A. Dudley

Object

Representation ID: 16920

Received: 11/10/2021

Respondent: Danielle Morris

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

Support

Representation ID: 16925

Received: 05/10/2021

Respondent: Mrs Jackie DiVito

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.

Support

Representation ID: 16927

Received: 06/10/2021

Respondent: Mrs Judi Lorrance

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: 16950

Received: 11/10/2021

Respondent: Kevan Mcdermott

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: 16973

Received: 08/10/2021

Respondent: Mrs Jacqueline Haden

I object to the changes as there are many derelict/abandoned factories/shops across the Black Country that could be developed for homes but instead it is an easier/cheaper option to use green belt. Builders want a blank canvas therefore do not want areas already abandoned.
The damage to wildlife and the enviroment will be substantial. The roads in this area are already congested /bottle necked/polluted. The ability to see a GP/Dentist /A&E is difficult enough without additional families.
I am referring to building on green belt in the Dudley area.

Object

Representation ID: 16993

Received: 07/10/2021

Respondent: Mark Prior

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)

Object

Representation ID: 17075

Received: 05/10/2021

Respondent: Matthew Yarnall

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: 17087

Received: 08/10/2021

Respondent: Mr Martin Parker

I would like to voice my very strong objection to any development or loss of green space in the Clockfields estate along with the other estate residents. We were advised against a communal purchase when the land went up for sale for £15k in 2011 on the basis that the council would protect it from any development. All the residents of the estate were fully assured the land would never be built on by the then councillor of the ward and former Dudley mayor, Pat Mar n, who organised the tree preservation order in the interests of the estate residents to protect all the trees including the Black Country Urban Forest planted in 2001. The land shows as green space on most maps and should be protected as per the council brownfield first policies. The campaign and opposition to building on the land has been supported by Mayor Andy Street, all the ward councillors (past and present) and our local MP Suzanne Webb.
Please can adequate and appropriate protection be placed on this green space as with other green spaces in the borough if brownfield sites are priori sed.

I would also like to support the proposed designation of the Corbett Meadow under Policy DSA4 as an Area of High Historic Landscape Value, also referenced under Policy ENV5

Object

Representation ID: 17089

Received: 11/10/2021

Respondent: Martin Deeley

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: 17137

Received: 10/10/2021

Respondent: Jane Stevens

[Three Fields, Norton -- LGS Designation]

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, 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 being in 'close proximity to the community it serves' (NPPF). The site is "demonstrably special to the local community", as evidence 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 for 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 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: 17208

Received: 11/10/2021

Respondent: Mrs Marlene Ingram

DUH045. 80 homes in park lane object doctors surgerys can't cope also not enough school places
and lyde green road has become very busy with cars and heavyweight traffic I think it would make
the traffic worse for us who live on the main road sorry had to send this way couldn't get on the bit
page.
DUH045. Also ment to put in my email every ones saying about the climate they will cut down all the beautiful tree on this site which run up to the park they have already started cutting the tree down what about the wild life that live there 80 homes is a lot on that small site will they cut in to homer hill estate causing more traffic on estate leading to lyde green (object)

Support

Representation ID: 17226

Received: 07/10/2021

Respondent: Mr John Miller

I generally support the plan, It is interesting that Dudley seems to have such a disproportionately large need for new houses compared to Sandwell & Wolverhampton. Perhaps Dudley is a better place to live!

Object

Representation ID: 17243

Received: 28/09/2021

Respondent: Nigel Smith

I wish to object to the Proposed development in Worcester Lane DY8/9
Based on society infrastructure overburdened.

