Delivery Constraints
Object
Draft Black Country Plan
Representation ID: 11433
Received: 02/10/2021
Respondent: Mr Andrew Roberts
The road infrastructure is already overran and cant cope with the volume of traffic in and around the A449. Our house backs on to the A449 and the noise from the vehicular traffic is sometimes unbearable already without adding what could amount to thousands of new vehicles. These sites should not even be considered because the infrastructure is simply not there!
Object
Draft Black Country Plan
Representation ID: 12017
Received: 10/10/2021
Respondent: Miss Emma Thompson
I object to the term brownfield-first being used in the BCP. This suggests all land previously occupied by a permanent structure is low value with regards ecosystem services. In the Black Country many sites of high aesthetic, wildlife or health and wellbeing value are post-industrial or have been previously occupied by a structure. The NPPF is clear in its definition of previously developed land that this excludes sites ‘where the remains of the permanent structure or fixed surface structure have blended into the landscape’. This term is widely understood and should be used in place of brownfield throughout the BCP
Object
Draft Black Country Plan
Representation ID: 18456
Received: 11/10/2021
Respondent: L&Q Estates
Agent: Pegasus Group
Paragraph 4.1 - Brownfield first approach not supported, broader approach recommended. Considered to undermine the "key part of the BCP which is to maintain a steady supply of housing land"
Comment
Draft Black Country Plan
Representation ID: 18457
Received: 11/10/2021
Respondent: L&Q Estates
Agent: Pegasus Group
Paragraph 4.2 - "In itself mineral extraction can have significant adverse impacts on the amenity of neighbouring
properties. As set out elsewhere in these representations it is important that the BCP pays regard to this factor."
Object
Draft Black Country Plan
Representation ID: 19208
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
4 Infrastructure & Delivery
Delivery Constraints
4.6
Object: WTBBC object to the term brownfield-first being used in the BCP. This suggests all land previously occupied by a permanent structure is low value with regards ecosystem services. In the Black Country many sites of high aesthetic, wildlife or health and wellbeing value are post-industrial or have been previously occupied by a structure. The NPPF is clear in its definition of previously developed land that this excludes sites ‘where the remains of the permanent structure or fixed surface structure have blended into the landscape’. This term is widely understood and should be used in place of brownfield throughout the BCP.
Comment
Draft Black Country Plan
Representation ID: 19211
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
4.8
Comment: Paragraph 4.8 acknowledges that greenfield sites are often quicker and easier to develop than sites in the urban area. It is WTBBC’s view that in response to this reality sites should be released in phases of five years over the life of the plan, with appropriate urban sites released first, thereby avoiding releasing greenfield sites that may later be found to be surplus to requirement through changes in housing demand. This approach will prevent developers ‘cherry-picking’ the most profitable greenfield sites at the expense of the green belt and natural environment, whilst ensuring appropriate urban sites are not left undeveloped.
Object
Draft Black Country Plan
Representation ID: 23228
Received: 11/10/2021
Respondent: Member of Parliament
Constituents from across Aldridge-Brownhills would be forgiven for not sharing the sentiments set out in the Black Country Plan where in Paragraph 4.6 it states:
"The BCP adopts a brownfield-first approach to maximise delivery of development within the urban area".
As a community we are on the urban fringe of the West Midlands 'Metro' conurbation and I am still seeking to understand in the Borough of Walsall the extent to which that policy has been put into practice.
Furthermore in the same paragraph the authors of the Plan undermine their opening statement by declaring: "however, poor ground conditions are a legacy of the Black Country's mining and industrial past are a significant constraint, in both physical and financial terms". This assertion must be challenged.