Policy CSP3 – Towns and Neighbourhood Areas and the green belt

Comment

Representation ID: 16860

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

And while Walsall FoE is not in a position to analyse in detail the overall
housing need and supply numbers, we are aware of other environmental
groups, such as CPRE, which are in a better position to do so and we share
their concern that the Council is relying on out-of-date housing forecasts from
the ONS.
We would urge the council, along with the other three authorities, to review
the availability of brownfield land and to assess new sources, such as
redundant industrial land and excess retail accommodation, especially in our
existing centres. We believe the council should be seeking more mixed use
and housing development close to and within centres to make them more
viable and reduce travel.
This should allow the council to reduce, or preferably remove the need for
additional housing on the edge of the conurbation in the Green Belt and on
high ecological value sites within the Borough.

Object

Representation ID: 16887

Received: 10/10/2021

Respondent: Miss Jane Williams

I very strongly object to the planning of building on the greenbelt land. Even the government object to it and should only be approved in 'exceptional circumstance /VERY SPECIAL CIRCUMSTANCES.'
Government policy on protection for the Green Belt is set out in chapter 13 of the National Planning Policy Framework (NPPF), which opens by stating that the Government attaches great importance to Green Belts. On protecting the Green Belt, the NPPF urges LPAs to maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. The NPPF demands that there should be “exceptional circumstances” before Green Belt boundaries can be changed and says that inappropriate development is harmful to the Green Belt and should be approved only in “very special circumstances”.
I do not class the building of all these homes as 'very special circumstances' or 'exceptional circumstances'.
The building of these homes on greenbelt is totally unacceptable. We need to keep the greenbelt for generations to come so that we do actually still do have fields/trees, wild life etc which are a great thing for global warming. The building of more homes will not help this situation at all. We will lose the areas where nature is presently happy to live. All kinds of insects, birds etc live in/on the greenbelt and if we get rid of this they will lose their homes and these insects/animals could become extinct.
It will mean a large increase to the population within the areas where you are planning on building. This will put already stretched services such as dentists, Doctor surgeries and schools to the absolute maximum and this is totally unacceptable.
I understand that more houses are needed but the government and councils need to come up with other solutions. Perhaps not letting people buy their council homes is one solution.
This should not be happening at all.
Building on land where pubs/factories/warehouses/large chimneys etc have been demolished is a much better option which has taken place in my area.
You need to re-think this as what we don't want is an of concrete housing with no greenbelt to be enjoyed.

Object

Representation ID: 16967

Received: 10/10/2021

Respondent: Kenneth Carrington

I object to the development of any Green Belt whilst there are adequate brown field sites in desperate need of regeneration.

Object

Representation ID: 17070

Received: 11/10/2021

Respondent: Mike Amor-Wilkes

My objections are this would destroy irreplaceable Green Belt Land lowering the quality life in this area of the Black Country not only enjoyed by people that live in the area but further away.
It will add unacceptable pressure on our local amenities, such as schools, roads that are heavily congested at as it is, Dentists, GP’s, hospitals and other public services.
There has already been a massive building programme on Stalling Lane where fields have been lost, a Brownfield site has been used and a further one in the planning, pressurising local amenities as it is adding to waiting lists and times for all health care users.
Parking issues with insufficient places as it is.
There has been no biodiversity checks been made or wildlife impact assessment.
An audit of preserved or valuable trees has not been carried out.
Exhaust all brownfield site before looking at Green Belt Land.
Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH 206 Worcester Lane
DUH 207 Worcester Lane Central
DUH 209 Worcester Lane South
DUH 217 Wollaston Farm grazing land
DUH 210 Viewfield Crescent
DUH 041 Two Gates Lane Cradley
DUH 212 Lewis Road Lye
DUH 214 Seymour Road Wollescote
DUH 215 Bent Street Brierley Hill

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for residential or industrial purpose.

Object

Representation ID: 17083

Received: 11/10/2021

Respondent: Mr Matthew Davies

Number of people: 5

I am objecting to the plans to build on the greenbelt land. It will make the area overcrowded and lose its appeal, it would be displeasing to see more buildings, bringing more traffic and pollution. We do not want more traffic in our road risking our children's life's.

It will put pressure on services such as gullies, drainage, schools, medical services, etc. The drains and roads in nearby Moseley / Springfield flood when it rains, removing our trees and green land will make this problem worse.

We need to be protecting our environment and nature, not destroying it. Where will the wildlife go? The species that are at risk?

It would be detrimental to people's physical and mental health. Being outside in nature is so beneficial to a person's wellbeing. Removing this natural form of taking care of one's self is only going to add more pressure to already stretched health services. The appeal of this area for me was the closeness of the green spaces right by us and the field opposite us brings us great pleasure when it is occupied by the sheep or cows.

I feel there are many brownbelt sites that need to be explored before destroying our greenbelt. Once this is gone we can never get it back. There are many brownbelt sites around the area that have been le derelict and abandoned for years. The government pledged not to build anymore on greenbelt. These plans contradict this.

It can be destroyed in a matter of moments, but these lands have been here for many many years, enjoyed by many previous generations. Why are you taking this away from our future generations? I see you have already put up masts, encouraging more young people to stay home on electronic devices, not outdoors enjoying nature. This would be so bad for our future generations.

