy, especially the lonely elderly who would benefit from moving to premises where there would be company and camaraderie.
5. For every new housing development, provide local shops to negate the need to drive for provisions also local schools, local medical care, local social clubs and local public transport.