Comment

Representation ID: 17255

Received: 04/10/2021

Respondent: Nicky Francis

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.
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.
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. It’s appreciated for its breathtaking views over the Black Country, and its secluded, private areas, quite different to the much larger fields overlooked by the farm and farm buildings to the south of Oldnall Road or the enclosing, towering treescape of Caslon Wood.
It’s claimed that there are exceptional circumstances now regarding the need for housing and commercial premises. I believe that there is no justification for removing the protection on greenbelt and greenfield land. It can never be replaced as a source of pleasure, and physical and mental wellbeing for the community. It is not sustainable to build on our countryside, resulting in loss of farmland, natural habitat for wild life, hedgerows and trees.
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 ci es 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 only will appear on the Black Country Plan website available for public viewing.

Object

Representation ID: 17257

Received: 11/10/2021

Respondent: Mr & Mrs John & Susan Howells

Number of people: 2

While we appreciate extra housing is required in the area we have the following concerns:
1. Infra-structure - what plans are in future for road expansion to cope with increased traffic around the proposed areas?
Similarly are there going to be an expansion in current medical facilities i.e. hospital expansion more GP and Health Clinincs put into operation. Education - expand existing schools or build new?
2. Green site v. Brown sites
Why are old industrial and unused industrial sites not being considered?
3. Cost
Who in the long term will be paying? what effect will it have on existing Dudley Council residents in their Council Tax Bills - how much on average will annual bills increase?

Object

Representation ID: 17273

Received: 08/10/2021

Respondent: John Teuwen

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).

Comment

Representation ID: 17284

Received: 05/10/2021

Respondent: Paul Allen

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.
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.
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. It’s appreciated for its breathtaking views over the Black Country, and its secluded, private areas, quite different to the much larger fields overlooked by the farm and farm buildings to the south of Oldnall Road or the enclosing, towering treescape of Caslon Wood.
It’s claimed that there are exceptional circumstances now regarding the need for housing and commercial premises. I believe that there is no justification for removing the protection on greenbelt and greenfield land. It can never be replaced as a source of pleasure, and physical and mental wellbeing for the community. It is not sustainable to build on our countryside, resulting in loss of farmland, natural habitat for wild life, hedgerows and trees.
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 ci es 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 only will appear on the Black Country Plan website available for public viewing.

Object

Representation ID: 17327

Received: 04/10/2021

Respondent: Mrs Pauline Albutt

Land at Worcester Lane, Stourbridge Pedmore and Stourbridge East and Norton

I am appalled at the prospect of further development of 115 homes at Worcester Lane (Code F). Access is already extremely precarious at the adjoining roads - Redlake Road and Racecourse Lane having to pass over a very narrow bridge and further housing together with cars could make it a death trap. It will also increase journey times due to volume of traffic. I also hold the opinion that brown belt sites should be utilised first and foremost.

Comment

Representation ID: 17504

Received: 11/10/2021

Respondent: Kinver Parish Council

In general, we welcome the Local Plan, which sets out a planning framework for the entire Black Country. We support most of the policies relevant to rural areas such as Kinver and the edge of the Black Country, but do have reservations about some of the proposed allocations and potential policy implications in the wider area. Our concerns are set out in this letter.

As the neighbourhood plan qualifying body for Kinver Parish Council, we have embarked on the preparation of a neighbourhood plan. There is clearly a requirement for the local planning authority and neighbourhood plan body
to work in close liaison. The comments contained in this representation have been prepared against that context.