Object

Representation ID: 17085

Received: 11/10/2021

Respondent: Miss Rachael Villau

I am objecting to the plans to build on the greenbelt land. It will make the area overcrowded and lose its appeal, it would be displeasing to see more buildings, bringing more traffic and pollution. We do not want more traffic in our road risking our children's life's.

It will put pressure on services such as gullies, drainage, schools, medical services, etc. The drains and roads in nearby Moseley / Springfield flood when it rains, removing our trees and green land will make this problem worse.

We need to be protecting our environment and nature, not destroying it. Where will the wildlife go? The species that are at risk?

It would be detrimental to people's physical and mental health. Being outside in nature is so beneficial to a person's wellbeing. Removing this natural form of taking care of one's self is only going to add more pressure to already stretched health services. The appeal of this area for me was the closeness of the green spaces right by us and the field opposite us brings us great pleasure when it is occupied by the sheep or cows.

I feel there are many brownbelt sites that need to be explored before destroying our greenbelt. Once this is gone we can never get it back. There are many brownbelt sites around the area that have been le derelict and abandoned for years. The government pledged not to build anymore on greenbelt. These plans contradict this.

It can be destroyed in a matter of moments, but these lands have been here for many many years, enjoyed by many previous generations. Why are you taking this away from our future generations? I see you have already put up masts, encouraging more young people to stay home on electronic devices, not outdoors enjoying nature. This would be so bad for our future generations.

Object

Representation ID: 17215

Received: 11/10/2021

Respondent: Natasha Flowers

I wish to object in the strongest possible terms to ANY building on green belt in the Dudley Borough area.
In the Council Scrutiny meeting on 6.10.21 your officer [Redacted-sensitive information] admitted that NO bio diversity checks have been made or wildlife impact assessment.
Our roads are already gridlocked, schools over subscribed, GP's over subscribed, huge waiting lists at hospitals.
People need green spaces for mental health and physical fitness. The impact on the environment and climate by building over remaining green land has been underestimated. An audit of preserved or valuable trees has not been carried out.
The quality of life for existing residents will be greatly diminished, with more traffic, parking issues, nowhere to walk dogs or just take a walk in a green environment.
The plan mentions re-wilding - but where will that be as all available space is gradually eroded and built on. Why not just leave the existing habitat alone.
I do not believe that 'exceptional circumstances' apply in any of the areas listed. I do not believe that all brownfield sites have been identified. I do not believe that all empty Council houses that could be refurbished have been. It is clear that if there is a shortage of land that there should be a preference or flats or maisonettes thereby creating more housing from the same brownfield plot.
A question was also raised in the Scrutiny meeting regarding the data upon which the housing requirement has been calculated. Dudley Council should ask for this to be reviewed particularly post Brexit and post pandemic.

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for residential or industrial purpose

Object

Representation ID: 17247

Received: 08/10/2021

Respondent: Nikki Roadley

I wish to object in the strongest possible terms to ANY building on green belt in the Dudley Borough area.
In the Council Scrutiny meeting on 6.10.21 your officer [Redacted- sensitive information] admitted that NO bio diversity checks have been made or wildlife impact assessment.
Our roads are already gridlocked, schools over subscribed, GP's over subscribed, huge waiting lists at hospitals.
People need green spaces for mental health and physical fitness. The impact on the environment and climate by building over remaining green land has been underestimated. An audit of preserved or valuable trees has not been carried out.
The quality of life for existing residents will be greatly diminished, with more traffic, parking issues, nowhere to walk dogs or just take a walk in a green environment.
The plan mentions re-wilding - but where will that be as all available space is gradually eroded and built on. Why not just leave the existing habitat alone.
I do not believe that 'exceptional circumstances' apply in any of the areas listed. I do not believe that all brownfield sites have been identified. I do not believe that all empty Council houses that could be refurbished have been. It is clear that if there is a shortage of land that there should be a preference or flats or maisonettes thereby creating more housing from the same brownfield plot.
A question was also raised in the Scrutiny meeting regarding the data upon which the housing requirement has been calculated. Dudley Council should ask for this to be reviewed particularly post Brexit and post pandemic.

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for residential or industrial purpose

Object

Representation ID: 17267

Received: 11/10/2021

Respondent: Nicola Ceney

I wish to object in the strongest possible terms to ANY building on green belt in the Dudley Borough area.
In the Council Scrutiny meeting on 6.10.21 your officer [Redacted-sensitive information]admitted that NO bio diversity checks have been made or wildlife impact assessment.
Our roads are already gridlocked, schools over subscribed, GP's over subscribed, huge waiting lists at hospitals.
People need green spaces for mental health and physical fitness. The impact on the environment and climate by building over remaining green land has been underestimated. An audit of preserved or valuable trees has not been carried out.
The quality of life for existing residents will be greatly diminished, with more traffic, parking issues, nowhere to walk dogs or just take a walk in a green environment.
The plan mentions re-wilding - but where will that be as all available space is gradually eroded and built on. Why not just leave the existing habitat alone.
I do not believe that 'exceptional circumstances' apply in any of the areas listed. I do not believe that all brownfield sites have been identified. I do not believe that all empty Council houses that could be refurbished have been. It is clear that if there is a shortage of land that there should be a preference or flats or maisonettes thereby creating more housing from the same brownfield plot.
A question was also raised in the Scrutiny meeting regarding the data upon which the housing requirement has been calculated. Dudley Council should ask for this to be reviewed particularly post Brexit and post pandemic.

