A. Dudley

Support

Representation ID: 22330

Received: 11/10/2021

Respondent: Mr Richard Moore

Consultation on Draft Black Country Plan: Dudley Sub Area Section, Site Allocations Table 14

I support the Conclusions in the Site Assessment Report that protect the greenbelt and green spaces in Dudley borough, and particularly in Cradley & Wollescote and Hayley Green & Cradley South wards by assessing sites there as not suitable for residential or industrial
purpose as follows:-
SA-0034-DUD Land North of Oldnall Road; SA-0159-DUD Land West of Avon Road, Cradley; SA-0245-DUD Land South of Park Road, Cradley; SA-0081-DUD Foxcote Farm, Oldnall Road, Wollescote; SA-0027-DUD Land West of Foxcote Farm, Oldnall Road,
Wollescote, DY9 9AR; SA-0079-DUD Land off Wynall Lane South, Wollescote, DY9 9AJ; SA-0036-DUD Land adjacent to Abbey Road, Halesowen, B63 2HH; SA-0040-DUD Land south of Cradley Town FC, Beeches View Avenue, Halesowen, B63 2HH.

Object

Representation ID: 22331

Received: 11/10/2021

Respondent: Mr Richard Moore

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, and particularly in Cradley & Wollescote and Belle Vale by assessing sites there as suitable for residential or industrial purpose as follows:-
DUH041 Land rear of Two Gates Lane, Cradley; DUH214 Seymour Road, Wollescote; DUH059 New Hawne Colliery (part only). I do not believe it is possible to put in place sufficient mitigation to make up for the loss of any greenbelt or green space to a community.

Support

Representation ID: 22332

Received: 11/10/2021

Respondent: Mr Richard Moore

I support the application by Friends of Homer Hill Park and Cradley Then & Now for designation of Local Green Space for Site ID 10522 The Flint Field, Land North of Oldnall Road, Cradley & Wollescote. The area is a special place for the community and holds particular local significance because of its natural beauty, tranquillity, wild life, archaeology, history and recreational value. Its size and character is different to neighbouring or other
greenbelt land in Cradley or Wollescote. A visit there for recreation is a different experience to visiting anywhere else in the locality, which is demonstrated by organised walks, and the support of the Black Country Society.



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 new residents that they may not have anticipated. I do not support any loss of green space, greenbelt land or greenfield land.

I understand this response and my name will appear on the Black Country Plan website available for public viewing.

Support

Representation ID: 22335

Received: 11/10/2021

Respondent: Mr Robert Freer

Black Country Plan - Support for the Protection of Green Belt Around Halesowen

I support the Council’s continued protection of ountryside at Lapal, Illey, Coombeswood, Uffmoor, Hayley Green, Lutley and Foxcote, following a formal review of the Green Belt.

Object

Representation ID: 22338

Received: 11/10/2021

Respondent: Mr Roger Whittaker

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.


While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF).

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22382

Received: 11/10/2021

Respondent: S Lucas

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.


While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22385

Received: 11/10/2021

Respondent: Mr Sean Clegg

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22395

Received: 11/10/2021

Respondent: Sharon Brown

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields. ature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22417

Received: 11/10/2021

Respondent: Mr Roger Thomas

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). .
The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’. .

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by
visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22435

Received: 11/10/2021

Respondent: Sue Rose

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF).

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22437

Received: 11/10/2021

Respondent: Mrs Susan OHagan

Nature of comment: ‘Objection’

Objection to The Three Fields, Norton, DY8 3LS and Clent View Road,Norton DY8 3JJ not receiving a
Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section
A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and being in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’. It forms part of a wider green corridor and offers walkers access to the wider countryside. It is used by dog walkers, and encourages a ‘sense of community’ amongst the socially isolated. It is very popular with children, for informal recreation, games, and nature study.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of
Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22445

Received: 11/10/2021

Respondent: Mr Tom Packwood

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF).

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.
The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22450

Received: 11/10/2021

Respondent: Mr ernest craddock

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.
The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22470

Received: 11/10/2021

Respondent: Vikki Pearce

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF).

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22476

Received: 11/10/2021

Respondent: Mr Lee Woodall

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF).

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Object

Representation ID: 22479

Received: 11/10/2021

Respondent: Miss Yvonne Hands

Site: ID 10511, The Three Fields, Norton, DY8 3LS

Objection to The Three Fields, Norton, DY8 3LS not receiving a Local Green Space Designation (site ID 10511 as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

This is a comment on an unallocated site.

While I support the non-allocation of the Three Fields, Norton (site reference SA-0076-DUD as it appears in Appendix A:Dudley) in the Draft Local Plan and its continued protection under green belt designation.

