A. Dudley

Object

Representation ID: 15830

Received: 11/10/2021

Respondent: Mr Stephen Palmer

Title: Black Country Site Assessment Report.
Dudley Appendix A, pages 75-78. Holbeache SA-0017-DUD.

Objection1:- Effect on local services:-NHS
- Not enough local doctors in the area, Moss Grove surgery is having to refer patients to Kinver.
- Russell's Hall Hospital - Emergency services are under severe pressure (A+E waiting times are already over 4 hours)

Objection2:- Effect on local services:- Roads
- A449 already very busy at peak times. Heavy congestion through Wall Heath and Himley. Extra vehicles will increase noise & pollution. Slow down bus services + increase number of drivers cutting through Maidensbridge estate.

Objection 3:- effect on local services: Schools
Local primary + secondary schools are already at almost 100% capacity - where will the additional children go to school?

Objection 4:- Employment & Transport links
No rail network plus limited bus services will force more communities to use cars and future gridlock The A449/A491

Objection5:- Irreversible destruction of valuable green belt land.

Object

Representation ID: 15931

Received: 11/10/2021

Respondent: Mrs Susan Fuller

DSA.1,2 & 3

I object to any further proposed development in the Kingswinford area as the infrastructure and in particular the road network is grinding to a halt.
GP Surgeries, schools and local hospitals also cannot cope with the current population.
The proposals will only add to the above pressures and IF they are to be followed through significant investment in local services and infrastructure needs to take place first.

Object

Representation ID: 15971

Received: 11/10/2021

Respondent: Rhett Turner

I object on a number of counts.
First and foremost, I object on the large scale building on green belt land. Until all other avenues are exhausted, we should not be using valuable green belt to build large scale housing developments.
Secondly the local infrastructure cannot withstand more large housing developments, and by infrastructure I am not just referring to road, the lack of other supporting infrastructures does put greater pressure on the road infrastructure.
As there are no large or growing employers in the area these new homes will invariably be filled by people who won’t work in the area, meaning that largely they will have to travel out of the local area for employment.
The area does not have good public transport links to the major employment areas meaning that for large numbers public transport is not an option for their daily commute.
The road infrastructure around Kingswinford, Wall Heath and Wordsley can’t cope with the current usage and is grid locked for large portions of the day. When travelling in or out of the area it is very noticeable how much worse the congestion is in and around these areas. [redacted] It’s the Kingswinford ends of the journey that take a disproportionally long time.
If traffic congestion gets worse then this will have a significate negative effect on air quality, with vehicles spending more time stationary or moving slowing emissions are going to get worse leading to increased health issues for young and old alike.
The local doctors and dental practices are already at capacity so won’t be able to take on the new arrivals into the area, meaning either people will have to go without or travel to other areas to get treatment, adding to the traffic burden.
Many of the local schools are at or close to capacity meaning finding local school places will become more difficult resulting in a greater requirement for the school run to have to use the car.
Financial impact, while those directly involved with the project will financially benefit a large proportion of the exiting population won’t, increased congestion and lack of availability of local resources can only mean the area is less desirable to live in putting downward pressure on house prices. Increased congestion will mean that more time is spent queuing meaning wasting money on fuel. Lack of local resources will also mean having to spend time and money travelling out of the area.
The negative effect of the general wellbeing on the local population. Having good accessible green belt areas close on hand has a highly positive effect on one’s general wellbeing, losing these areas will have a negative effect, then taken together with the greater stress placed on the local populous, having to spend more time in congestion, travelling out of the area for a doctors appointment etc, will have a compound effect on the general wellbeing in the area.

Object

Representation ID: 15980

Received: 04/10/2021

Respondent: Mrs Susan Lovell

SA-0050-DUD/BCP REF DUH216 Bryce Road
SA-0199-DUD/BCP REF DUH222 Severn Drive

We need to keep these green spaces for the local residents to enjoy, plus there are enough traffic around these areas without more houses being built.

Object

Representation ID: 16000

Received: 08/10/2021

Respondent: K Phillips

(ID 10511- Three Fields, Dunsley Road, Norton )