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for residential or industrial purpose

Object

Representation ID: 17282

Received: 01/10/2021

Respondent: Mrs Susan Toller

I know in the document you say that there are not enough brown field sites for all of the necessay housing but I so strongly disagree with using Greenbelt Land for any reason. We need to protect our green spaces not build on them, once we start doing that there will eventually be no Greenbelt land left.
In this age of Global warming we need as many plants & trees and possible and what about the wildlife that inhabits these green spaces you are trying take away from them, local authorities make my blood boil with their willy nilly use of green spaces just because they can they aways assume they should, well they shouldn't.
Instead of building single dwellings why not build maisonettes at least then you are housing two families instead of one.
I am aware that you will do what you want in the end (as always) but I needed to raise my objections.

Object

Representation ID: 17352

Received: 09/10/2021

Respondent: Dr. Bin Zhao

The green belt is important part of our life. It has been reduced over the years dramatically. It is not sustainable to keep on invading green belt.

Comment

Representation ID: 17453

Received: 11/10/2021

Respondent: Solihull MBC

Black Country Plan R18 - Response by Solihull MBC

I would be grateful if you would treat the contents of this email as Solihull MBC’s comments on the
consultation.
Solihull MBC welcomes the opportunity to comment on this important next stage in bringing forward
a new plan for the Black Country.
This response will focus on the strategic matters relating to land supply for housing and employment
uses. The Council wishes to repeat its position of seeking collaborative working alongside the BCA,
and other authorities in the HMA, to seek to address solutions to accommodate the unmet needs of
Birmingham and the Black Country.
Solihull Council recognises the difficult decisions that have to be made when considering potential
Green Belt land release. You will be aware that through our current Local Plan Review (currently at
examination stage) that SMBC have sought to take a brownfield land/urban location first approach,
but that it’s been supported be the need to make significant releases of land from the Green Belt
(amounting to some 574ha to fully accommodate its own development needs, and in order to make a
meaningful contribution to the HMA shortfall. This includes land for both housing and employment
delivery as well as supporting the regional gateway to HS2. It also includes positive planning for
substantial mineral extraction within the Boroughs Green Belt to support regional requirements.
It is in this context that Solihull Council does not believe that the Black Country Plan has made enough
of a contribution towards meeting its own needs before asking neighbouring authorities for
assistance. In particular:
Failing to take account of the PPG which at paragraph 035 Reference ID: 2a-035-20201216
(Where should the cities and urban centres uplift be met?) advises: “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.”
Question marks remain regarding the maximisation of brownfield land opportunities as
indicated by the mayor and to be tested through an independent study commissioned as such.
Failing to maximise the opportunities presented in the Green Belt in the Black Country to a
sufficient extent before asking neighbouring authorities to sacrifice their own Green Belt.
In relation to the latter point, the commentary at paragraph 3.49 of the plan is particularly noteworthy
as the importance of the Green Belt to Solihull is held in a similar high regard, added to which is the
strategic function that the Green Belt in the Meriden Gap makes in Solihull by separating the
Birmingham & wider conurbation from Coventry. We accept that such a view will undoubtedly be held
in all areas where Green Belt is present and as such do not want to get drawn into a ‘green belt beauty
contest’. Our point is simply that national guidance requires local needs to be met where they arise (in
order to promote sustainable development) and as such local opportunities within a respective area
should be maximised before they are sought to be met elsewhere.
I would be grateful if the above points can be taken into account.

Support

Representation ID: 17524

Received: 11/10/2021

Respondent: Sport England

As above, Sport England would encourage the Authorities to add a reference to uses for sport and recreation within part 1e) of the policy as this would be consistent with the definition of Main town centre uses within the NPPF. Part 1g) of the policy should add a reference to sport and recreation as the green belt is an important location for sports pitches across the Black Country area.

Object

Representation ID: 17532

Received: 11/10/2021

Respondent: Miss Suzanne Dimmock

Crestwood Park / Lapwood is [redacted]under threat [redacted]but I object to ALL the proposed sites in Wallheath / Kingswinford/ Pensnett.
There are empty council properties and units all around Pensnett / Brierley Hill.
As a keen walker, I use all the green spaces in my local area. Bryce Road, Severn Drive, Summerhill, Holbeache, Standhills, Guys Lane, as well as Lapwood / Crestwood as mentioned above.
I understand the need for housing but to lose precious nature when there are plenty of brownfield sites available is disgusting. Our roads are unable to cope with the extra housing developments of the last few years. Public transport is not up to standard, hardly any cycle routes, schools are already over subscribed & NHS services are overwhelmed.

