Development Allocations

Showing comments and forms 61 to 90 of 332

Object

Draft Black Country Plan

Representation ID: 14391

Received: 19/09/2021

Respondent: Gill Mitchell

Representation Summary:

I object to the proposed building on Wood Hayes Lane/Wood end road for the following reasons:
1. Loss of valuable green space to take air and exercise
2. Increase in road traffic and strain on infrastructure
3. Loss of green space in an already extremely built up area
4. Increased air and visual and noise pollution
5. Negative impact on mental health and well being of existing residents
6. Increased traffic causing safety issues for young children on already overloaded roads
7. Strain on local schools which are already over capacity
8. Increased traffic causing additional road congestion and road damage

Object

Draft Black Country Plan

Representation ID: 14392

Received: 19/09/2021

Respondent: David Joynson

Representation Summary:

I object to the proposed building on Wood Hayes Lane/Wood end road for the following reasons:
1. Loss of valuable green space to take air and exercise
2. Increase in road traffic and strain on infrastructure
3. Loss of green space in an already extremely built up area
4. Increased air and visual and noise pollution
5. Negative impact on mental health and well being of existing residents
6. Increased traffic causing safety issues for young children on already overloaded roads
7. Strain on local schools which are already over capacity
8. Increased traffic causing additional road congestion and road damage

Object

Draft Black Country Plan

Representation ID: 14402

Received: 07/10/2021

Respondent: Ms Suzanne Brown

Representation Summary:

As a resident of [text redacted] I COMPLETELY disagree on using this Site [St Luke's School] for housing. I have lived at this address for [text redacted] and over the years the traffic, noise pollution, light pollution has worsened and become very hard to deal with. You have given us no timescale for us residents to appeal from this only receiving the letter only giving us 5 DAYS to respond!
Our street simple can NOT cope with any more traffic and noise disturbances than what we already have. This opposed plan has
Deeply upset me, especially when I am the [text redacted] and I feel I am effected the most by the school and everything else around it!
I feel you are not considering how busy our street already is and simply do not care about the residents on this street that have to
Endure this on a day-to-day basis.
I strongly disagree with housing to be going ahead on the school playing fields [text redacted] and leave it as green land!

Object

Draft Black Country Plan

Representation ID: 14403

Received: 17/09/2021

Respondent: Amy-Leigh Goodier

Representation Summary:

I object to the proposed planning on the green belt within Wolverhampton, specifically the Wood Hayes Road- Essington development. I see no reason to release the green belt for development when there are many other viable options that where a new development would improve local areas such as on brown land (old industrial estates, wastelands) rather then destroying a valuable and necessary green belt. That green belt is the breathing space between Essington and Wednesfield.

Object

Draft Black Country Plan

Representation ID: 14406

Received: 19/09/2021

Respondent: Amanda Hoadley

Representation Summary:

I live in Wednesfield in [location disclosed] opposite the open fields which when I brought the property was told that it was greenbelt land and would never be built on.

I strongly appose the building site for Wolverhamtpon on Wood Hayes Road, as this will start to inpose on the land that I currently live across.

The roads are already conjested at peak times, and although I understand that new houses are needed to house people, I think there must be more open sites that can be used. The wildlife is lovely to watch and preserve and people who buy houses across the open fields do so with the purpose that they do not want to live in built up areas, with the chance that crime will go up, roads will be busier and you will lose alot of privacy.

Comment

Draft Black Country Plan

Representation ID: 14407

Received: 27/09/2021

Respondent: Colin Turner

Representation Summary:

We are being choked with poisonous gases from all sources of transport, heating and cooling, etc.
We also need trees, plants, grasses etc., to clean the air that we are contaminating, to enable us to breathe. Smestow Valley Nature reserve has been dedicated to that purpose.
We cannot and will not accept this plan to destroy this very valuable air renewal location.
One of the reasons that it is there is because the railways were a very ‘dirty’mode of transport.
To sacrifice this very valuable scource of giving us clean air and reducing the number of cases of lung disease for the sake of a few ‘privileged’ people, should not and cannot be allowed.
To this end I will (although it has not normally been my nature) will fight this plan tooth and nail to prevent it happening.

Comment

Draft Black Country Plan

Representation ID: 14408

Received: 25/09/2021

Respondent: Caroline Fereday

Representation Summary:

Hi,

I just have to let you know how disgusted and horrified I am at the plans to build 14 luxury houses on the precious green belt area at Swestow valley.

There are so few areas of such special unspoilt beauty in Wolverhampton as this strip of land which is a nature reserve full of many species of birds and mammals and reptiles. I am by no means an expert on wildlife and I am sure others are more informed on this topic but I do regularly walk through this nature reserve and appreciate being so close to nature without having to get in my car and drive somewhere which would pollute the environment. During lockdowns I walked daily through this nature reserve and still do 1-4 times per week.