Dear Madam/Sir

This letter of objection is in reference to sites DUH217, DUH206,DUH207, DUH209 and ID 10511.
Please leave our Greenbelt alone; it is not just about it's beauty but it's a haven for wildlife; such as foxes, deer, lots of different species of birds including starlings (which were once common in the 1970's but have declined greatly), at least 20 species of butterfly which alongside other pollinating insects must be helped + protected as they are struggling hugely. There's also many types of plants + trees including Hawthorn trees (whose blossom is very important to pollinating insects) + ancient hedgerows.
It is also one of the few green spaces accessible to people within walking distance from Wollaston. It is used by people all the time, for exercise, for recreation and it is also extremely beneficial to people's mental health. These spaces are used all the time but in particular in the pandemic when their benefits were invaluable.
They also have environmental benefits such as capturing carbon + protecting the water supply from pollution. Birmingham + Black Country Wildlife Trust says 6 out of 10 UK species are in decline with more than 1 in 10 in danger of disappearing.
Woodland, grassland + heathland, fresh water + wetland species are under great threat in this area. The threats to the environment globally is as you know in a very bad situation + if we want to make changes which we must- we have no choice, that includes you too, those changes start at home + in our immediate surrounding area. All of our greenbelt is precious + must be protected for us and the wildlife.
You keep saying brownbelt for houses first + then you attack the greenbelt. What about the huge sites near the Bonded warehouse, there's no mention of them +yet the sites are so big the could probably accommodate most if not all if the houses for the time being. There's also meant to be 270,000 houses in England that are empty + have been so for at least 6 months. What about looking into that? what about disused + abandoned pubs, churches, shops + offices being converted into apartments+ houses? There is a website called Land Hero run by Hagley based firm Land Attic, which is a match making services for landowners, agents + developers+ communities to bring forward sites for housing + employment, they can't be the only firm in operation , so there are always people who can put us in touch with more appropriate land. I don't bother with the internet + yet i know of those people- so why don't you- there is no excuse.
This is an appalling + unnecessary attack on greenbelt. It is also extremely undemocratic; one of the developers was quoted as saying about land in Pedmore that the site could + should be removed from the greenbelt. Who does he think he is. It is us who live here + have to put up with all the problems left behind, but ultimately damage + destruction of the environment effects us all, including him. This attitude is running roughshod over the general public. We deserve to be listened to+ respected. Once the greenbelt is gone its gone forever. We have a duty to preserve it not just for our present day generations but for future ones too.

Object

Representation ID: 16045

Received: 11/10/2021

Respondent: Alexandra Barton

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 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)
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.

Support

Representation ID: 16107

Received: 23/11/2021

Respondent: Angela Brooks

[Halesowen Greenbelt]

Lapal, Illey, Coombeswood, Uffmoor, Hayley Green, Lutley and Foxcote
I support the Council’s continued protection of countryside at Lapal, Illey, Coombeswood, Uffmoor,
Hayley Green, Lutley and Foxcote, following a formal review of the Green Belt.
Circa 1989, Dudley Council, following a previous Green Belt review, improved the Public Rights of Way network in these areas, by working in collaboration with local volunteer groups. Following on from that, the Council promoted enjoyment of this countryside, by the public, for informal recreation. They supported the production of walk leaflets explaining the historic, landscape and ecological significance of each area.
The Council even contributed £20,000 towards The Woodland Trust purchasing Uffmoor Wood, despite this being just outside the Borough Boundary and coming under Bromsgrove. In doing so, they appreciated the important relationship between this ancient coppice woodland and neighbouring farmland, including Tack Farm, which is the site of a former Anglo-Saxon mill (Notwic Mill).
This countryside, protected by Green Belt designation, is rich in history. At Lapal and Illey are the remains of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance. At Lutley we have a Conservation Area associated with historic Lutley Mill and the green lane that links it to the mediaeval hamlet of Lutley, which was once held by the Canons of Wolverhampton. Foxcote, which forms the foreground setting of the Iron Age Fort on Wychbury Hill and historically is linked to it, is archaeologically rich with frequent finds of flint arrow heads, flint scrapers, axes and other tools.
It was the site of ancient hunting summer camps, and, in part, this explains the wide scatter of historic ‘finds’.
The countryside, hereby defined, is important to people from far afield, and, within the wider landscape, encompasses the famed and beautiful Clent Hills, a major area of which is owned and managed by the National Trust. We must also consider the Hagley Hall Estate, which includes a major proportion of Wychbury Hill, the importance of which was acknowledged in the 18th Century, by George Lyttelton, in his creation of Hagley Park, which is now a Grade 1 Listed Garden. On Wychbury Hill are two significant ‘follies’ - The Temple of Theseus and The Obelisk, tastefully exploiting the landscape prominence of the hill and the presence of the fort.
The whole of this area, including that within Dudley Borough, is of regional importance as an amenity asset for the welfare of, and enjoyment by, a large population. It would be so simple to seriously damage the area with inappropriate developments and associated infrastructure.