Object

Representation ID: 17615

Received: 11/10/2021

Respondent: Member of Parliament

I am writing to oppose proposed development on several sites in my parliamentary constituency of Stourbridge, covering two main areas:

- Land adjacent to Worcester Lane, Pedmore (Ref: DUH206, DUH207 and DUH209)
- Former grazing land at Wollaston Farm (Ref: DUH217)
I object to these proposals on four main grounds: -

1. Brownfield First
The Prime Minister has recently said that we should be "building beautiful homes on brownfield land in places that make sense". I agree completely with his statement.
I believe that the region should also adopt a brownfield first policy so these unnecessary proposals can be stopped.
I have always believed very strongly in building on brownfield sites before any green belt site can be considered. It is my belief that there is more work to be done to identify brownfield sites in the Dudley Borough. In this way, the homes earmarked for the sites could be built elsewhere, preserving precious green belt for residents.
Not only does this preserve existing green belt sites, but it also regenerates and invigorates areas that have often been left to decay or have at the very least been grossly underused. In my view, extra resources deployed to identifying and analysing brownfield sites would considerably outweigh the damage that could be done to green belt land. Evidence has also shown that building on these sites is often quicker than building on green belt sites.
The West Midlands Combined Authority (WMCA) has also secured £33m from the Brownfield Housing Fund (BHF), which allocates cash to bring old industrial sites back into use. Whilst I note this will not reduce housing targets in the Black Country Plan, it is a welcome move to expedite the use of brownfield sites that require remediation over releasing land from the Green Belt.

2. Preventing Urban Sprawl and Building Back Beautiful
We need housing targets reduced in the region to stem the flood of high-density development, which is creating immense pressure in commuter areas and our infrastructure and creating urban sprawl.
In 2017, Birmingham City Council adopted its Development Plan which paved the way for a monolithic urban extension of 6,000 homes on green belt land, mainly in Sutton Coldfield. The plan failed to consider thousands of negative responses during the consultation. It is expected that only around 2,000 – perhaps fewer – will be delivered by the Plan's end date of 2031. Residents have been left with a plan that fails to address the real housing need of local people.
There is a real risk the same could happen should the Black Country Plan be approved in its current state. An increasing body of evidence supports the fact that increasing densification and fragmentation of green spaces, propagated by 'filling in the gaps' around urban development, feeds a plethora of negative outcomes. These include increased traffic congestion (with the resultant pollution), greater energy use and the destruction of wildlife habitats.
These points are particularly relevant to site ref DUH217 (though sites DUH206, 207 and 209 also suffer) at Wollaston Farm – a slither of green space amongst hundreds of other homes. As well as the negative consequences mentioned above, development here would further degrade the distinctiveness and character of the area. A hard to measure metric, but certainly one that is mentioned time and again by residents.
For many years, urbanism has been turbo-charged with a mandate for place-making on the edge of our cities. We must let the environment be the turbo-charge for future place-making and build homes for the future that are truly environmentally led and that reflect both the surrounding community and the land that is used.

3. The value of Green Belt land
Green belt land is precious and once lost can almost never be reclaimed.
National Planning Policy Framework (NPPF) Section 13: Protecting Green Belt Land – Paragraphs 137-151. The policy makes it very clear that “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
That Green Belt boundaries should only be altered where exceptional circumstances exist. It is not clear what the exceptional circumstances are thought to be for the inclusion of DUH206, 207,209 and 217 in the plan.
Each piece of green belt land lost to development degrades the environment and weakens the long-term health of our communities.
As well as being a rich habitat for many different species, we cannot undervalue the benefits to our mental health that green spaces provide. Throughout the pandemic, people have been telling me how useful walking in the fields and in nature have been to their mental health. If ever there is a time to protect local green space, it is now. Living near a piece of land on which you can walk freely in the fresh air is a necessity in a major residential area. Each site I have mentioned in this response falls within this category. In a Borough which has been historically highly industrialised, local people defend their green spaces vigorously for these reasons.
Whilst both the Wollaston site and the Pedmore sites share these benefits, each has its own unique risks. The Wollaston site, Ref DUH217, as I have mentioned, is a green oasis in an otherwise built-up area. To build here would be to remove access to rare green space in a heavily residential area. In Pedmore, the sites Ref DUH206, 207 and 209 enhance the character of the area. People value the green space dividing Hagley and Pedmore, and many move to the area for its benefits. Similarly, visitors to the area are attracted from nearby Birmingham and Wolverhampton to enjoy the more rural surroundings.
Importantly if the land is released, it would mean houses in the wrong place –denying people the chance of home ownership, leaving many in a long term rental trap. It leaves people without aspirational living. It would leave a region bordering on urban sprawl.

4. Infrastructure
Services are under pressure in and around Stourbridge, so much so that any increase in population could push at-risk infrastructure past a tipping point. Schools, GP surgeries, dentistry, social care, parking, and emergency services are all under pressure. Without sufficient provision to support an increased population, any housing development – whether on green belt or not – should be seriously questioned.
In addition, traffic is a major and worsening issue in Stourbridge. Congestion throughout the area causes disruption and environmental damage. Some roads in Stourbridge are amongst the worst for air pollution in the Borough. There is no doubt that further significant development, resulting in hundreds more cars on local roads, will worsen the local situation. More specifically, considering sites DUH206, 207 and 209, Worcester Lane – a busy, single track road - would struggle to support any further service roads to residential developments. The same could be said for Kingsway in Wollaston, which is also very close to a local school.

Object

Representation ID: 18120

Received: 11/10/2021

Respondent: Mr Tony North

All my comments relate to land within DMBC.
Overall objection to the use of Green Belt for housing, unless it is absolutely unavoidable. I understand there is a need for more housing and praise the efforts made to utilise brownfield first. However, the plan runs to 2039, any attempts to sacrifice green belt are premature. There is no account taken of the probable arising of more brownfield land in the period up to 2039, which might satisfy the housing shortfall.