There are many brown belt areas in the city which would be much better suited to yet another housing development. Even in terms of green belt areas there are surely other spaces that are not well-established nature reserves that would be more suitable for this type of development.

I feel very strongly that this particular development should not go ahead because of the unnecessary threat to wildlife species in the area and because so many people, including me and my family, are using the area for much-needed recreation and for our physical and mental health.

I sincerely hope you will listen to the passionate opposition to this development from I am sure many many people - as well as also understanding that there will be many more people who rely on being able to escape the stresses of city life by going to this nature reserve but who may not be able to communicate this, such as people struggling with their mental health at this stressful time (due to covid, job losses, relationship breakdowns etc) and those with other disabilities.

Sincerely,

Caroline Fereday

Comment

Draft Black Country Plan

Representation ID: 14409

Received: 29/09/2021

Respondent: Carol Waldron

Representation Summary:

I strongly protest to the building of houses in this much needed and used green space in the centre of Wolverhampton please lodge my protest against this as far as I am concerned this is not a brownfield site and should never be classed as one.

Object

Draft Black Country Plan

Representation ID: 14410

Received: 06/10/2021

Respondent: Miss Heather Rous

Representation Summary:

I would like to register my strong objection to the WEC being included for housing development in the Black Country Plan. I am agast that such a treasure trove of biodiversity may be ruined

Comment

Draft Black Country Plan

Representation ID: 14413

Received: 27/09/2021

Respondent: Cara Baker

Representation Summary:

I am writing in opposition to plans to build houses on the Wolverhampton Environmental Centre in Smestow Valley. This is green belt space with insects and wildlife that must be protected. This goes totally against what we need to do due to climate change. We need much more green space in order to beat climate change and should definitely not be reducing it. There is plenty of brown field land that can be used for housing.

Object

Draft Black Country Plan

Representation ID: 14417

Received: 29/09/2021

Respondent: Adrian Jones

Representation Summary:

To whom it may concern,

This email is to advise you that I strongly object to any proposed developments of the WEC site on Westarce Crescent, Wolverhampton.

The proposed development is set out in the Black Country Plan on page 608, ref WOH274 WTNA. WEC Smestow Valley Wolverhampton. Not only will this have a detrimental impact on wildlife and protected species it will also have an impact on Mental Health and wellbeing of many local people in the area.

This is an unnecessary and ill thought out plan and could be improved by utilising other areas that are better suited to the local authorities priorities.

Comment

Draft Black Country Plan

Representation ID: 14418

Received: 27/09/2021

Respondent: Alison Carminke

Representation Summary:

I am writing to express my opposition to the proposal to build new houses on the nature reserve at Smestow Valley. I am very surprised to consider that the Council is considering building on an area which hosts a range of wildlife species, including several different kinds of bats – I understand these are at particular risk in the UK.

Object

Draft Black Country Plan

Representation ID: 14419

Received: 26/09/2021

Respondent: Katie Lavelle

Representation Summary:

I am emailing to lodge my objection to the plan to build housing on this site.

I only discovered the Smestow Nature Reserve about 3 years ago after buying a dog. I have met so many new people when walking the dog and we all love to say hello and pass the time of day. To me this one small gesture goes a long way as I find we live busy and hectic lives. There is plenty of space for everyone and so much time and money has been spent making beautiful walkways through the reserve. You can escape and hear all the beautiful sounds of nature, which for me is so valuable, as an nhs worker working through the pandemic, seeing the loss and devastation the pandemic has done. For me before my shift I will walk the dog, stop at the ponds and take time to appreciate the unspoilt surroundings. It means so much to my mental and physical health. If this is taken away I will have to travel elsewhere as I cannot walk the Staffordshire Railway Walk as I feel the amount of cyclists coming at speed is so dangerous, in fact my dog was hit by a cyclist going too fast. We have a Facebook group and on it you will see photos of all the wildlife you can see and it makes you think that you don’t have to go far to appreciate the finer things in life to make it positive, people are so passionate about its upkeep.

Object

Draft Black Country Plan

Representation ID: 14420

Received: 28/09/2021

Respondent: Alan Bowell

Representation Summary:

I wish to register my objection the the building of 'luxury homes' on the nature reserve at Wolverhampton Environmental Centre in Smestow Valley nature reserve. This area is a vital piece of the area's natural environment and is enjoyed by many people looking for peace and a break from the hum drum!

We hope that this development can be stopped for the benefit of the many people who visit the reserve.

Object

Draft Black Country Plan

Representation ID: 14421

Received: 25/09/2021

Respondent: Adrian Tobin

Representation Summary:

Having been made aware of the plan to build a substantial amount of homes on Nothycote Lane and Legs Lane I feel compelled to voice an objection.

Having been a resident of this area for 30 years (19 Kempthorne Avenue and then 24 Legs Lane) I am amongst a number of local people that feel this development would destroy the character of the area.