Three Fields meets criteria for the designation of Local Green Space. It meets all of Part A criteria, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application.

The site has been assessed as meeting two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’.

The Site Assessment summary for this site quotes the NPPF; “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).

However, Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas. The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Comment

Representation ID: 22486

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site selection in Dudley
We welcome the findings of the Site Assessment Report: August 2021 and consider this to be a
mostly robust piece of work to identify sites for selection. However, we do have some concerns
regarding the lack of weight/regard given to the GBHMA Strategic Growth Study 2018 in the final
site selection process, particularly in broad locations identified by the 2018 study in the Dudley
area (Appendix A of that document).

It currently appears that only 860 dwellings are proposed on Dudley’s Green Belt edge, in two sites
forming the Kingswinford Neighbourhood Growth Area. However, previous correspondence
received from the Black Country authorities in response to South Staffordshire’s 2019 Spatial
Housing Strategy and Infrastructure Delivery (SHSID) consultation indicated that there was
potential for up to 5,000 dwellings to be delivered in Green Belt areas surrounding Dudley2. Whilst
we appreciate this was only a high-level indication of capacity, it also appeared to be broadly
consistent with the more detailed findings of the GBHMA Strategic Growth Study 2018. This
recommended that the western edge of the Black Country (including Dudley) could accommodate
500-2,500 dwellings through dispersed housing development, whilst the southern edge of Dudley
(around Halesowen) had the potential to accommodate a 1,500-7,500 dwelling sustainable urban
extension based around garden village principles. Whilst neither option was without its potential
constraints, these two areas of search were still considered on balance to be more sustainable,
deliverable and less harmful to Green Belt purposes than other strategic development
opportunities elsewhere within the GBHMA.

Given the acuteness of the regional housing shortfalls, it is important that the GBHMA Strategic
Growth Study’s recommendations are fully explored. In light of this, we do not consider that the
Site Assessment Report: August 2021 has given sufficient weight to the findings of the GBHMA
Strategic Growth Study 2018 and do not consider it currently offers a robust basis for establishing
the upper end of Dudley’s potentially suitable Green Belt capacity. Specifically, it currently appears
that large numbers of site options have been discounted on Dudley’s Green Belt edge not because
they are truly undeliverable, but because they are not considered to be sufficiently suitable (e.g.
sufficiently free from policy constraints) and have not arisen from a wider GBHMA-wide evidence
base. This also affects many sites in broad areas recommended for growth by the GBHMA Strategic
Growth Study 2018. Common reasons given in the site assessment conclusions for rejected sites in
Dudley’s Green Belt include:

• Levels of sensitivity/harm identified in the 2019 Green Belt Study and Landscape Sensitivity
Assessments
• Additional local designations or officer judgements which duplicate factors already
considered through the cross-boundary 2019 Green Belt/landscape sensitivity evidence
• Comments regarding proximity to heritage assets which do not indicate whether heritage
impacts could be mitigated or are likely to be significant, which do not appear to reflect an
accepted Historic England methodology for understanding of the significance of a heritage
asset3
• Constraints that are likely to be capable of mitigation/compensation through site layout
(e.g. minor areas of Sites of Local Importance for Nature Conservation (SLINC)/Sites of
Importance for Nature Conservation (SINC) coverage within a site, slight overlap with Flood
Zones on a site’s boundary corner)

A list of the sites within Dudley’s Green Belt that appear to be capable of delivery but have been
discounted largely on the basis of the reasons given above are included in Appendix 1 of this
response. [see attachment]


We also note that many of the sites listed in Appendix 1 fall within areas of Very High harm Green
Belt and Moderate-High landscape sensitivity4, which the Black Country have previously indicated
would be considered a significant constraint on site options5. We agree with the general principle
of considering sites options’ relative suitability based upon local Green Belt/landscape evidence
and do not have any concerns with the threshold proposed. However, we do not believe it is
appropriate to use such a threshold to discount strategic recommendations of the GBHMA
Strategic Growth Study 2018, given the scale of the shortfall and knock-on impacts this will have
on shortfalls elsewhere in the GBHMA. Green Belt purposes, landscape character impacts,
sustainability and deliverability of such locations have already been considered at a GBHMA-wide
level through the GBHMA Strategic Growth Study 2018. Therefore, in lieu of better HMA-wide
evidence, it is imperative that the recommendations of the 2018 study are fully explored and
delivered as far as possible.