Comment

Representation ID: 18130

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.14 to 3.17 - CSP3 should be given equal status with CSP2. It may not be practical to achieve strong and seamless links to regenerated areas in the Core Regeneration Areas and Strategic Centres. Sustainable advantages of new Neighbourhood Growth Areas and the ability of green belt release to provide choice in the housing market.

Object

Representation ID: 18183

Received: 11/10/2021

Respondent: Mr Frederick Perry

[redacted] it is devastating to envisage that our lovely rural enviroment we have enjoyed for over 50 years maybe destroyed forever by the current proposal that GREEN BELT land opposite us should be used for residential homes.
[redacted details of location of property]
Requests for improvements and priorities had been made over the years and refused on the grounds that street lights would be detrimental to the current rural status that Worcester Lane is known for and therefore would be a negative effect on the current rural enviroment !!

How can building numerous new homes benefit the area and curent residents ? The proposed area have always been a place for people to appreciate the beauty and tranquility of the area.
Although the infrastructure can be changed to accomodate housing, the enviroment will changed forever and for the worse!! this will reflect on the exisiting properties and amenities that are already curently over stretched to capactity.
We strongly object to any proposal on the suggested GREEN BELT areas.
THIS IS NOT PROGRESS TISIS DISTRUCTION !!!

Comment

Representation ID: 18219

Received: 11/10/2021

Respondent: Mr Trev White

2. That the brown field areas must be utilised first. The CPRE (The countryside charity) says "Our research, released in the 2020 edition of our annual ‘Recycling our land: the state of brownfield’ report, has found that there’s
already enough brownfield land available to meet the government’s own targets."
3. Upgrading or replacing existing buildings must also be prioritised
4. Green Belt land;
a. Should not be used
b. Once used for other purposes it has gone forever and cannot be replaced. Future generations will have lost a valuable resource
c. Wild life and its habitat is lost.
d. Green Belt land is extremely valuable for food production, flood prevention, climate change mitigation and much more.
e. The social impact of destroying Green Belt areas cannot be over emphasised.
f. Green Belts were also designed to prevent urban sprawl.
5. Houses and work places built on declassified Green Belt land does not preclude families living there from working elsewhere. ie London workers commuting from homes in Oxfordshire and beyond.

Comment

Representation ID: 18383

Received: 07/10/2021

Respondent: Richard Williams

With less than three days to go before consultation regarding the Black Country Plan closes, how do I make comment on a plan that has been developed for over four years by a team who have access to both private and public research, investigations and ideas? A chance word last Monday made me aware that there was a plan and after an e-mail exchange with the local authority to find it, I discover that the deadline for comments is next week.
It would appear that the need for the councils to build 75000 extra houses across the whole area is the principal issue together with the supporting infrastructure of employment, education, transport, medical facilities, shops etc.. On the face of it I applaud the use of ‘brown field’ sites but I am concerned about the ‘green belt’ areas that have been identified. These seem to be small and scattered across the area. Assuming that this whole exercise for each council to build affordable housing, will the housing stock be in keeping with the area? In Worcester Lane (Stourbridge) houses already exist worth in the excess of £500,000 so is the council proposing to build their houses in the same style as the rest of the area. Will there be sufficient schooling available for these new families – local schools are currently struggling to find space for existing children so a new school would have to be built. Would any new schools built on this ‘green belt’ land, cause existing small schools to close (thus providing new brown field sites) The whole idea of using small areas of ‘green belt’ land to top up the local authority housing stock needs to be carefully thought through in terms of costs. Will the council houses be built in keeping with the existing local stock – how much additional cost will be required for educational needs – will the current medical services need to be improved.
No doubt all these issues will have been considered over discussions in the last four or five years but if this is a plan for 2039 how many changes are there likely to be before then?
‘Brown field’ sites should be the first to be developed even if they are more costly. Using land which is doing nothing and le to go derelict, will always be preferable to using our precious ‘green belt’. This could also be used to meet the various Council objectives of cleaning up the environment. It is likely that once the ‘brown field’ sites have been used, new sites will be required and ‘green bel’ has to be used but these areas must be dealt with sympathetically and new builds must be developed in the style of the existing area.
These are just general thoughts as I have not had me to digest the plan or even Dudley’s part in it. I get notified of the lay persons who want to be elected on to the West Midlands Police Authority but with something much more fundamental to my area, i.e. a Plan for the Black Country, I have received no notification or information.

Object

Representation ID: 18515

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1bi and 1d
Object: The statement ‘A network of new Neighbourhood Growth Areas providing 6,792 homes, in highly sustainable locations on the edge of the Urban Area’ underplays the impact on the Black Country landscape of these allocations. The term Neighbourhood Growth Areas refers to for 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: 18516

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1e
Comment: WTBBC support the aim of delivering an integrated and continuous (where possible) network of green infrastructure, walking and cycling routes. The importance of this should be emphasised through it being in a separate point to a network of centres, health, leisure and community facilities.
1g
Comment: WTBBC support a defensible green belt to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents. WTBBC do not support the use of ‘where possible’ in reference to the landscape being safeguarded and enhanced for its heritage, recreation, agricultural and nature conservation value. 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 is valued for the benefits it provides the Black Country.