Object

Representation ID: 16145

Received: 11/10/2021

Respondent: Mrs Anu Sahota

Comments on Draft Black Country Plan
Reference: BCP-SGR-2021: Stourbridge group response to Draft Black Country Plan
SUMMARY
I object to the allocation of the following green belt sites for the reasons listed:
Sites: DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane
Central, Stourbridge DUH209, Worcester Lane South, Stourbridge Objection to
allocation because:
Sites lie in an Area of High Historic Landscape Value (AHHLV) Sites are adjacent to a
Site of Local Importance for Nature Conservation (SLINC) Release would constitute
unacceptable harm to the green belt.
Site: DUH217, Grazing Land Wollaston Farm, Stourbridge Objection to allocation
because:
Site should be used as a public open space.
Site falls in an area of high Landscape sensitivity Site should be protected due to
Tranquillity We object to the following site not being designated as a Local Green
Space (LGS)
Site: ID 10511, Three Fields, Dunsley Road, Norton.
Objection to this site not being designated as LGS because:
The site meets all criteria for a Local Green Space (LGS) LGS designation would
demonstrate its significance to the community.
Page 1/2
I OBJECT TO THE ALLOCATION OF THE THREE WORCESTER LANE SITES FOR
THESE REASONS:
Site reference numbers: DUH206, Worcester Lane North, Stourbridge; DUH207,
Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV.
Strategic Priority 12 is to "protect, sustain and enhance the quality of the built and
historic environment." See also Policy ENV5, p. 230. All three are green field sites
with grade 3a agricultural land situated in a strongly rural landscape and contain
public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation,
agricultural and nature conservation value”, these sites should not be allocated.
Proximity to Site of Local Importance for Nature Conservation (SLINC): There is an
adjacent SLINC, as well as mature trees and hedgerows, and I/we believe that no
mitigation would be sufficient to be considered sustainable.
Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green
Belt harm for these three sites. There would be no clearly “defensible boundary” to
this development (Policy GB1, and para 3.16). Development would also encroach on
the open countryside between Hagley and Pedmore, going against at least three of
the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted
sprawl, (b) preventing neighbouring towns merging into one another, and (c)
safeguarding the countryside from encroachment.
I/WE OBJECT TO THE ALLOCATION OF GRAZING LAND WOLLASTON FARM
FOR THESE REASONS: Site reference number: DUH217, Grazing Land Wollaston
Farm, Stourbridge.
Public open space: The site is located within Community Forum 7, where there is a
below-average quantity of open space. It was well-used in the past, before the public
were excluded from the site. I/we believe the site should be re-opened to provide a
much-needed green space in this area which could additionally be developed as a
wildflower meadow.
Landscape sensitivity: This is a green belt, green field site, which although having no
agricultural rating and defined as ‘urban’, falls within area S17 having high landscape
sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity
Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be
considered to constitute “significant planning constraints which cannot be mitigated",
despite the high levels of housing land which the BCP is seeking to meet.
Tranquillity: The NPPF states that planning policies should "identify and protect
tranquil areas which have remained relatively undisturbed by noise and are prized for
their recreational and amenity value for this reason" (NPPF 2019, para 180(b)). The
government guidelines on what constitutes a tranquil place are that it is "relatively
undisturbed by noise from human sources that undermine the intrinsic character of
the area" with a positive soundscape for e.g. of birdsong. ("Guidance: Noise", HMG
2019, para. 8). This site should be assessed for tranquillity and protected under
Policy GB1 (4) on protecting tranquil areas.

Object

Representation ID: 16155

Received: 07/10/2021

Respondent: Mrs Anna Partridge

Title of document: Draft Black Country Plan To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley

Nature of comment: ‘Objection’

I object to the allocation of the following four sites in the Draft Black Country Plan:

DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
DUH217, Grazing Land Wollaston Farm, Stourbridge.

I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.

Reasons for objections:

Sites: DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.

Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV. Strategic Priority 12 is to “protect, sustain and enhance the quality of the built and historic environment”. See also Policy ENV5, p.
230. All three are green field sites with grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way.
Given the emphasis in Policy CPS3 on “heritage, recreation, agricultural and nature conservation value”, these sites should not be allocated.

Proximity to Site of Local Importance for Nature Conservation (SLINC):
There is a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mitigation for this.

Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green Belt harm for these three sites. There would be no clearly “defensible boundary” to this development (Policy GB1, and para 3.16).
Development would also encroach on the open countryside between Hagley and Pedmore, going against at least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another, and (c) safeguarding the countryside from encroachment.

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.

I object to the allocation of the above site for development on the following bases:

Public open space: The site is located within Community Forum 7, where there is a below-average quantity of open space. It was well-used by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it as a wildflower meadow.

Landscape sensitivity: This is a green belt, green field site which, although having no agricultural rating and defined as ‘urban’, falls within area S17 having high landscape sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be considered to constitute “significant planning constraints which cannot be mitigated”, despite the high levels of housing land which the BCP is seeking to meet (Site Assessment Report).