It is one of the few places left around here that is not stifled by buildings and is a very refreshing and attractive place to walk.

People from out of the area often visit and help support local business, the café at the farm and local shops and fuel stations.

I work in Telford and often recommend a visit to the area and people that have visited have also included a visit to Moseley Old Hall.

This development would spoil the area. I understand the need for housing but this development is too big for this area especially when you consider there are other areas of town that could take a share.

Object

Draft Black Country Plan

Representation ID: 14430

Received: 09/10/2021

Respondent: Alison George

Representation Summary:

RE: Black Country Plan-Page 608
Ref:WOH274 WTNA,
WEC Smetstow Valley,
Wolverhampton.
I wish to object to the proposed housing development on this site for the following reasons:
1. The site provides a wonderful open space for the local community.
2. It is a potential site for nature conservation.
3. It has an incredible amount of wildlife, flora and fauna.
4. At a time when global warming is accelerating at such a phenomenal pace, green spaces, such as Smetstow Valley , is invaluable in contributing towards lowering the Earth’s increasing temperatures.
It is part of the lungs of Wolverhampton !

Comment

Draft Black Country Plan

Representation ID: 14436

Received: 06/10/2021

Respondent: Alice Lane

Representation Summary:

I would like to make a comment regarding the possibility of building homes on our WEC Smestow valley nature reserve.

This action would be devastating and damaging to our wonderful fauna and flora here and would ruin the enjoyment for me of spending time around this reserve.

Black country plan page 608 ref no WOH274 WTNA WEC Smestow Valley Wolverhampton.

Object

Draft Black Country Plan

Representation ID: 14478

Received: 11/10/2021

Respondent: John Rowley

Representation Summary:

1. Re Site Allocation WHO 274 WTNA
The former Wolverhampton Environment Centre (the WEC) appears in Table 43 (Site allocations) page 608 as a site for potential development. The WEC should never have been added to the draft Black Country Plan (BCP).
The proposal to build houses on the WEC was controversial when it was first mooted in 2015. It is contrary to the Local Neighbourhood Plan of 2014. National, regional and local planning regulations had to be manipulated or ignored for it to be recommended to WCC Planning Committee of 20th March 2018.
Site allocation WHO 274 WTNA the WEC was included in the draft BCP because ‘Outline planning permission had been previously granted for 14 houses on the WEC site. Permission lapsed in the face of concerted public opposition in April 2021.
The proposal to build fourteen houses in the middle of the Smestow Valley Local Nature Reserve conflicts with the concept of climate change [CC1] in the draft BCP, with protection for wildlife[ENVI-9], with desire for exercise and recreation in a traffic-free environment[CC4, ENV8-9, CSP1, HW1, CEN5, TRAN 1-8] as well as with the principles of sustainable transport [TRAN1-8] and a diverse economy [EMP1-5].
Abuse of Local Democracy
The Tettenhall Neighbourhood Plan (TNP) had been passed in a local referendum in 2014 by 92% of the voters of the two wards. TNP policy 6 explicitly excluded commercial or residential development on the WEC yet outline permission was granted for houses.
The policy to exclude housing on the WEC could have been changed by evidence of ‘Community Involvement and Consultation’, as set out in TNP policy 7.
A form of ‘consultation’ was conducted in 2016-17. It was an embarrassment. It failed to meet the high standards required by Policy 7. An external consultant persuaded two small unrepresentative local associations to facilitate five public meetings. The lack of transparency was glaring. Residents were denied knowledge of the real reasons for the proposal – the intention, it transpires, was to sell 14 houses in a desirable location, the Local Nature Reserve, to raise money to build social housing elsewhere in the city, but this was never made clear to residents.
The essential question, ‘Do you want houses to be built on the WEC?’ was never put to any of the five meetings.
A total of forty-eight residents out of some 30,000 in the two wards attended the five ‘Engagement’ meetings. They were not persuaded to vote for the proposal. Furthermore, a 2,885 people in the autumn of 2017 signed a petition against the proposal for housing on the WEC. The Planning Committee of March 2018 ignored both the detailed objections to the application and the weight of public opposition to the proposal. Outline planning permission was granted.
Abuse of the National Planning Policy Framework
A key element in the Report to Committee was the claim that the WEC was a previously developed site (brownfield land) which allowed an exception to Green Belt policy. This interpretation of National Planning Policy Framework (NPPF) on the Green Belt turned out to be highly questionable.
“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open”. (NPPF paragraph 79 / para.133 in 2019 version)
The Smestow Valley Local Nature Reserve is in the Green Belt. The BBC Local Sites Report of 26th July 2015 states that WEC is essentially part of the Smestow Valley Local Nature Reserve (LNR). It is surrounded on all sides by the LNR. If houses are built on the WEC, the nearest urban area the Finchfield estate will spread into the Green Belt. The Green Belt will no longer be open.
In their Design & Access Statement for 18/00078/OUT the developer claimed that ‘the WEC is surrounded on three sides (sic) by the LNR, and on the fourth by houses’. This is incorrect. The former GWR line, purchased by WCC on 1970s and incorporated into the LNR in 1998, clearly separates the WEC from houses on Westacre Crescent, in Finchfield.
Use of Ambiguity : ‘Agricultural’ of ‘Brownfield’
The 2018 Report to the Planning Committee repeated the same grammatical / topographical error, and added a number of its own. It asserted that the WEC is ‘previously developed site (brownfield land)’ and therefore an exception to Green Belt policy was allowed in paragraph 80.5 of the NPPF.
However, this assertion is surely incorrect. The WEC site had four large glasshouses, a brick bungalow and two small ancillary buildings for horticultural/agricultural use. In the TNP (2014) the WEC is designated for agricultural use. It had not been identified for development in any strategic policy. Wolverhampton’s Unitary Development Plan paras.8.3.1 and 8.4.5 explicitly exclude the WEC from development. By March 2018 there had been no formal change of use from the ‘agricultural’ designation.
Although in September 2017 there was an application,17/01141/FUL, entitled ‘Change of Use’. It changed little. It merely moved 90% of the WEC from an enclosed site to ‘a public open space and nature reserve’. The application did not change the designation of the WEC from agricultural to Brownfield.
The WEC was not in the Black Country Core Strategy as a site for potential development. It was not on the National Land Use Database. When Wolverhampton’s Brownfield Land Register (BLR) replaced the national register of land for development in April 2019 it showed the WEC to be a site for development in 2016. This appears to have been added retrospectively, perhaps to cover up an administrative omission.
Whatever the reason for the late addition to the BLR, the public was unaware that a change had been made. No ‘CHANGE of USE’ notices were posted on the gates of the WEC. No formal application was made in 2016 for a change of use.
Private developers, unless they were ‘in the know’, would also have been ignorant of the change, since the WEC was not on the National Land Use Database, the official national Brownfield Register at the time.
WVLiving, CWC’s development arm, should have known of the change of use. The implications of the lack of transparency about the change must be a cause for concern. Sandwell is doubtless not the only council in the Black Country where slack planning procedure allows corrupt practice to happen (report in Express & Star 11th October 2021)
It was not until 2019 that members of the public were aware that the WEC had been officially designated as a ‘brownfield site for development.’ Even in 2019 the information was given reluctantly; it had to be gained by a FOI request.
Residents were denied an opportunity to challenge the change of use, to hold the council to account.
Strangely, even the council’s developer, WVLiving, seemed unaware that the site had been declared brownfield in 2016. Or perhaps WVLiving was unclear about the definition of ‘brownfield’?
The Design & Access Statement for 18/00078/OUT claimed that a brownfield site would be created by demolishing the four glass-houses, after outline planning permission had been granted!
Outline planning permission should never have been granted in 2018. The attempt by WVLiving, the council’s development arm, to build the 14 houses in the next three years exposed apparent collusion with the planning department. This raised public awareness of the travesty of the planning process and the threat to the Local Nature Reserve. It aroused wide spread opposition to the proposal for houses in the middle of the city’s only local nature reserve and, positively, a wider realisation of how much of an asset the WEC is as a green space.
BCP Climate Change Adaptation and Mitigation. (Page 262)
“Factors which may lead to the exacerbation of climate change (through the generation of more greenhouse gases) must be avoided (e.g. pollution, habitat fragmentation, loss of biodiversity) and the natural environment’s resilience to change should be protected.”
Wolverhampton has the least green space of any city of comparable size in the UK. Cllr Ian Brookfield, CWC’s Council Leader, acknowledges that only 11% of Wolverhampton is green space. South Staffs Spatial Housing Strategy has identified land in the Smestow Valley for housing. This will close off the Local Nature reserve from open country to which it is now connected. Preservation of what little green space the city still has is important in the challenge to mitigate climate change.
The WEC – formal and informal education about climate change and the natural environment
Protection of the Smestow Valley Local Nature Reserve (LNR) will help Wolverhampton to learn formally and informally how to adapt to climate change. The WEC could be a Field Study area for the city, Black Country and south Staffordshire. Ten schools and a college are within easy walking distance of the LNR; many more can reach it by public transport and by green and blue routes.
The WEC should be an information resource for visitors, community and educational groups.
The environmental reasons for keeping the WEC as a green space, for leaving the LNR intact include :
• [text redacted]
• bio-diversity of the site. For example, a shallow wetland has emerged.
• Smestow Valley is a wildlife corridor, a migratory route for animals and birds to rest and recover, while by-passing the West Midlands conurbation
• [text redacted]