Object

Representation ID: 19245

Received: 11/10/2021

Respondent: Mr Ronald Wilson

My objections are as follows:
1. Building houses on Greenfield Sites
2. Increased Traffic Congestion
3. Danger to Habitat
4. Increased Pressure on Local Services
5. Increased Pollution
6. Hospitals, Schools, Doctors Surgeries Would be Unable to Cope with the Increased Growth of the Population

Object

Representation ID: 20977

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt
For the reasons stated in our comments to CSP1, we would question whether the area outside of the Strategic Centres and Regeneration Corridors is capable of delivering 27,068 dwellings.
We welcome the identification of Neighbourhood Growth Areas (NGA) and the acknowledgement that Green Belt land needs to be released if the development needs identified are to be met. However, we do not consider that identifying NGA’s with a capacity of 6,792 dwellings goes anywhere near far enough. There is plenty more scope to deliver more sites within the Black Country area and reduce the need for adjoining authorities to release Green Belt land. Exporting the development needs to adjoining authorities is not going to change the requirement to release Green Belt land or remove the need for difficult decisions to release sites which are seen as more sensitive than those already identified. Instead, it just passes that decision to someone else. This will not remove the need to export development to adjoining authorities, but every attempt should be made to minimise this as far as possible, particularly when your largest neighbour is only currently proposing to test 4000 dwellings, which is just 17% of the housing overspill.
Clear evidence will be needed to demonstrate why in exporting such a large amount of development that this would facilitate these needs being delivered on less sensitive and ultimately more sustainable sites than could otherwise be delivered in the Black Country.

Support

Representation ID: 21241

Received: 11/10/2021

Respondent: Newlands Developments

Green Belt
The Black Country Authorities have undertaken Local Sites Assessment Reports for the proposed allocations, including Land south of Bentley Lane, Walsall (Site Reference SA-0057-WAL). A copy of the Site Assessment Form completed for the Site is included at Appendix 2.

The Site Assessment Form includes a Green Belt assessment of the Site, owing to its location within the Black Country Green Belt. The Assessment identifies that the Site comprises a narrow gap between towns and has urban edges on two sides and urbanising influences to the west. It concludes that the release of this area from the Green Belt would only weaken the contribution of land to the west of the Site, which would not increase overall harm. Furthermore, the Site Assessment Form goes on to state:
“The Site is considered more suitable for employment uses rather than residential uses and is also one of only a few sites identified by the EDNA (the Black Country Economic Development Needs Assessment) as being suitable for employment.”

Paragraph 140 of the NPPF confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.

The Black Country Authorities consider that, through the preparation of the Black Country Plan, exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. An Economic Development Needs Assessment (EDNA), which provides an objective assessment of the industrial land needs for the Black Country against the area’s economic development needs, was prepared for the Black Country during 2016/17. This Assessment identified that there was a potential shortfall in employment land over the Plan period of between 283 hectares (against baseline growth scenario requirements) and 563 hectares (against most likely growth scenario requirements). A Black Country EDNA update (EDNA2, 2021) has been produced by WECD Consultants to update employment land demand estimates presented in the 2017 EDNA1, to inform the objective assessment of employment land needs for the Black Country to 2039. The EDNA2 (2021) notes that there have been some significant changes in the use of employment space since the publication of EDNA1, particularly in the last 18 months. Whilst manufacturing remains an important sector for the Black Country Economy, the COVID-19 pandemic has fuelled e-commerce, resulting in increased demand for logistics space requirements, including last mile facilities in close proximity to large urban populations. Accordingly, there is now projected to be an undersupply of employment land of between 148 hectares and 168 hectares.

The EDNA2 (2021) has estimated that the potential loss of employment land over the Plan period would be 62.7 hectares based on the detailed review of employment sites (including losses to residential uses and other alternative forms of development for employment spaces in the Black Country). Allowance for this loss will need to be considered for the future provision of employment space in the Black Country, bringing the level of employment land requirement in the Black Country to 30-31ha per annum over the next planning period (equivalent to between 212 and 232ha). This represents 37% of employment land need arising in the Black Country that cannot be met solely within the Black Country.

The Black Country Urban Capacity Review Update (May 2021) also concludes that, at this stage, a significant shortage of employment land will remain. This is after consideration of the potential for additional sources of employment land to meet the shortfall, such as current non-employment allocations which have not yet been developed for the alternative use, intensification of existing sites, any vacant land, and contributions from outside of the Black Country (for example, within South Staffordshire and Shropshire). It concluded that these potential sources will not fully accommodate the need for employment land and the gap in supply will remain significant in scale. Consequently, Paragraph 4.7 of the Urban Capacity Review concludes that “the exceptional circumstances necessary to trigger a Green Belt review in the Black Country, in order to meet housing and employment land needs, have been met”.

However, before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, as noted in NPPF Paragraph 141. This will be assessed in terms of whether the strategy:

a. Makes as much use as possible of suitable brownfield sites and underutilised land;
b. Optimises the density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c. Has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.

With regard to making as much use as possible of suitable brownfield sites and underutilised land, the Urban Capacity Review Update (2021) identifies that the only additional sources of employment land supply within the Black Country urban area, which are not identified in the EDNA, are:
• • ‘Land within the urban area that is currently allocated for development for non-employment uses – in the main housing- but not yet developed for that use. This land is currently either occupied by employment uses and has scope for intensification, or vacant land that could be used for new employment uses in the future.
• • Additional employment land within existing employment areas – either through the intensification of existing under-occupied employment sites or land that is either currently vacant or may become vacant over the Plan period.’