Tranquillity: The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place are that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise”, HMG 2019, para. 8). This site should be assessed for tranquillity and protected under Policy GB1 (4) on protecting tranquil areas.

Object

Representation ID: 16161

Received: 10/10/2021

Respondent: Ann Dixon

Title of document: Draft Black Country Plan
To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley
Nature of comment: ‘Objection’
I object to the allocation of the following four sites in the Draft Black Country Plan:
DUH206, Worcester Lane North, Stourbridge
DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
DUH217, Grazing Land Wollaston Farm, Stourbridge.
I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.
Reasons for objections:
Sites: DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
Area of High Historic Landscape Value (AHHLV):These sites lie in an AHHLV.
Strategic Priority 12 is to “protect, sustain and enhance the quality of the built and historic environment”. See also Policy ENV5, p. 230. All three are green field sites with grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation, agricultural and nature conservation value”, these sites should not be allocated.
Proximity to Site of Local Importance for Nature Conservation (SLINC): There is a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mi ga on for this.
Green Belt harm: I disagree with the Green RAG ra ng of low/moderate for Green Belt harm for these three sites. There would be no clearly “defensible boundary” to this development (Policy GB1, and para 3.16). Development would also encroach on the open countryside between Hagley and Pedmore, going against at least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another, and (c) safeguarding the countryside from encroachment.

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:
Public open space: The site is located within Community Forum 7, where there is a below average quantity of open space. It was well-used by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it as a wildflower meadow.
Landscape sensitivity: This is a green belt, green field site which, although having no agricultural rating and defined as ‘urban’, falls within area S17 having high landscape sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be considered to constitute “significant planning constraints which cannot be mi gated”, despite the high levels of housing land which the BCP is seeking to meet (Site Assessment Report).
Tranquillity: The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place are that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise”, HMG 2019, para. 8). This site should be assessed for tranquillity and protected under Policy GB1 (4) on protecting tranquil areas.

Support

Representation ID: 16184

Received: 05/10/2021

Respondent: Ben Conway

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

Circa 1989, Dudley Council, following a previous Green Belt review, improved the Public Rights of Way network in these areas, by working in collaboration with local volunteer groups. Following on from that, the Council promoted enjoyment of this countryside, by the public, for informal recreation. They supported the production of walk leaflets explaining the historic, landscape and ecological significance of each area.

The Council even contributed £20,000 towards The Woodland Trust purchasing Uffmoor Wood, despite this being just outside the Borough Boundary and coming under Bromsgrove. In doing so, they appreciated the important relationship between this ancient coppice woodland and neighbouring farmland, including Tack Farm, which is the site of a former Anglo-Saxon mill (Notwic Mill).

This countryside, protected by Green Belt designation, is rich in history. At Lapal and Illey are the remains of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance. At Lutley we have a Conservation Area associated with historic Lutley Mill and the green lane that links it to the mediaeval hamlet of Lutley, which was once held by the Canons of Wolverhampton. Foxcote, which forms the foreground setting of the Iron Age Fort on Wychbury Hill and historically is linked to it, is archaeologically rich with frequent finds of flint arrow heads, flint scrapers, axes and other tools.

It was the site of ancient hunting summer camps, and, in part, this explains the wide scatter of historic ‘finds’.

The countryside, hereby defined, is important to people from far afield, and, within the wider landscape, encompasses the famed and beautiful Clent Hills, a major area of which is owned and managed by the National Trust. We must also consider the Hagley Hall Estate, which includes a major proportion of Wychbury Hill, the importance of which was acknowledged in the 18th Century, by George Lyttelton, in his creation of Hagley Park, which is now a Grade 1 Listed Garden. On Wychbury Hill are two significant ‘follies’ - The Temple of Theseus and The Obelisk, tastefully exploiting the landscape prominence of the hill and the presence of the fort.

The whole of this area, including that within Dudley Borough, is of regional importance as an amenity asset for the welfare of, and enjoyment by, a large population. It would be so simple to seriously damage the area with inappropriate developments and associated infrastructure.

Object

Representation ID: 16220

Received: 06/10/2021

Respondent: Colin and Ruth Burch

Number of people: 2

Hi as a resident in [Redacted- GDPR] Wollaston , Stourbridge I live very near to the proposed
development of 90 houses on the land between The Kingsway , Wollaston and Hyperion Road, Stourton .
My wife and I use the bridleway to walk alongside the
meadows currently used for horses grazing .
This is a very valuable piece of green belt that is used by many local; people for walking , cycling , running etc . There is also varied wild life in the area .
We regard this piece of land therefore as very unsuitable for a development of 90 residential properties.
Ps . Why not develop the land between Vicarage Road, Stourton and the main A458 road near the rugby ground .