If the Black Country are of the view that the GBHMA Strategic Growth Study recommendations
cannot be accommodated in the specific areas of search proposed in that study (e.g. South of
Halesowen) then it is imperative that other site options around Dudley’s edge are explored fully to
offset the loss of housing delivery this implies. This is particularly important as Dudley’s
administrative area holds significantly more areas of potential Green Belt than other Black Country
authorities (aside from Walsall). To do otherwise risks shifting these pressures into less sustainable
locations within the GBHMA which are more remote from the source of unmet need (the Black
Country). We do not believe it would be sustainable or desirable for all Green Belt land in Dudley to be allocated without regard to suitability factors. However, the Site Assessment Report: August
2021 clearly shows there is a wide choice of land (as indicated in Appendix 1 of this response)
capable of accommodating a higher Green Belt housing supply figure in this area, consistent with
the figures given in the previous 2019 correspondence from the Association of Black Country
Authorities and the scale of locations identified for growth in the GBHMA Strategic Growth Study
2018. We would welcome further discussions with the Black Country authorities to ensure a
consistent cross-boundary approach to this issue.


2 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf
bases (e.g. Areas of High Historic Landscape Value, judgements regarding settlement
patterns, defensible boundaries and settlement gaps etc.)
3 See Historic England guidance available here: https://historicengland.org.uk/images-
books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-
local-plans/)
4 As set out in 2019 Black Country Green Belt Study and Landscape Sensitivity Assessment
5 See correspondence from the Association of Black Country Authorities available here:
https://www.sstaffs.gov.uk/planning-files/Spatial-housing-strategy-statutory-bodies-and-
stakeholders/ABCA%20SHSID%20(1)%20Final%20Letter.pdf

Comment

Representation ID: 22488

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Appendix 1 - Dudley Green Belt site options discounted but potentially capable of delivery [table] [see attachment]

[Taken table headings, presented here as headings:]
Ward/Site Reference/Site area

/Comments on site assessment [appears below these]:

Pedmore and Stourbridge East SA -0031 -DUD 19.8

Appears reliant on Green Belt/landscape factors in part for discounting. Heritage impacts cited as part of reason for unsuitability but no indication of 'substantial
harm'. Appears to have site frontage directly onto main road (Pedmore Lane); unclear why access is a constraint.

Kingswinford North and Wall Heath SA -0114 -DUD 27.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
Unclear why access could not be achieved through adjacent parcel (SA-0017-DUD)

Kingswinford North and Wall Heath SA -0033 -DUD 1.7

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting proximity to listed building is prohibitive.
SLINC appears to be the only constraint preventing delivery of a site in otherwise less harmful Green Belt/landsacpe area.

Cradley and Wollescote SA -0034 -DUD 13.8 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only partially covers the site and the remainder could be feasibly considered

Cradley and Wollescote SA -0081 -DUD 64.2 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' suggesting archaeology is prohibitive.

Pedmore and Stourbridge East SA -0250 -DUD 20 Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' to SAM indicating proximity is prohibitive.

Halesowen South SA-0088-DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. No indication of 'substantial harm' due to heritage effects; only a 'potential' to impact upon
setting.

Halesowen South SA-0087-DUD-B 30

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC/Ancient Woodland only cover small part of site and could be designed around.
Access concerns may be addressed through delivery alongside adjacent parcels (e.g SA-0242-DUD)

Halesowen South SA-0015-DUD 14.7

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why access onto Lapal Lane has been treated as a constraint as site appears to have
access onto other roads which could provide a satisfactory access

Halesowen South SA-0242-DUD 150

Appears reliant on Green Belt/landscape factors in part for discounting. Scale of potential development could deliver singificant scope for highways/access solution
and on-site facilities. SINC/SLINC/Ancient Woodland/Flood Zones only cover small part of site and could be designed around. Impacts around surface water aren't
clearly set out but at this scale it seems unlikely that they could not be designed around. No indication/evidence for why the potential harm on SAM setting is
considered to be substantial and therefore prohibitive. This appears to closely align to a recommendation made by the GBHMA Strategic Growth Study for a 1,500-
7,500 dwelling SUE South of Halesowen which doesn't appear to be given weight in site selection.

Hayley Green and Cradley South SA-0135-DUD 54 Unclear why SINC/SLINCs crossing site are considered prohibitive given significant site area - offers opportunity to design around these.
Halesowen South SA-0255-DUD 5.2 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0246-DUD 64 Appears reliant on Green Belt/landscape factors in part for discounting.

Sedgley SA -0125 -DUD 5.8

Appears reliant on Green Belt/landscape factors in part for discounting. Given the limited cover of pylons within the site, the significant site area and that the bat
corridor is only adjacent (not covering) the site, it is unclear why these constraints can't be overcome.