The Urban Capacity Review identifies that 488 hectares of occupied employment land was allocated for housing within Black Country Authority Area Action Plans and Site Allocations Documents. This land was allocated on the basis of it being assessed to be of low quality in terms of its sustainability for employment uses in the long term and the future investment intentions of the businesses who occupied it.

As part of the evidence base work for the Black Country Plan, a Black Country Employment Area Review (BEAR) has been prepared, which has been informed by a landowner engagement exercise (as noted in the Landowner Engagement Exercise Technical Report (August 2021)). The BEAR seeks to identify the current intentions for existing employment sites and business needs to inform the Black County Plan approach on the protection and retention of employment land. The report reviews the extent to which existing housing allocations involving the redevelopment of employment land should be deleted, with those sites retained for employment activity.

The BEAR has concluded that many of the occupied employment sites currently allocated for housing contain businesses which have either invested in their premises and/or intend to remain in situ in the long term, and specifically throughout the new Plan period. In addition, the BEAR notes that the re-allocation of employment sites to housing would impact negatively on the ability of the Black Country to provide sufficient employment land to meet its identified needs, as any employment land lost to alternative uses would need to be replaced elsewhere and added to the land requirement. Therefore, the BEAR strongly suggests that these sites should be retained for employment uses and current housing allocations deleted through the Black Country Plan review. The EDNA2 (2021) also identifies a requirement for a net increase in employment land over the new Black Country Plan period, which is likely to require the retention of more existing employment land than previously anticipated.

In terms of optimising the intensification of existing sites and maximising the development of under-utilised buildings, the Urban Capacity Review recognises that there are likely to be some additional opportunities for intensification and redevelopment within existing employment areas that were not identified in the EDNA. However, it is anticipated that any new allocated sites are likely to be limited and small in scale, potentially contributing up to 50 hectares of additional employment land. Further recycled land may also come forward as ‘windfalls’ over the Plan period. It must also be acknowledged that increasing site densities, as part of intensification, can make sites less attractive to the market in certain sectors, for example, due to inadequate yard space/depths that precludes operational efficiency.
With regard to discussions with neighbouring authorities, further contributions are being explored through the Duty to Cooperate with neighbouring local authorities who share a physical and/or functional relationship with the Black Country. The EDNA2 (2021) estimates a potential contribution of 19 hectares of employment land to be made through Duty to Cooperate arrangements with South Staffordshire. The Shropshire Regulation 19 Local Plan also includes a contribution of 30 hectares of employment land towards meeting needs arising in the Black Country. In addition, there is an estimated contribution from the proposed West Midlands Interchange at Four Ashes of between 72 and 94 hectares. This would equate to a total of 121 hectares of contribution from outside the Black Country, which would mean that the undersupply of employment land requirements to meet market, growth and replacement demand in the Black Country would reduce to between 91 and 111 hectares.

Based on the above, it is considered that the Council have fully examined all other reasonable options for meeting the identified need for development outside of the Green Belt in line with Paragraph 141 of the NPPF. Despite this, there remains a significant undersupply of employment land in the area. Therefore, we consider that the Black Country Authorities have demonstrated that exceptional circumstances exist to remove certain areas of land from the Black Country Green Belt to meet employment land needs, including, land to the south of Bentley Lane in Walsall. However, it should be noted that local authorities should not shy away from higher employment land and housing numbers just because Green Belt release will be needed to achieve these numbers. Broader spatial objectives can and should be taken into account to justify higher employment land and housing figures, as demonstrated in the High Court ruling on the three statutory challenges to the adoption of the Guildford Local Plan (in Compton Parish Council & Ors v Guildford Borough Council & Anor [2019] EWHC 3242 (Admin)):

‘"Exceptional circumstances" is a less demanding test than the development control test for permitting inappropriate development in the Green Belt, which requires "very special circumstances." That difference is clear enough from the language itself and the different contexts in which they appear, but if authority were necessary, it can be found in R(Luton BC) v Central Bedfordshire Council [2015] EWCA Civ 537 at [56], Sales LJ. As Patterson J pointed out in IM Properties Development Ltd v Lichfield DC [2014] EWHC 2240 at [90-91 and 95-96], there is no requirement that Green Belt land be released as a last resort, nor was it necessary to show that assumptions upon which the Green Belt boundary had been drawn, had been falsified by subsequent events.’ [70]

This High Court judgment provides clarity on the circumstances under which the exceptional circumstances test can be met. It goes on to state:

“Likewise, at IR80, the Inspector found that land available for additional business development in the Guildford urban area was very limited, and it was unrealistic that much extra capacity could be obtained on existing sites such as the existing Surrey Research Park:

"The ability to meet the identified business needs therefore depends on making suitable new land available and there is no realistic alternative to releasing land from the Green Belt. Exceptional circumstances therefore arise at the strategic level to alter Green Belt boundaries to accommodate business and employment needs.”

We believe the same principles apply here and ‘exceptional circumstances’ are clearly demonstrated in light of the significant shortfall in employment land required.

Comment

Representation ID: 21258

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt
A network of new Neighbourhood Growth Areas are proposed to provide 6,792 dwellings in highly sustainable locations on the edge of the Urban Area. We support the allocation of Redrow Homes’ site as part of strategic allocation WSA2.