Object

Representation ID: 16224

Received: 05/10/2021

Respondent: Deborah Palmer

Title of document: Draft Black Country Plan
To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley
Nature of comment: ‘Objection’
I object to the allocation of the following four sites in the Draft Black Country Plan:
DUH206, Worcester Lane North, Stourbridge
DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
DUH217, Grazing Land Wollaston Farm, Stourbridge.
I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.
Reasons for objections:
Sites: DUH206, Worcester Lane North, Stourbridge DUH207, Worcester Lane Central, Stourbridge DUH209, Worcester Lane South, Stourbridge.
Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV.
Strategic Priority 12 is to “protect, sustain and enhance the quality of the built and historic environment”. See also Policy ENV5, p. 230. All three are green field sites with grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation, agricultural and nature conservation value”, these sites should not be allocated.
Proximity to Site of Local Importance for Nature Conservation (SLINC): There is a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mi ga on for this.
Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green Belt harm for these three sites. There would be no clearly “defensible boundary” to this development (Policy GB1, and para 3.16). Development would also encroach on the open countryside between Hagley and Pedmore, going against at least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another, and (c) safeguarding the countryside from encroachment.
Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:
Public open space: The site is located within Community Forum 7, where there is a below average quantity of open space. It was well-used by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it as a wildflower meadow.
Landscape sensitivity: This is a green belt, green field site which, although having no agricultural rating and defined as ‘urban’, falls within area S17 having high landscape sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be considered to constitute “significant planning constraints which cannot be mi gated”, despite the high levels of housing land which the BCP is seeking to meet (Site Assessment Report).
Tranquillity: The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place are that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise”, HMG 2019, para. 8). This site should be assessed for tranquillity and protected under Policy GB1 (4) on protecting tranquil areas.

Object

Representation ID: 16226

Received: 07/10/2021

Respondent: Deb Brownlee

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 underetimated. 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 mee ng 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)
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: 16237

Received: 06/10/2021

Respondent: K Phillips

(ID 10511- Three Fields, Dunsley Rd, Norton)

Site: ID 10511, Three Fields, Dunsley Road, Norton.
Objection to this site not being designated as LGS because:
The site meets all criteria for a Local Green Space (LGS)
LGS designation would demonstrate its significance to the community.

I/WE OBJECT TO THREE FIELDS NOT BEING DESIGNATED AS A ‘LOVAL GREEN SPACE’ FOR THESE REASONS:
Site reference number: Site ID 10511, The Three Fields, Norton, DY8 3LS (site ID number 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, which was assessed for a LGS Designation in the Site Assessment Report.
Local Green Space: This site meets all of Part A criteria, and sufficient of Part B criteria (Beauty, and Recreation) to meet national criteria for a Local Green Space. 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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise…the community value of land” (Neighbourhood Planning, 2019, para134). A LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘green belt’.
Designations: The site has mature hedgerows which should be surveyed. Other hedges in the locality recently received SLINC protection (Racecourse Lane, SLINC,Norton)
Tranquillity: This site should be protected under Policy GB1(4) on protecting tranquil areas as it fulfils the criteria listed above.

Object

Representation ID: 16240

Received: 11/10/2021

Respondent: Mr David Viner

I would like to raise an objection to the following sites in the "Black Country Plan” (BCP): Wollaston Farm (DUH217), Worcester Lane (DUH 206, 207, 209), Corbett Meadow (OSA4).

I understand the land known as Corbett Meadow was gifted to the people of Stourbridge by Mr John Corbett . It is not acceptable to have this gift of land destroyed by building on it.
The reason for my objection is that these plans fail paragraph 141(a) of the
Government’s guidance for “Protecting Green Belt Land” as there is sufficient brownfield land for Dudley Borough until 2036. These green areas are also vital for people in the locality to use for exercise and recreation such as walking. Furthermore, it would displace the natural wildlife in those areas.

There is a lot of talk about building on brownfield land rather than building on the green belt. Now is the time to put words into action.

Comment

Representation ID: 16251

Received: 05/10/2021

Respondent: Mr Balwant Toor

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, I believe that due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.

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 is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations

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'. 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 has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, "green belts do not recognise… the community value of land" (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply 'green belt'. This site should therefore be granted a Local Green Space designation.

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. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night There are extensive views over local countryside, fields, woodland and distant hills The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8).

Comment

Representation ID: 16316

Received: 05/10/2021

Respondent: Frederick White

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, I believe that due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.