Pedmore and Stourbridge East SA -0018 -DUD - C 4.7

Text on page 106-107 indicates the site (Worcester Lane South) is suitable for development alongside adjacent parcels, acknowledging the potential to create a new
defensible boundary to the south; unclear why it hasn't been selected.

Pedmore and Stourbridge East SA -0251 -DUD 6.5

Appears reliant on Green Belt/landscape factors in part for discounting. SINC/SLINC only cover a small portion of the site and it is unclear why they cannot be
designed around.
Norton SA -0019 -DUD 1.37 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC only affects limited area of site.

Gornal SA - 0139 -DUD 0.06

Appears reliant on Green Belt/landscape factors in part for discounting. Unclear why settlement pattern is considered a prohibitive constraint given the need to
increase densities within the Black Country.
Norton SA -0009 -DUD 1.19 Appears reliant on Green Belt/landscape factors in part for discounting.
Hayley Green and Cradley South SA-0091-DUD 2.73 Appears reliant on Green Belt/landscape factors in part for discounting.

Hayley Green and Cradley South SA-0244-DUD 1.5 Appears reliant on Green Belt/landscape factors in part for discounting. SLINC/TPO coverage is only partial and majority of the site appears unaffected.

Norton SA -0018 -DUD - A 38

Appears reliant on Green Belt/landscape factors in part for discounting. Areas of lesser Green Belt harm with 20ha of non-SINC land; unclear why trees scattered
throughout site cannot be designed around/mitigated.


Norton SA -0018 -DUD - B 167

Appears reliant on Green Belt/landscape factors in part for discounting. Partial coverage of SINC/SLINC within the site but given the large site size (167ha) it is
unclear why impacts cannot be mitigated through scheme design. Intervisibility with SAM and archaeological factors given, unclear from information provided why
these would be prohibitive towards development or whether there would be substantial harm to heritage.

Gornal SA -0059 -DUD 10.6

Unclear from the information provided why the site is considered not deliverable within the plan period, despite the site proforma otherwise indicating that site
issues can be mitigated.

Cradley and Wollescote SA -0027 -DUD 6.87

Appears reliant on Green Belt/landscape factors in part for discounting. Given the site size it is unclear why the loss of a limited area of SLINC (hedgerow) loss could
not be mitigated within the wider site.

Gornal SA-0243-DUD 50.18

Appears reliant on Green Belt/landscape factors in part for discounting. Majority of the site (between Cotwall End Rd and Sandyfields Rd) appears to be a golf
course and it is unclear why this use precludes redevelopment.
Lye and Stourbridge North SA -0227 -DUD 2.13 Appears to be listed as a rejected site but is allocated elsewhere in the Draft Plan (but only for part of the site area - see DUH025)

Object

Representation ID: 22625

Received: 11/10/2021

Respondent: Miss Mollie Haden

DUH 208 - Holbeache
DUH 211 - Triangle
DUH 218 - Guys Lane
DUH 031 - Straits Majors
DUH 210 - Viewfield Crescent

Environment - Destruction of habitats/hedgerows, trees - increased flooding
Road/Highways - Significant increase in highways traffic - accidents increase
- lack of infrastructure to support developments
- lose of village identity
- Additional houses will not be affordable
- Green space/belt should only be taken in exceptional circumstances - this is not exceptional circumstances as available brownfield sites

Object

Representation ID: 22626

Received: 08/10/2021

Respondent: Miss Molly Butcher

SA-0199-DUD/BCP Ref DUH222

I have recently moved out of my parents home on Severn Drive.
The field opposite is always in use by children and dog walkers and is a vital part of the community. As a kid I used this space to play safely and now so do many of the other kids on the estate.
It needs to be left as an open green space. I have watched the wildlife we get over there and during lockdown, it was a perfect exercise space for the small time we were allowed out. I have watched the community use this space to walk and meet up with others. Save this space and look at the abandoned buildings that are derelict and utilise those first and keep the small green spaces for community use.

Object

Representation ID: 22627

Received: 11/10/2021

Respondent: Miss Morgan Tutty

The green spaces we have are a great bit of land for the likes of children and dog walkers.
I always see children playing on these green spaces and this not only benefits their social life but their health and fitness too. These green spaces also allow dogs to have their runs without having to stick to just the pavement! I am a resident that personally uses these green spaces and I feel that the nature of these fields are MUCH nicer to look at on our estate than more houses that are not needed. The road will not cope with the extra traffic and cars parked with their being a school right opposite one.
Theres enough traffic on Lapwood Avenue and Bromley Lane and the more traffic this would cause is severely concerning