Object

Representation ID: 17949

Received: 13/12/2021

Respondent: Mr Matthew Haddon

Dudley Council has already stolen valuable recreational space which it classed as "windfall" from our estate and any further building on green space should be strictly limited. The land at Crowle Drive, Lye was already in use by the local community and local church for recreational purposes , but was deemed "windfall" basically because the council knew very well that it is difficult to stop them building on land without court action. The council just stole this land from the local community who now have no or little green space within the estate and the local children now have limited play areas within the estate, pretty much none.This is blatant theft of recreational space.
Councils are also legally required to try to protect green space. Although the council promised to improve nearby land it has failed to do anything.
The guidelines regarding housing density are in my opinion wrong, there should be less housing per hectare or unit.
Wolverhampton council has already expressed concern that they cannot meet housing needs as there is limited space available in the borough. I'm pretty sure that this would also apply to Dudley although there are still some brown sites available for development. There are numerous sites which have been left derelict for many years in fact without any development.
Any future development should be carefully considered as to existing use and future use which avoids stealing land which is in use as recreational space which goes against government guidelines anyway.
Green belt should remain as green belt and not be encroached upon as it has been at Hagley even though there were large amounts of objections from the local residents. Also the government should stop overriding planning decisions in favour of builders.
Local resident's views should always be prioritised and not just bulldozed over which seems to happen more often than not.
Brown sites should be prioritised and although Dudley claim to be doing this the building at Crowle Drive proves otherwise, as this land was already in use as recreational space....the only recreational space within the estate of any significance, which has now been stolen by an uncaring council who obviously have little time for younger people.
The planning department need to assess any building opportunities and ensure that the best use of the available space is being used without too much density of housing.
All housing should have frontages and parking areas as we still rely very much on cars, but as people start to make better use of public transport this could be reviewed.
There are properties such as the buildings near the rear of the Ryemarket in Stourbridge which should be returned to habitable properties without councillors suggesting that they be made into numerous flats with 2 parking spaces which is ridiculous. If councillors cannot come up with sensible ideas then they shouldn't be councillors.
There are too many councillors in the borough they should be reduced, preferably culled!!!!
Why has the leaflet only just been delivered when the review has been ongoing for 2 weeks ???

Comment

Representation ID: 17967

Received: 11/10/2021

Respondent: Miss Margaret Jarvis

Personal response to council proposals for all areas indicated have been given considerable thought and I honestly believe are unbiased, free of any political preference and are based on nearly 40 years of unbroken service to education across all levels and age groups and a personal similar background within the Midlands area that suffered from heavy constant boming raids throughout the second world war with its varied ills. Life lessons learned and fantastic understanding support from remarkably committed parents and teachers. Experiencing this for this second time enabled children like me and my five siblings achieve our talent potential and much was to be expected in return.

1) Planning proposals should be based on open accountability, sound management, over sight non political agreement, practical community involvement, security and public safety.

2) Renovating, restoring the shopping, commercial creative social and accommodation Dudley from town centre and immediate adjacent areas to encourage to be part of and enjoy visits and help the economy of the town. Reclaiming the parks and support voluntary groups utilising recent retirees and redundant skilled works to build play areas, seating in quiet places, replanting etc - basic materials and professionally skilled supervision provided by the council.
Roads and streets leading into town and connected suburbs to be enhanced to make an attractive destination to visitors from other regions etc.

3. Upgrading existing buildings and imposing the inclusion of responsibility for acceptable shop facades suitable to good design and historic emblance maintenance of clean facades, windows, doorways, litter, good decorative window displays, interior decor and layout - possibly handing boxes etc with the help from Chamber of commerce, commercial enterprises and local societies/ schools.
Council spreading varied enterprises - avoiding clusters of similar range of goods fast food outlets, cafes, cheap outlets, estate agents, charity shops. Balance supermarket with good butchers, fish mongers, bakeries, stationers / bookshops, drapers, cheese shops, health foods, vegetarian, craft/ art supplies etc. Group tea shops / cafes in attractive spaces in high street, precincts - the (relatively) new at the top of the town which could also accommodate majority of charity shops and a walk in health centre which includes at various times and days GP nurse, minor treatments simple surgery etc chiropody, dentist, information / advice (council input), citizens advice - shop reglons and any (if existing) upper rooms. Commercial/ traders would pay usual rental and agree to same responsible requirements and the rest of the main hubs market should restore life to original fruit/ veg/ flower, plant/ curtain and dress fabrics etc. Good quality at competitive price can hold their own with larger concerns.

4) Empty property, above shops, unlet private rentals, existing council offices/ buildings no longer in use could become 1/2 bedroom studio flat or apartments for young couples, single parents (according to number and needs of the children), elderly couples, rehabitated, homeless and those with special needs with appropriate on going support and support personal living on site.