BCP Linkages between Health and the Natural Environment
The Black Country has lower rates of physical activity and higher rates of obesity than most to the UK. [HW1 - 5.10 page 73] Poor air quality has a detrimental effect on health. There are lower rates of both life expectancy and healthy life expectancy than the rest of England. There are higher rates of multiple deprivation, of children living in poverty and of unemployment than the rest of England, as well as some of the poorest academic achievement of school leavers. All contribute to poor health and are influenced by the built and natural environment. [HW1, HW3 pages 73 and 84]
The WEC – Promotion of Health and Wellbeing
“Properly designed and well-located open spaces will help mitigate flood risk, provide space for wildlife and encourage informal recreation for local people.” [CSP4 page 42]
The WEC and the LNR are commercially free and accessible to everyone.
“Key transport corridors will be prioritised through the delivery of infrastructure to support active travel (walking, cycling)” [TRAN1 page 177]
“Creating an environment that encourages sustainable travel requires new developments to link to existing walking and cycling networks. The links should be safe, direct and not impeded by infrastructure provided for other forms of transport.” [TRAN5 page 191]
The WEC and the wider LNR ..
• are accessible to all,
• encourage social interaction – some of the most deprived and the wealthiest areas of the city border the LNR
• manage the negative effects of traffic by keeping vehicular traffic out,
• contain allotments and leisure opportunities etcetera beneficial to physical and mental well-being.

The WEC – Promotion of improved Air Quality [CC4 pages 277 – 278]
“Air pollution is the top environmental risk to human health in the UK”(DEFRA 2019). The main cause of poor air quality in the Black Country is traffic.
The Smestow Valley is called Wolverhampton’s ‘green lung’. It is relatively free of traffic. It is less than two miles from the city centre. Cleaner air helps reduce work place absence. It creates and sustains a pleasant and attractive living and working environment, which is more likely to encourage growth and investment in the area.
• Housing and traffic in the WEC will affect the air quality of the site and of the Railway Walk
• Housing and traffic will make the LNR a less desirable place to visit and Wolverhampton will be a less desirable place to live and work.
The WEC - Increased efficiency and resilience to Climate Change [CC1 pages 265 - 267]
The former line of the GWR is now a Railway Walk, listed in the Guardian among the ‘Top Ten Railway Walks in Britain.‘ The Railway Walk links the local Tier 3 Centres of Compton - Finchfield - Castlecroft; it reduces the need to use a car. Creation of a PRoW from Wightwick Mill Lock to the Bridgnorth Road would open up pedestrian/ access to Tettenhall Wood as well.
The Railway Walk is a popular commuting route from South Staffs to the i54 and to the city centre. It links up with National Cycle route 81, the tow paths of the Staffs –Worcester and Birmingham Canal Navigation and is part of a 30 mile circular cycle route through Wolverhampton – Dudley –south Staffordshire.
• Housing on the WEC will interrupt the traffic-free Railway Walk.
• Housing in the WEC will also set a precedent for housing elsewhere in the LNR.
The WEC – Mitigating flood risk to adapt to Climate Change [CC5 & CC6 pages 284 -286, 288]
“To pass the Exception Test, developments will need to:
8 a) provide a demonstrable benefit to the wider sustainability of the area. Matters such as biodiversity, green infrastructure, historic environment, climate change adaptation, flood risk, green energy, pollution, health and transport should be considered;” [CC5 page 284]

• In the case of the WEC, which is within the Green Belt and the LNR, this test should be more stringent than elsewhere because flooding will affect the Finchfield Brook, the Smestow and ultimately the River Stour and the Severn.