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 is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations

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'. 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 has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, "green belts do not recognise… the community value of land" (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply 'green belt'. This site should therefore be granted a Local Green Space designation.

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. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night There are extensive views over local countryside, fields, woodland and distant hills The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8).

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: 16356

Received: 11/10/2021

Respondent: Mr Eurwyn Matthews

I wish to lodge my OBJECTION to the Draft Black Country Plan in general as it gives insufficient consideration to what supporting infrastructure works would be necessary for such a substantial increase in population.

An increase of 76.076 houses would mean an increase of 200,000 + of population. Almost like adding another Wolverhampton!

When, nearly years ago, my employer moved me to this area I could drive during “rush hour” from Kingswinford to my office on the outskirts of Stourbridge, taking not much more than 10 minutes. Today that same journey, at any me of the day, can take in excess of 30 minutes.

Have the roads improved to deal with the increased traffic? No, they are exactly the same. Are there additional schools?
More GP surgeries? Water reservoirs?
Sewage treatment works?

The list just goes on and gradually over me the same unimproved facilities get overloaded. Enough, I say. Let us improve what we have and make this the nice place to live, which it once was.

Object

Representation ID: 16384

Received: 10/10/2021

Respondent: Ms Denise Hicklin

Generic
Increase traffic, noise and pollution

Lack of facilities such as doctors, dentists, schools, chemists etc - where to build and how funded?

Loss of open green spaces

Loss of habitat for nature

Increaesed pressure on local shops, lack of car parking

Increased difficulty leaving and entering an already busy estate - personal expereince of this where I was involved in a RTA.

Inadequate Infrastructure

Extra time to get to A & E

People moving out of area due to loss of green spaces

Object

Representation ID: 16415

Received: 04/10/2021

Respondent: Mr and Mrs Jean and Derek Hill

Number of people: 2

Site known as Land off Lutley Lane, Adj to Brookside Close.
It has been brought to our attention, the proposal for building houses on the land opposite Brookside Close, Halesowen B63.
WE WISH TO OPPOSE THE APPLICATION.
We would bring to your attention, the fact that this land is in constant use by the residents of both the Hasbury Farm and Squirrels estates for walking and also exercising their dogs.
In the lock down, when we were only allowed to exercise within 3 miles of our home, we found it a godsend to be able to walk across the fields using the public rights of way.
Your "OC2 version of form", only mentions the public footpath running alongside the eastern boundary, but there is also a bridleway on the north of the site.
Where do you propose to access the site?
The area where Lutley Lane meets Huntingtree Road, contains The Mill which is currently classed as an historic site.
Lutley Lane towards the farm, is only able to be used by farm tractors and would not be suitable for any wider vehicles unless hedgerows were removed from adjoining land.
Please re think your policy ! There are many brownfield sites that could be used instead .

Comment

Representation ID: 16498

Received: 06/10/2021

Respondent: Ms Imogen Mortiboys

I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.

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, I believe that due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.

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 is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations

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'. 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 has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, "green belts do not recognise… the community value of land" (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply 'green belt'. This site should therefore be granted a Local Green Space designation.

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. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night There are extensive views over local countryside, fields, woodland and distant hills The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8).

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: 16501

Received: 07/10/2021

Respondent: Ian and Marilyn Vanstone

Number of people: 2

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: 16522

Received: 11/10/2021

Respondent: Mrs Margaret Collins

If we continue to build on Green Belt land, where will it end? Before we know it we will be joined up to Wolverhampton in one direction and Kidderminster in the other. Where will the children go to school? Doctors surgeries are overwhelmed and more traffic on the 449 road doesn't bare thinking about. It's murder to cross the 449 at the top of our street. Please think this through and look more closely at other options.

Object

Representation ID: 16542

Received: 04/10/2021

Respondent: Mrs Margaret Harris

Congestion/ Pollution. State of roads - Heavy traffic - Wall Heath, Kingswinford Cross, High Oak, Wordsley/ Brierley Hill Road.
(Driving locally - stressful.) Audnum/ Bretell Lane. Stourbridge - Wall Heath.
Green spaces - Lack of healthy safe places to walk, exercise. Quality of life.
Hospitals/GPs/ school's - not enough doctors, beds in hospitals. Ambulances queueing or diverted.
Infrastructure - Investment amongst lowest in country after funds dedicated to HS2!
Employment - at present there are thousands of vacancies nationwide.
Air quality / climate change - a huge problem. Especially of concern increase in childhood asthma due to traffic and parking near schools.
Gov. figures for housing - totally unrealistic - already over developed - must be challenged. Cannot afford to lose these green spaces. Once built on - no going back.