Support

Representation ID: 23086

Received: 07/10/2021

Respondent: Halesowen Abbey Trust

Celebrating Halesowen's Countryside
Black Country Plan Consultation
The Halesowen Abbey Trust supports the Green Belt designation of countryside in our Area of Benefit, as shown on page 14 of our attached report, following the Green Belt review and assessments.
For many years, the Trust worked with Dudley Council to improve this historic countryside, which is an important amenity serving a large population. We will provide a comprehensive report, in due course to explain our support in more detail. In the meantime, I attach a report, dated March 2020, titled,
'Celebrating Halesowen's Countryside', which explains the trials, tribulations and pleasure we have
experienced in respect of this countryside.
Will you please acknowledge our support by confirming safe receipt of this email and attachment?
'When any of the jaded toilers in the district known as the Black Country have an afternoon to spare, and feel that a few hours passed amidst the beauties of nature would be a benefit to them, there is nothing more natural than that they should travel by train to Hagley Station, or obtain a horse and conveyance, and proceed with as little delay as possible to the foot of Adam's Hill, Clent, in preference to taking a much longer and more troublesome journey elsewhere with no better result. The time occupied in reaching Clent from the surrounding populous districts is so comparatively short, and the neighbourhood around Clent Hill so beautiful, that it is pre-eminently the place to select for the popular day or half-day outing.'
Clent, 1910 - E Blocksidge, Stone St, Dudley.
We are fortunate to have beautiful countryside adjacent to and within Halesowen. It is an important informal recreational and educational resource for the region and has hitherto been formally recognised for its historic; landscape and ecological importance.
Recognition pre-dates the modern era. The Premonstratensian Canons of Halesowen Abbey, noted for their love of natural beauty, chose the site that was later known as Lapal - derived from the French 'la' added to the Anglo Saxon 'pol', meaning 'the pool' - A clear reference to the fishponds created for the Abbey. The Canons occupied the Abbey from 1218 until the dissolution of 1538. The remains of the Abbey were scheduled as an Ancient Monument as early as 1915 - in recognition of the importance of the site.
We are fortunate that the remains are preserved in their original rural setting, which is important to the character and identity of historic Halesowen.
Unsurprisingly, the Dudley Historic Environment Record indicates an unusually high incidence of entries, ranging through the mesolithic; bronze and iron ages, as well as the Romano-British and mediaeval periods. There may have been a substantial Roman Villa.
It has long been accepted that any disturbance of the ground, at, or in the vicinity of Manor Farm, is likely to reveal artefacts of archaeological significance.

Watching Brief for Erection of a New Barn at Manor Farm - 2008/2009
The owner of Manor Farm was granted planning permission for the erection of a large modern barn, just outside of the scheduled area of the monument but in close proximity to the Abbey's Infirmary - the most complete of the monastic remains on the site.
The erection of the barn took place in the field known as 'Abbey Oaks' and commenced on the 17th December 2008. The Borough's Archaeological Officer was engaged to carry out a watching brief and report the results.

To those familiar with the area, it came as no surprise to find that the chosen site was rich in archaeological deposits. Many fragments of mediaeval encaustic clay tiles from the Abbey were found. A small selection is shown in the above image.

Green Lanes. Public Rights of Way and Mediaeval Ploughing
Superficially, it may appear strange to group 'green lanes', Public Rights of Way and medieval ploughing, but in this instance they are further links to the historic rural past of Lapal and llley. The photograph opposite shows Manor Lane, circa 1905, when it was little more than a 'green lane'. From 1218, until 1538, It was an highway maintained by the Abbot of Halesowen Abbey. Subsequent development meant that it was upgraded, the most extreme change being from the junction with Grange Hill through the new section to junction 3 of the M5, as a dual carriageway, now known as Manor Way. Not so extreme, but still notable is Lapal Lane, split by Manor Way. The northern section serving the Manor Abbey Estate has been upgraded as an urban road with footpaths, increased carriageway width and street lighting, whilst Lapal Lane South, separating Manor Farm from Lapal Farm, is still a narrow country lane. Development in the Lapal countryside would change that.