“8 b) detail the sustainability issues the development will address and how doing so will outweigh the flood risk concerns for the site;”
• Building on the WEC will affect a wetland and two pools [text redacted]
• Driveways to houses are often impermeable. Water runs off into drains and into the rivers.
• Water from a developed WEC will run off into the Finchfield Brook which is incapable of holding it at present without flooding.
• Permeable driveways would allow some rainwater to be absorbed by the ground, and refill aquifers, otherwise it will run into the Finchfield Brook, and cause flooding
“8 d) prove that the development can be achieved without increasing flood risk elsewhere and, where possible, will result in a reduced flood risk.”
• a difficult test to pass. Development on the WEC will result in increased flood risk, which will have an impact on places downstream.
2. Re Black Country Plan
The draft Black Country Plan builds on earlier planning regulations to give order and stability to future development. Regulation by Green Belt policy has protected our city from the flight from the centre which happened to American cities in the post-war period, until now.
Since compilation of the draft Plan began our high streets have emptied of shops, office blocks have emptied of staff. The Covid-19 pandemic has also accelerated public recognition of the benefits of clean air and green spaces. The Black Country Plan needs to be more radical to deal with these changes.
Conversion of city centre shops and offices to accommodation, cultural and leisure use must be encouraged. The challenge of climate change will encourage local shopping centres at the expense of the city centre. The challenge to reduce traffic pollution may encourage working from home. For these and many other reasons green spaces are likely to be invaluable for the immediate future.
I use ‘invaluable’ in the non-financial sense of the benefits of exercises, of the peace and tranquillity that green spaces bring. However, a financial value can be placed benefit from our green space of exercise etcetera. The Dasgupta Review published in February for the CO26 conference at Glasgow, analyses the ‘Economics of Biodiversity’. It will. I hope, encourage planners to consider the opportunity cost to the NHS, to Social Services, to Anti-Social Behaviour teams….., to society, of elimination of green spaces in our urban areas. Preservation of green space will save our city millions of pounds.
The draft BCP is not robust enough to protect the city’s natural environment from development.
1. CSP 2, on page 26, seeks to deliver growth and development by …..e) ‘Protecting the openness, integrity and function of the Black Country’s designated and retained Green Belt by resisting inappropriate development;’
This aim has been lifted word for word from the BCCS. It appears in similar form in Wolverhampton’s UDP, yet outline planning permission for an inappropriate development of 14 houses was nevertheless allowed on the former Wolverhampton Environment Centre (the WEC) in March 2018. [Table 43 ]
The definition of ‘exceptional circumstances’ in paragraph 3.14 of the Justification needs to be strengthened. It is difficult to see how building expensive houses on Green Belt land can be justified by the need to raise cash, as happened with the WEC, especially when there are brownfield sites and sites with previous planning permission waiting to be developed in Wolverhampton.
2. Paragraph 3.15 accepts that green spaces should be assessed…with regard to the wider area but I could find no consideration in the BCP of the impact South Staffs Spatial Housing Strategy will have on Wolverhampton’s Green Belt - context CSP , paragraph 3.49. We may be ‘surrounded’ by open countryside on north, west and south at the moment but not for ever.
Victorian planners had the vision to protect the green spaces of East and West Park before urbanisation enclosed them. We need stronger protection for all our green spaces, but especially for the Smestow Valley Local Nature Reserve, before the pressure for houses in SStaffs, over which voters and council taxpayers of Wolverhampton have little influence, becomes too great to be stopped.
The draft BCP recognises the benefit of open space, yet the WEC has been included in the Plan as a site for potential development. For example…..
“ENV 8 2) - Development that would reduce the overall value of the open space, sport and recreation network in the Black Country will be resisted.” BUT: Houses on the WEC will reduce the value of the wider Smestow Valley Local Nature Reserve
“10.111 The provision of high-quality open space to serve the ….improvement of existing open spaces is critical to the overall aims of urban renaissance and environmental transformation across the Black Country.” BUT: The WEC has a high level of bio-diversity, it has a rare shallow wetland and is home to a protected species [text redacted]. It is integral to the LNR.
“10.115 Greenways are defined as linear features of mostly open character, including paths through green spaces, canal corridors and disused railway lines (although some of these could be brought back into rail use in the future), which act as wildlife corridors and provide attractive and safe off-road links for pedestrians and cyclists. They form an important network throughout the Black Country but in some cases are of poor quality or are severed by other infrastructure or barriers. The restoration of towpaths, bridges, public rights of way and the creation of cycle and pedestrian links to enhance the greenway network will be sought through planning conditions and obligations, transportation funding, and the support of other organisations such as the Canal & River Trust. Blue infrastructure features such as rivers and streams also provide opportunities for physical activity. BUT: Voluntary organisations the BBC Wildlife Trust, WREN, Wildside Activity Centre, Finchfield Waterside Care work to improve habitat and the infrastructure of paths and streams of the LNR. This green network will be severed at the southern end by housing development on the WEC
“10.116 To promote healthy living, it is important that open space and sports facilities, and places that people visit every day such as shops and schools, are located and designed so that people are encouraged to walk or cycle to them from their homes.” Local centres at Compton, Finchfield and Castlecroft are accessible along the traffic-free route of the former GWR line through the LNR, the Railway Walk. There are 10 schools and a college within easy reach of the Railway Walk; to my knowledge it is used as a traffic-free route to school for parents and pupils at Smestow, Castlecroft and Bhylls Acre schools. It is part of a commuter route from S.Staffs to the i54 and to city centre. The Railway Walk links to NCR 81 and is part of a 30 mile circular cycle route through the Black Country. BUT: traffic will cross the Walk if houses are built on the WEC.
Houses should not be built on the WEC. The WEC should not be in the BCP as a site for potential development.
Inclusion of the WEC in the draft Black Country Plan raises doubts about whether Wolverhampton was ever serious about ……
1. observing environmental policies if they conflict with goals to make money
2. the importance of health and well-being
3. sustainable and active transport
4. local democracy as represented by the Tettenhall Neighbourhood Plan, NPPF Green Belt policy, Black Country Core Strategy (BCCS) and Wolverhampton’s Unitary Development Plan
…..and whether CWC will be serious about meeting the challenge of climate change.
Accountability and the Black Country Plan
It was disturbing to read in today’s Express & Star of serious malpractice, corruption, Sandwell Council (E&S 11.10.2021) is at the core of democratic government. We rely on our councillors to hold officers to account.
There is much that is constructive about the draft BCP. It is an impressive piece of work. But the Consultation on the BCP is complicated and daunting for many of us. It is unlikely to be a true reflection of what people want. We rely on our elected representatives to hold our planners to account.
Accountability is at the core of democratic government. We rely on our councillors to hold officers to account. Therefore it is disturbing to read that some councillors cannot be trusted.
Planning regulations are so lengthy and complex - at 735 pages the draft BCP was too much for this amateur - it is no wonder that councillors get lost. An Aide Memoire to the Black Country Plan will help. It could also help the public understand the planning process.
Clearly no Summary will replace professional officers. At all levels of bureaucracy there is mismanagement. Unfortunately Councillors can easily be misled by Officers, especially when a lack of transparency is part of the culture of the planning department, as I have discovered over the last six years while exploring the reasons for granting outline planning permission for houses on the WEC.
What is needed is a change in bureaucratic culture: line managers at all levels of seniority must be made to understand that they will be publicly held responsible for serious mishaps and expected to resign.
Nolan’s Seven Principles of Public Life should form the basis of a Code of Conduct for all council officers.
Finally, front-line officers should be able to admit to mistakes without fear of reprisal, and should be encouraged to critically question planning decisions in order to arrive at decisions which are just and fair, and in line with the Black Country Plan.