Paragraph 3.48 states that it is important that “neighbourhood Growth Areas are master-planned together, regardless of ownership” and phasing plans will be required to set out triggers for the provision of required infrastructure. In order for strategic sites to accord with this requirement, the Council must ensure that all land allocated is available before being included within the allocation boundary and any joint masterplans prepared should only be expected to be high level concept plans to allow for flexibility.

Support

Representation ID: 21288

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt
This draft Policy sets out the strategic approach for the Towns and Neighbourhood Areas and the Green Belt. We are supportive of the Policy, which states that 27,068 new homes will be provided, including a supply of small-scale residential development opportunities 1)(b)i. This is considered to be consistent with paragraph 69 of the NPPF, which supports the allocation of small and medium sized sites due to the important contribution they can make to meeting housing requirements and as they are often built out relatively quickly.

Object

Representation ID: 21334

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY CSP3 – TOWNS AND NEIGHBOURHOOD AREAS AND THE GREEN BELT: OBJECT
WDH’s response to Policy CSP1 sets out their concerns in relation to the BCP’s overall development strategy, and as such those comments are referred to in response to Policy CSP3. Those comments set out that, given the scale of the BCAs’ own housing needs and the housing context in the wider HMA, the BCP should seek to meet a higher proportion of the BCAs’ housing needs before exporting its unmet need to neighbouring authorities. That response to Policy CSP1 highlights that this approach to maximising development within the jurisdiction of the BCAs is entirely justified, and that the SA should be revisited to ascertain the maximum level of housing that could be accommodated before significant adverse impacts arise.

In that context, WDH recognise the important role that Towns and Neighbourhood Areas and the Green Belt adjacent to such settlements can play in meeting the BCAs’ considerable housing needs. Indeed, the supporting text for the policy outlines that these areas relate to the built-up area “where most of its residents live” and that “a key spatial priority of the Plan is to support the delivery of a constant supply of new housing development”, a significant amount of which will be accommodated in these locations.

That is an entirely appropriate and justified approach in principle, and WDH are of the view that the BCP should maximise growth in those areas where there are suitable sites in sustainable locations so as to meet the BCAs’ housing needs more fully. That approach would ensure that housing needs would be met close to where they arise, which would be testament to positive planning and would be an inherently sustainable approach to development.

As set out in WDH’s response to Policy CSP1, it is important that the BCAs develop a clear spatial to guide that identification of further development sites. Doing so would ensure that the BCP allocates those sites that are located in the most sustainable locations so as to limit the adverse impacts of that additional development, and would also provide further clarity to direct future growth should sites fail to deliver or the BCAs’ housing needs increase further.

The merits of Pedmore as an inherently sustainable location for growth are set out in WDH’s response to Policy CSP2 given its location adjacent to the main built form of Stourbridge, the range of services and facilities available both within Pedmore and nearby settlements, and the excellent connectivity that the settlement shares with surrounding settlements and higher-order settlements. The clear suitability of Pedmore as a location for growth should be reflected in the spatial strategy that must be developed to sit within Policy CSP1. The merits of Bromwich Lane, Pedmore are outlined in WDH’s response to Policies CSP1 and HOU1.

WDH also recognises the policy objectives of Policy CSP3, and notes the key role that the development of Bromwich Lane, Pedmore could play in realising those. Notably, the site’s development would deliver green corridors and key open spaces that would contribute towards an integrated and continuous green infrastructure network, and would also benefit from strong links to nearby Core Regeneration Areas and Strategic Centres to ensure the site’s integration with the existing built form. Upon the delivery of a sensitive development scheme with appropriate mitigation, the site would also ‘round-off’ the existing urban form and provide a defensible Green Belt that creates a clear threshold between the redefined settlement edge and the Countryside to the south and west, which would provide easy access to the countryside for residents whilst also safeguarding and enhancing its heritage, recreational, agricultural and conservation values. The development of Bromwich Lane, Pedmore would therefore be testament to sustainable development, as demonstrated in WDH’s response to Policy HOU1.

Object

Representation ID: 21455

Received: 11/10/2021

Respondent: Cllr Lorna Rattigan

I am concerned that not enough Brown field sites are being looked at first for the increasing housing requirements before looking at green space, due to climate changes that we are facing re flooding etc that can be made worse if built on. We need to keep trees and existing wildlife green spaces for health and mental well being.

Comment

Representation ID: 21477

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

2.10. The evidence supporting the emerging Black Country Plan has identified that within the urban area is insufficient capacity to meet the Plan’s housing needs, even when taking into account potential opportunities for redevelopment of brownfield sites and increasing densities for new development. As a result, it has been concluded that there is sufficient justification to release land from the Green Belt through this Plan.

2.11. Whilst the need to release the Green Belt is not disputed given the scale of housing need and shortfall identified, it is a concern that the Authorities have proceeded to do so despite not exhausting all opportunities within the urban area. As a result, in order for the Plan to be justified and consistent with national policy regarding the Green Belt, the authorities need to demonstrate that all other reasonable options to meet its identified needs have been examined fully. This should include consideration of available sites within the urban area, such as the Land at Corbett Hospital, which represents underutilised land in a sustainable location within the urban area.

2.12. Therefore, in order for the Council to proceed with Green Belt release through this Plan and included within Policy CSP3, the Plan must be supported by a robust evidence base that justifies this approach. This should include identifying how all opportunities within the urban area such as the Land at the Corbett Hospital have been assessed, in order to ensure that the Plan accords with the Framework’s tests of soundness.