In the 1980s the Halesowen Abbey Trust restored the Public Rights of Way of Lapal and Illey under the umbrella of the ‘Dudley Countryside Management Project’ jointly funded by Dudley Council and the Countryside Commission. As part of that work, the overgrown and neglected mediaeval ‘green lanes’ were restored. They were ditched either side for drainage, and in the steep section to Coopers Wood, wrought iron horseshoes from the medieval period were found, preserved in the clay. The presence of these, and hedgerow dating methods, helped to date the ‘green lanes’, the maintenance of which are referred to in the extant Court Rolls of Halesowen Abbey.
Today, the ‘green lanes’ are a valued relic, reminding us of the origins of some of our oldest local roads. They are also a source of pleasure and recreation for the hoards of walkers who enjoy this historic countryside. The value of the Public Rights of Way to the physical and metal well-being of those who enjoy them should never be under-estimated.
Ridge and Furrow appearing as undulations of the land, is a legacy of medieval ploughing. The Sites and Monument Records, held by Dudley Council, state that these date from between 1066 and 1485, and are found at Lapal and Illey on unimproved grassland. Where land has been under regular modern arable cultivation evidence of ridge and furrow has generally been erased. The photograph, taken at Illey Clearly shows the undulations with are best observed in a low oblique sunlight.
Below is an atmospheric photograph of Manor Farm, taken in the 1960s. It records the historic site as it was in its lengthy period as a working tenanted farm, which lasted from the dissolution of the monastery in 1538, until it was sold in 1993 by Viscount Cobham, whose family had held the site since 1560. A benefit of the long period of tenancy in farming was the lack of disturbance of most of the monument. Archaeological excavations took place in 1870 by J. R. Holliday and between 1925-1928 and 1934-1940 by the Duke of Rutland. Seven hundred and sixty of the Abbey's tiles are held in the British Museum and eight tiles are now in the Holliday Collection at the Victoria and Albert Museum, with six fragments in Halesowen Central Library and a case of tiles in St. John the Baptist Church, Halesowen. The long shadows in the photograph emphasise the earthworks of the Abbey. In the foreground is a dam to one of the former monastic fishponds.

Under the terms of a Guardianship Agreement of 1979, with the then owner, Viscount Cobham, English Heritage have the right to open the Abbey to the public along a defined and restricted route, with access to the Infirmary. A small car park is identified for visitors. For several years that right has not been enacted, but the public can walk the Public Rights of Way, giving limited access to some of the fishponds and allowing views of the monastic remains.
The six bedroom farmhouse, for Manor Farm (seen in the above photograph), built in the late 19th century, replaced a mediaeval building, the use of which is in doubt. The old building has been variously described as the former Abbot's lodging and as a mill. The impressive replacement was designed by Yeoville Thomason, the distinguished architect responsible for Birmingham's impressive Council House and other such fine buildings.

In the 18th Century, this was the landscape enjoyed by William Shenstone of the Leasowes; his relative and friend, Lord Dudley of the Grange and their literary associate, John Scott Hilton of Lapal House. Shenstone used stone from the Abbey to construct his ruined 'Priory'- a major feature of his landscape creation, the Leasowes. Sir George, Lord Lyttelton (1709- 1773), of Hagley Hall, allegedly took stone from the Abbey to create one of his fine parkland follies, the Castle.

Official Recognition, 1989
Hitherto, we have concentrated on llley and Lapal, but this is simply part of a swath of special countryside that in the mid nineteenth century was described as 'Clentine' because of its relationship to the famed Clent Hills. The Clent Hills are set within beautiful countryside and are inseparable from it and vice-versa.
Whilst the public are aware of the importance of the
'Clentine' countryside, unfortunately it is not afforded the protection of an 'Area of Outstanding Natural Beauty', or a 'Country Park'. Perhaps it should be? Nevertheless, in 1989, it was recognised in a statutory plan, produced, at that time, by an enlightened Dudley Council planning department, titled 'A Place for Leisure'. It was formally acknowledged by the Royal Town Planning Institute for its progressive and positive approach.

Besides being prepared to 'establish and define the boundaries of the Green Belt', the other main reasons for preparing the plan were:
• to give recreation and open space considerations significant place in decision making
• to provide land for the whole range of outdoor recreational activities in the Borough
• to contribute towards urban regeneration

The four main aims of the plan were:
1. to provide a positive context for the protection and enhancement of open land throughout the Borough
2. to establish a site specific basis for a programme of new development

3. to establish a land use context for the development of a nature conservation strategy
4. to provide an opportunity for the public to participate in planning decision

The implementation of 'A Place for Leisure' led to the employment of a Countryside Manager and the creation of the Dudley Countryside Management Project (DCMP}, which started a three year experimental phase in September 1988. A 'Biennial Report 1991-1993' indicated how successful the project was.
Betray?
The Dudley Countryside Management Project has been downgraded and no longer has planning department support, or recognition. Similarly, 'A Place for Leisure', and its aims and objectives, are not acknowledged and are even denied by the current planners. In 2015, Dudley's planners supported a huge enterprise zone on the countryside of Lapal and llley, as shown on the plan opposite. Ancer Spa were commissioned to pursue this. It would have decimated splendid historic countryside, important to the character and identity of Halesowen and its people. Understandably, this sorry episode damaged public confidence in Dudley's planners.