Object

Draft Black Country Plan

Representation ID: 14485

Received: 20/09/2021

Respondent: Jan Vanstone

Representation Summary:

I object to any building proposals on this land which is situated in the middle of our only nature reserve.
Wolverhampton has one of the lowest areas of designated Green Areas in the country and the lowest in the West Midlands.
The World is in the midst of an environmental crisis. Building 14 luxury houses in the middle of a nature reserve will not solve a housing problem BUT will have a devastating effect on our environment .
We owe it to this and future generations to save what we have .
Jan Vanstone

Object

Draft Black Country Plan

Representation ID: 14490

Received: 02/10/2021

Respondent: John Fryith

Representation Summary:

Yorks Bridge, Pelsall (580 Homes) Site No WAH236
I oppose greenbelt development as brownfields should be looked at first, to build houses on beautiful farm land would be a long term mistake, this land also has abundance of irreplaceable wildlife, "Deer, fox, rabbits, buzzard, crows, bats, magpies, owls, kestrels, sparrow hawks, herons, when I was a child these fields had plenty of lovely lapwings (all gone now). 580 homes come with 580+ motor vehicles adding to the already overloaded lichfield v norton roads. There has been too much development in Pelsall since I was born on the Wolverhampton Road, which is also overly busy. Has anyone checked the traffic pollution yet? I am also not happy about the installation of a new canal bridge alongside 'Yorks Bridge' which will look stupid and create faster moving traffic making it more difficult to exit moat farm estate. Pelsall village cannot take anymore vehicles?

Object

Draft Black Country Plan

Representation ID: 14566

Received: 10/10/2021

Respondent: Mrs Lynda Adams

Representation Summary:

Please register my complaint that I object to new houses being built on the only Green space near
to me to walk by the grapes pool.
As a woman alone it’s the only safe place for me to walk which I do daily.
You will completely ruin the beautiful wild life and trees, which I find absolutely disgraceful.
Further more it will completely ruin the whole area.
I have enjoyed this area from a little girl walking with my grandad. I am nearly 60 and still enjoy
this place every day with my family and my dogs.
There is an abundance of wild life, plants and trees. I don’t understand why you can’t build
somewhere where there are derelict buildings that are an eysore for us. This area is very
beautiful. Please register this as my complaint as it’s clear your site has been made difficult to
register anything to stop this happening.
I am absolutely disgusted that the area has been included in any plan to build

Object

Draft Black Country Plan

Representation ID: 14567

Received: 29/09/2021

Respondent: Richard Down

Representation Summary:

I thought the development of the old WEC site had been turned down
Now I hear it has been approved again
Could you clarify the latest please , it would be much appreciated
The area is next to a pond and there are definitely great crested newts there which are protected under law. Also a number of variety of bats - also protected.
Woild be a shame to ruin such an area of rich wildlife for the sake of 14 houses.
Plenty of other places to build where there aren't protected species

As pointed out as an option, I would very much like to state my objection to the BCP plans to remove WEC as green belt land and also object to it being used for housing development. Please officially lodge my objection. I thank you for this.

Whilst I understand the 10 year commitment post build, I still feel strongly the build will have a negative effect on the area. Hence my objection to this proceeding

Object

Draft Black Country Plan

Representation ID: 14777

Received: 11/10/2021

Respondent: Finchfield and Castlecroft Community Association

Representation Summary:

I write as Chairman of the Finchfield and Castlecroft Community Association, which represents hundreds of residents in these areas of Wolverhampton. My comments reflect the views of the committee and the great majority of residents in Finchfield and Castlecroft.