5) Existing schools renovated, updated - expanded (where needed and where possible) within an attractive environment which enables practical addition to the required curriculum and ethos of the school. Establish links with other schools across age levels for use of skills/ instruction / sharing facilities and opportunities to understand / experience future schooling. Encourage input practice periods - mentoring - sharing skills - visits to 'academy' schools colleges graduate year students so that they too can see the possibilities of the teaching profession. This would I believe, encourage good/outstanding teachers to the area, raise the level of learning, life skills, social responsibility, self confidence and discipline. Parents should be actively engaged as they I'm sure, would respond to reform and all these opportunities would be available to children, regardless of race creed colour or gender. All too often in the past it was failing to consider the possibility that even the most disadvantaged have ability, and aspirations and can reach beyond their own hopes and expectations.

6) School space and facilities are underused, 4:30-6:30, 7-9pm and in even day time slots could be utilised by recent leavers teenage unnames / parents elderly and groups and societies. Lots of these units provide their own leaders/ teachers. Share responsibility for organising, arranging, material provision and teaching input and each co exist and even inspire young steps to try 'old' skills the classes etc. Reading groups, photography, creative writing, life skills 'health and exercise, simple cooking, creative arts knit and natter, seeds, potting on, window boxes and hanging baskets, literacy, numeracy, speech (elecution, verbal communication, public speaking), restyle and recyle / wardrobes and household furnishing, singing and simple woodwork and horse painting. The list is endless - there a a lot of untapped skills outage and soon to be graduates and the unemployed graduates - in every area on the list could volunteer and get experience to add to CV I'm sure those of us who are decluttering/ house clearing / down sizing / keen gardeners would be happy to donate any items that would be of use - both sides would benefit. Charity shops could give unwanted clothing that could be adapted or unpicked unravelled and reused. It must not be needed by donors and a way of unloading rubbish !!

7. Finally society and safety - cctv, visible policing and efficient / swift response, honest application of law and order / how tolerance of abuse assault, bullying, intimidation, theft and burglary etc. Support and recognition of the result of community pride and engagement, in response to provision of council commitment.

All of the above applies to all the areas that make up the Dudley region; the council should not settle for the soft option of settling for the few existing green sites (bearing in mind government policy on the greening, tree planting to promote clean air, carbon, climate problems, and should look to obtain ful sites and inappropriate scrap/ waste sites created by unscrupulous traders.

My apologies for the length but age and its attendant ills have diminished respect and affection for the region and the belief that it isn't too late to build a better world with the combined unbiased help of council and community.

Thank you for affording me the opportunity to respond, and in anticipation of your patience and willingness to read it.

Object

Representation ID: 18001

Received: 11/10/2021

Respondent: Ms Mary Dudley

New homes - Dudley borough

- Green belt release to accommodate new housing
- Kingswinford Neighbour growth area

The current road infrastructure is insufficient to support the volume of traffic to use them. The main roads from Kingswinford into the Black Country are gridlocked in the mornings and evenings. Travelling from Kingswinford to Russells Hall hospital, a distance of two miles can take 20-40 minutes at peak times. An additional 863 homes would add a great deal of additional traffic causing total gridlock. In addition the pollution levels resulting from idling engines adds considerably to climate change problems. An key route taking traffic from the proposed n'hood growth area towards Stourbridge would take traffic along the High Street at Wordsleywhich is already on eof the most polluted in Borough.

Healthcare services, in particular GP's and dentists already have long waiting lists in the Kingswinford area, additional homes would only compound the problems.