On that occasion, councillors, who had hitherto been sidelined by the planners, responded quickly and threw out the proposal at a meeting of full Council. However, with the employment of new staff, the planners have ever since been aggressively pursuing development of Dudley's countryside.

In spite of Dudley Borough having a surplus of urban housing land to meet its own needs beyond the end of the next plan period in 2038, the planners have provisionally agreed to 5,000 new houses in Dudley's Green Belt to meet the claimed needs of neighbouring authorities. This first came to light in a letter of the 9th September 2019 from Wolverhampton Council to Shropshire Council, which stated
"Given that the Black Country Green Belt is located primarily in Walsall and, to a lesser extent, in Dudley, these are the two main housing market areas for delivery of housing, with only small amounts of housing potential in Wolverhampton and Sandwell. Therefore, based on a scenario that there was sufficient unconstrained physical capacity identified within the Green Belt, it may well be that a Delivery Study (based on similar principles to that completed by PBA for Birmingham), could reasonably conclude that these two nominal housing market areas could only be expected to deliver up to 5,000 homes each over the 15-year Plan period, based on upon what the market can be expected to deliver. This would therefore only provide up to 10,000 homes in total."
It is fortunate that such revealing and premature comments have come to light. Again public confidence in the integrity of the planning process, has been justifiably damaged. In September 2019, we were led to believe that evidence was still being collected and collated, in advance of being considered. Then the matter should go to Cabinet before going public. It is a controversial decision for a Council, with no justification to develop its Green Belt for its own needs, to offer its precious countryside for the needs of others. Do such grounds, which would surely be ongoing, if agreed, constitute the 'exceptional circumstances' as required by the National Planning Policy Framework? The Green Belt, instead of having the protection required in guidance would become a perpetual resource for development.

Volunteers Support the Previous Policies of Dudley Council
Whilst the current Dudley planners have turned their backs on recognition, protection and improvement of our countryside, volunteers who pro-actively worked with their predecessors, continue with the task. Within the limits of available resources, footpaths are cleared and problems are addressed. Elected members are appreciative and supportive.
In the summer of 2017, volunteers of the Halesowen Abbey Trust, constructed a substantial footbridge at the Trust's Grade 1 Listed Leasowes Walled Garden (in the Green Belt); transported it to site, adjacent to Uffmoor Wood, in the vicinity of Tack Farm and installed it. This overcame a major flooding problem, which had prevented appropriate use of a popular Definitive Right of Way.

Promoting Appropriate Use & Enjoyment of the Countryside

The National Planning Policy Framework reflects the Government's positive attitude towards Green Belts, and states:
13. Protecting Green Belt land
133. 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
141. Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Paragraph 141 relates perfectly to the aims of 'A Place for Leisure', which defined the Green Belt boundaries of Dudley in 1989 and not in the 1970s as claimed by the Borough's planners.

The Halesowen Abbey Trust has produced eight walk leaflets to promote use and enjoyment of the local countryside in their area of benefit. An 'Index and Guide' has just been published to accompany the walk leaflets and explain how the walks link up. The illustrated leaflets are full of information to assist the user.

The 'Area Map' clearly illustrates the link up of the walks over an extensive area. We are fortunate to have such an asset, but at present the future of that countryside is in doubt. It need not and should not be that way

Comment

Representation ID: 23099

Received: 11/10/2021

Respondent: Canal & River Trust

The plan also includes a site over the line of the Dudley Tunnel (DUH204), which requires careful consideration, including of the probable former construction shafts within the site, which require protection.

Comment

Representation ID: 23155

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

Paragraph A1, we feel that this should include reference to its important natural heritage of internationally famous limestone fossils.

Paragraph A2 should also refer to the internationally renouned fossil collections on display at Dudley Museum in the Archives and Local history centre. It is also worth noting in this paragraph that Castle hill is a very important tourism ‘node’ within the Geopark.

Paragraph A7, needs to include its natural heritage in this narrative.- as it has world-renowned natural assets too of its fossil collections and sites like Castle Hill and Wrens Nest National Nature Reserve. These should not be omitted.

Paragraph A 16 Brierley Hill under bullet point i) it is worth including linkages between adjacent heritage sites such as Fens Pools (European sAC), saltwells National Nature Reserve(Literally just across the Pedmore Road from the site boundary and very significant to the landscape character here).