Support

Representation ID: 16564

Received: 30/09/2021

Respondent: John Durnall

I support the Council’s continued protection of countryside at Lapal, Illey, Coombeswood, Uffmoor,
Hayley Green, Lutley and Foxcote, following a formal review of the Green Belt.
Circa 1989, Dudley Council, following a previous Green Belt review, improved the Public Rights of Way network in these areas, by working in collaboration with local volunteer groups. Following on from that, the Council promoted enjoyment of this countryside, by the public, for informal recreation. They supported the production of walk leaflets explaining the historic, landscape and
ecological significance of each area.
The Council even contributed £20,000 towards The Woodland Trust purchasing Uffmoor Wood, despite this being just outside the Borough Boundary and coming under Bromsgrove. In doing so, they appreciated the important relationship between this ancient coppice woodland and neighbouring farmland, including Tack Farm, which is the site of a former Anglo-Saxon mill (Notwic Mill).
This countryside, protected by Green Belt designation, is rich in history. At Lapal and Illey are the remains of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance. At Lutley we have a Conservation Area associated with historic Lutley Mill and the green lane that links it to the mediaeval hamlet of Lutley, which was once held by the Canons of Wolverhampton.
Foxcote, which forms the foreground setting of the Iron Age Fort on Wychbury Hill and historically is linked to it, is archaeologically rich with frequent finds of flint arrow heads, flint scrapers, axes and other tools. It was the site of ancient hunting summer camps, and, in part, this explains the wide scatter of historic ‘finds’.
The countryside, hereby defined, is important to people from far afield, and, within the wider landscape, encompasses the famed and beautiful Clent Hills, a major area of which is owned and managed by the National Trust. We must also consider the Hagley Hall Estate, which includes a major proportion of Wychbury Hill, the importance of which was acknowledged in the 18th Century, by George Lyttelton, in his creation of Hagley Park, which is now a Grade 1 Listed Garden. On Wychbury Hill are two significant ‘follies’ - The Temple of Theseus and The Obelisk, tastefully exploiting the landscape prominence of the hill and the presence of the fort.
The whole of this area, including that within Dudley Borough, is of regional importance as an amenity asset for the welfare of, and enjoyment by, a large population. It would be so simple to seriously damage the area with inappropriate developments and associated infrastructure.

Object

Representation ID: 16587

Received: 09/10/2021

Respondent: Mr Kevin James

COMMENT 5b: LGS APPLICATION FOR THE THREE FIELDS, STOURBRIDGE
Document: Draft Black Country Plan Site assessment Report... Appendix A - Dudley
<https://blackcountryplan.dudley.gov.uk/media/18569/comp_appendix-adudley.pdf?fbclid=IwAR0yuByEkO9Xceyrb8M1iE9bsrEn8HIse7jSHAsuBL96PkX9C6z76cgScP8>
Section: A-6 Sites Assessed for Local Green Space
Comment type: OBJECTION
I object to the following site not receiving a Local Green Space (LGS) Designation
• ID 10511*, The Three Fields, Norton, DY8 3LS
(*as so designated in the Draft Black Country Plan Site Assessment Report... p. 534).
for the following reasons:
• I believe that, due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.
• The 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 is
extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity, seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to
future generations.
• 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’. 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 has been used in the past for organised social activities and could be used
again for similar activities as well as by local schools and community groups in activities related to the local natural environment.
• 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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise… the
community value of land” (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘green belt’. This site should therefore be granted a Local Green Space designation.
• 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. It is
possible to enjoy sunrise and sunsets, and because of dark skies, the stars at night. There are extensive views over local countryside, fields, woodland and distant hills. The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and
protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise”, HMG 2019, para. 8).
• The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).
• In addition, the site, which abuts the ancient county boundary, may contain sub-surface archaeology relating to the Wollaston Ridge boundary dykes to the north (James, 2019a: 1–6).

Object

Representation ID: 16884

Received: 09/10/2021

Respondent: Jan Cox

Title of document: Draft Black Country Plan
To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley

Nature of comment: ‘Objection’

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, I believe that due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.

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 is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations

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'. 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 has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, "green belts do not recognise… the community value of land" (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply 'green belt'. This site should therefore be granted a Local Green Space designation.

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. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night There are extensive views over local countryside, fields, woodland and distant hills The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8).