Object

Representation ID: 18106

Received: 06/10/2021

Respondent: Mr Philip Cartwright

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: 18142

Received: 11/10/2021

Respondent: Mr Tracy 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. I work in Cradley Heath, a 5 mile journey which takes me a minimum 40 minutes each way already. This traffic is trying to get out of Kingswinford and Wordsley. The roads can’t cope with more traffic.
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: 18154

Received: 11/10/2021

Respondent: Mrs Valerie Bloomer

I object to the application for Local Green Space designation being refused to The Three Fields, Norton, DY8 3LS, Site ID 10511, as it meets all of Part A criteria (NPPF) and two of the Part B criteria for beauty and recreation. It is also a popular but tranquil and peaceful area, thereby fulfilling the criteria for designation. It therefore qualifies for the extra level of protection that entails because of its special importance to the surrounding community. Its greenbelt status does not reflect that particular significance and local importance, which if lost is not possible to recreate;

Object

Representation ID: 18155

Received: 11/10/2021

Respondent: Mrs Valerie Bloomer

Site ID 10522 The Flint Field, Land North of Oldnall Road, Cradley & Wollescote. I object to this site not receiving Local Green Space designation. 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; the flat farmed area is only 8 ha, the full site is approx 13.8 ha while Foxcote Farm to the south is 64.2 ha. A visit there for recreation is a different experience to visiting anywhere else in the locality, which is demonstrated by its popularity, organised walks, and the support of the Black Country Society. It’s appreciated for its breathtaking views over the Black Country, its network of paths, and secluded, private areas, quite different to the much larger fields to the south of Oldnall Road, with for the mostpart only one popular right of way, overlooked by the farm and farm buildings. It is also totally different to the enclosing, towering treescape of nearby Caslon Wood. Because of the position of the site on a ridge, going elsewhere in the community for recreation by those living close to it involves walking down/up steep slopes and crossing very busy main roads with high pollution levels. That is not viable when seeking the pleasure recreational walking/running brings, and it also impacts in varying ways on different age groups regarding levels of fitness, ability to cross busy roads alone etc. LGS designation would give the extra level of protection the site deserves in that the views of the local community would also need to be taken into account when considering any development proposals on it.

Support

Representation ID: 18158

Received: 11/10/2021

Respondent: Mrs Valerie Bloomer

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.


I support the protection of greenbelt and green spaces from development of any kind. It's claimed that there are exceptional circumstances now regarding the need for housing and commercial premises. I believe there is no justification for removing the protection on greenbelt and greenfield land. It can never be replaced as a source of pleasure and well-being for the community. It is not sustainable to build on our countryside, resulting in loss of farmland, natural habitat for wild life, hedgerows and trees, and thereby causing irreversible damage to the ecosystems that our world and its peoples depend on.

Support

Representation ID: 18200

Received: 05/10/2021

Respondent: Mr Alec Stevens

Re: 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.

Support

Representation ID: 18226

Received: 04/10/2021

Respondent: Mr Tom Freer

Support for Protection of Green Belt

The Black Country Plan - Support for Protection of Green Belt
I support Dudley Council in its proposal to protect the greenbelt at Halesowen (Illey,
Lapal, Uffmoor, Hayley Green, Coombeswood), Lutley, and Foxcote.
These areas provide an escape from every day stress within the urban environment and
have proved themselves invaluable during the Covid crisis. They are important
aesthetically, physically and for mental well being. They are our ‘life's blood’, breathing
oxygen into the atmosphere and absorbing CO2.
Over many years, the public have been encouraged by Dudley Council’s positive
approach to the landscape, historic and informal recreational value of this countryside. It
is appreciated that the footpaths were restored and way marked in countryside
improvement projects, to encourage public use and enjoyment. There is often a false
perception that the Black Country is totally urbanised and industrialised. However this
countryside perfectly integrates into North Worcestershire and provides the foreground
to the Clent Hills, historic Hagley Park and various villages. It is living proof that the
perception of total urbanisation is incorrect. This relationship, which is finely balanced,
would be vulnerable to inappropriate development with roads and associated
infrastructure. I reiterate that the Council’s protection of this countryside, following
various studies, is fully supported.

Object

Representation ID: 18348

Received: 05/10/2021

Respondent: Richard Vere

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.