Object

Representation ID: 23163

Received: 30/09/2021

Respondent: Mr + Mrs Mr and Mrs Bradshaw

Dudley MBC
1) Worcester Lane (Ref: DUH206, DUH207, DUH209)

There is obvious Traffic + Transport hazards - Local roads are congested at rush hour + Stourbridge junction + Hagley services are congested (including the overflow at SBJ) often by 9am weekdays.
Our towns _ villages cannot cope with the increase in populous - as well as our already stretched schools, doctors + dentists. Local bus/rail services are unable to cope at present. How will they cope with 200+ more residents? The Worcester Lane site is a gateway to footpaths + bridleways, an increase in traffic on these narrow + winding roads will detract from the area, create more fumes and pollution impacting on ancient wildlife, flora + fauna. Walking through a housing estate with mostly artificial grass gardens will not support pollination and will have a detrimental effect on local agriculture. Also to cite "5 policies of the Green belt" Para 138 of the NPPF.

Object

Representation ID: 23207

Received: 11/10/2021

Respondent: Julie Norton

I made some comments about certain areas that were due for additional development in the surrounding area. Most of which I objected against having too many properties and struggling to commute and the lack of public transport that actually gets you anywhere. The rail service has reduced stops in coseley now. There are no police!

I cannot remember all I said but this is the gist of it.

Apologies but I spent a long time filling in the form and clearly it didnt save it so what a waste of time this has been. Ultimately it will mean that the local public are ignored and Dudley once again go against the wishes of its bill payers and still do exactly opposite what they wish as in the case of budgen road Gypsy Camp and the Tip at Anchor Lane

Object

Representation ID: 23463

Received: 04/10/2021

Respondent: Dr. Narendra Kamar

I object to the Green Belt land which has been identified between Worcester Lane and the Railway line for 115 homes construction. In my opinion, Dudley Council should focus on re-developing existing brownfield sites for new homes construction.
The proposed site on Worcester Lane will increase and add a lot of traffic & motor vehicles.
The increase in extra motor vehicles will make walking on Racecourse Lane, WITHOUT PAVEMENT, more dangerous for pedestrians.
Racecourse Lane is hardly 300 yards from the proposed site for New Homes Construction on Worcester Lane.

Object

Representation ID: 23474

Received: 08/10/2021

Respondent: Mr Neil Page

I object to Severn Drive SA-0199-DUD/BCP REF DUH222 being built on. As long as I can remember that piece of land being a great view and a part of that estate. It would be a great shame to lose it as I've often walked around it when visiting my friends. I cant see how the road around it will cope with extra cars and congestion. This would spoil the estate.

Summerhill Triangle-SA-0025-DUD/BCP REF DUH211
Building on this rea would cause so much congestion to an already busy area and roads and making it unsafe for motorists and pedestrians and school children. Also it is a view Kingswinford is known for and full of wildlife which we shouldn't lose

Object

Representation ID: 23475

Received: 30/09/2021

Respondent: Mr Neil Perry

Dear Sirs, I have lived at [Road] all my life opposite the proposed site. I am alarmed that it has been put forward with so much Brown field sites available. Apart from the obvious traffic issues the area will not be able to cope with more houses and people. The field adjacent to my house provides drainage and we are still prone to flooding along Worcester Lane. The main road and amenities in Hagley will simply not cope with more people. I walk my dog everyday across the fields and have had access for many years to the field opposite. The wildlife present is of great concern and must be considered. I have erected several nest boxes around the perimeter and Blue, great and coal tits have used these every year. Lapwings & Skylarks nest in the grass we have 3 species of owls hunting the fields. Barn , Tawny & Little Kestrels, buzzards and sparowhawks are also seen.
Mistle Thrushes, song thrushes, Blackbirds, Wrens, Robins, Chaffinch, Gold Finch, Green finch, Yellow Hammer, Bull finch, Linnets. the list is endless. Not to mention the muntjac & foxes, wild flower butterflies and insects. I could go on.
All this must be considered and looked after our wildlife needs these areas and it is vital to the environment. This must not be allowed to vanish forever...!!

Object

Representation ID: 23484

Received: 11/10/2021

Respondent: Neil Wyke

The proposal to build 45 houses on Lapwood Avenue Green will add to the already overloaded traffic congestion around Crestwood Primary School. Parking is already as a premium on the surrounding road and culdesacs and accidents, cars and people is bound to increase.
45 extra houses will bring many extra vehicles that will use Lapwood Avenue on to Bromley Lane which again is already overcrowded and the suggestion of adding a breakthrough to Ketley Quarry site will only add to this.
Lapwood Avenue Green field provides a central and accessible open space for all ages to enjoy. Older people, children and dog walkers use the green daily. Is it located away from the main road making it an ideal and safe source of recreation and community space.
The other effects on school placements , doctors and Dentist for the proposed new houses will adversely effect an already overloaded system