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

Support

Representation ID: 16907

Received: 06/10/2021

Respondent: Ms Katrina Baker

Black Country Plan - Support for the Protection of Green Belt Around Halesowen
I support the Council’s continued protection of countryside at Lapal, Illey, Coombeswood, Uffmoor,
Hayley Green, Lutley and Foxcote, following a formal review of the Green Belt.
Circa 1989, Dudley Council, following a previous Green Belt review, improved the Public Rights of Way
network in these areas, by working in collaboration with local volunteer groups. Following on from
that, the Council promoted enjoyment of this countryside, by the public, for informal recreation. They
supported the production of walk leaflets explaining the historic, landscape and ecological significance
of each area.
The Council even contributed £20,000 towards The Woodland Trust purchasing Uffmoor Wood,
despite this being just outside the Borough Boundary and coming under Bromsgrove. In doing so, they
appreciated the important relationship between this ancient coppice woodland and neighbouring
farmland, including Tack Farm, which is the site of a former Anglo-Saxon mill (Notwic Mill).
This countryside, protected by Green Belt designation, is rich in history. At Lapal and Illey are the
remains of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance. At
Lutley we have a Conservation Area associated with historic Lutley Mill and the green lane that links it
to the mediaeval hamlet of Lutley, which was once held by the Canons of Wolverhampton. Foxcote,
which forms the foreground setting of the Iron Age Fort on Wychbury Hill and historically is linked to
it, is archaeologically rich with frequent finds of flint arrow heads, flint scrapers, axes and other tools.
It was the site of ancient hunting summer camps, and, in part, this explains the wide scatter of historic
‘finds’.
The countryside, hereby defined, is important to people from far afield, and, within the wider
landscape, encompasses the famed and beautiful Clent Hills, a major area of which is owned and
managed by the National Trust. We must also consider the Hagley Hall Estate, which includes a major
proportion of Wychbury Hill, the importance of which was acknowledged in the 18th Century, by
George Lyelton, in his creation of Hagley Park, which is now a Grade 1 Listed Garden. On Wychbury
Hill are two significant ‘follies’ - The Temple of Theseus and The Obelisk, tastefully exploiting the
landscape prominence of the hill and the presence of the fort.
The whole of this area, including that within Dudley Borough, is of regional importance as an amenity
asset for the welfare of, and enjoyment by, a large population. It would be so simple to seriously
damage the area with inappropriate developments and associated infrastructure.

Object

Representation ID: 16915

Received: 05/10/2021

Respondent: Darren Ford

Title of document: Draft Black Country Plan
To which part of document: 1: Sub-Areas and Site Allocations, A. Dudley

Nature of comment: ‘Objection’

I object to the allocation of the following four sites in the Draft Black Country Plan:
DUH206, Worcester Lane North, Stourbridge
DUH207, Worcester Lane Central, Stourbridge
DUH209, Worcester Lane South, Stourbridge.
DUH217, Grazing Land Wollaston Farm, Stourbridge.

I further object to the site ID 10511, The Three Fields, Norton, DY8 3LS not having been designated as a Local Green Space.

Reasons for objections:

Sites: DUH206, Worcester Lane North, Stourbridge
DUH207, Worcester Lane Central, Stourbridge
DUH209, Worcester Lane South, Stourbridge.
Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV. Strategic Priority 12 is to “protect sustain and enhance the quality of the built and historic environment”. See also Policy ENV5, p. 230. All three are green field sites with grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation, agricultural and nature conservation value” these sites should not be allocated.

Proximity to Site of Local Importance for Nature Conservation (SLINC): There is a nearby SLINC, as well as mature trees and hedgerows, and there is no sustainable mitigation for this.

Green Belt harm: I disagree with the Green RAG rating of low/moderate for Green Belt harm for these three sites. There would be no clearly “defensible boundary” to this development (Policy GB1, and para 3.16). Development would also encroach on the open countryside between Hagley and Pedmore, going against at least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another and, (c) safeguarding the countryside from encroachment.

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.

I object to the allocation of the above site for development on the following bases:

Public open space: The site is located within Community Forum 7 where there is a below-average quantity of open space. It was well-used by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it as a wildflower meadow.

Landscape sensitivity: This is a green belt, green field site which, although having no agricultural rating and defined as ‘urban’ falls within area S17 having high landscape sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be considered to constitute “significant planning constraints which cannot be mitigated” despite the high levels of housing land which the BCP is seeking to meet (Site Assessment Report).

Tranquillity: The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place are that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8). This site should be assessed for tranquillity and protected under Policy GB1 (4) on protecting tranquil areas.

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, I believe that due to the pressure on local authorities to release green belt land for development, sites which have particular significance and importance to the local community should be identified and protected by the additional designation of Local Green Space.

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 is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations

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'. 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 has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

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). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, "green belts do not recognise… the community value of land" (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply 'green belt'. This site should therefore be granted a Local Green Space designation.

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. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night There are extensive views over local countryside, fields, woodland and distant hills The dominant soundscape is that of birdsong. The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise” HMG 2019, para. 8).

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