Our objection to the draft Black Country Plan specifically relates to site WOH274, the former Wolverhampton Environment Centre on Westacre Crescent in Finchfield, where it is proposed to build 14 properties. The community association, and hundreds of local residents as well as the local councillors, object to this proposal in the strongest possible terms.

The site sits at the heart of the Smestow Valley Nature Reserve, and is currently green open space that is enjoyed by many people, some of whom travel a considerable distance just to enjoy the nature and the beauty of the land. The value of having this green open space was particularly felt during the recent pandemic, when getting out and enjoying nature was one of the few pleasures that people could take part in when large parts of the country were closed.

The community association has previously held meetings with council officers to discuss their plans to build on the site. We note that the council's planning permission lapsed earlier this year without any development taking place. We would argue that the council is fully aware of local opposition to their proposals, and they had the chance to build on the land but didn't. They should not be given a second chance.

We work closely with the 'Friends of the WEC' group, a social media forum which currently has over 1,000 members, to oppose any development on the site and instead to preserve it for the local community to enjoy. The site is a hotbed of nature and wild animals, and any housing on the land could only be of detrimental effect to them. The land also absords water from the nearby Smestow Brook when that overflows, acting as a shallow wetland which benefits the environment and nature. If houses were built on the land, this would cause drainage problems and the overspill would have to go elsewhere.

The site is also specifically protected in the Tettenhall Neighbourhood Plan (Policy TNP6) where it states the land is designated as agricultural and the preferred option is to retain the land for community use. The Neighbourhood Plan also states that the site should be fully integrated into the Nature Reserve, and indeed designated as a SINC. Wolverhampton Council have disregarded the Neighbourhood Plan when drawing up their proposals to build on the site.

As part of the development of the Tettenhall Neighbourhood Plan, a public survey was conducted in which 78% of respondents objected to any housing development on the site. This further strengthens our objections on behalf of the local community.

To conclude, as a Community Association representing hundreds of local residents in Finchfield and Castlecroft, who would be greatly affected by development of the former WEC site, we object to the inclusion of this site in the Black Country Plan and request that it is removed. It is our strong belief that Wolverhampton Council can find more appropriate space elsewhere in the city for 14 properties to be built, including via increasing numbers at existing brownfield sites where development is planned.

Object

Draft Black Country Plan

Representation ID: 14798

Received: 08/10/2021

Respondent: Mrs Lorraine Gill

Representation Summary:

I wish to object to the development of 14 houses on the Smestow Valley Nature Reserve. The area is near Finchfield by the W-ton Council Allotments.
We walk as a group in the proposed Area every week and think it would be a great loss, never to be replaced. The area is A habitat for all sorts of Birds & insects, plus Foxs etc.
Please do not allow this development there are other Brownfield sites to use. We all need some open space to help our health. The site is very well used and easy to get to a little haven to escape to.

Object

Draft Black Country Plan

Representation ID: 14832

Received: 25/09/2021

Respondent: Mr Ivor Sperring

Representation Summary:

I am writing to express my opposition to the plen to build on land that is part of Wolverhamton Environmental Centre in Smestow Valley. It would be a tragic loss of emanity if this land were to be swallowed up into any kind of development. . My wife and I have also enjoyed this area in the 30 years we have lived in Wolverhampton.
Please reconsider this developement and give thought to developement on some of teh "Brown Field sites" within the Ciry Boundaries.

Object

Draft Black Country Plan

Representation ID: 14871

Received: 10/10/2021

Respondent: Julie Bedding

Representation Summary:

WEC Smestow Valley
I object to the housing on the WEC
the Black Country Plan - page 608, ref WOH274 WTNA, WEC Smestow Valley,Wolverhampton

The nature reserve is one of the only remaining natural places in the area •available for the public to roam.
•Essential to maintaining mental health
•Allowing nature to thrive
•Biodiversity
•Wetland
•Orchids and hundreds of other wild species of plants •provides a corridor into the city for people, wild plants and animals •an opportunity to use as a foundation for further work within Wolverhampton to ensure cleaner air, open spaces, tree planting,
rewilding •a place for children to be educated and appreciate nature
The WEC is not brownfield

Object

Draft Black Country Plan

Representation ID: 14888

Received: 04/10/2021

Respondent: Kathryn Kimbley

Representation Summary:

Planning reference: WOH274 WTNA
I have just heard about the plans for the WEC in Wolverhampton and am absolutely horrified.

This is a beautiful location with so much natural beauty, wildlife and nature is stunning.

Wolverhampton is already a hugely industrial area with limited access to natural areas. The idea of building on such an area is not only heartbreaking but completely immoral and unethical.

I wholeheartedly oppose the plans for this development. I only hope it doesn't go ahead.

Object

Draft Black Country Plan

Representation ID: 14920

Received: 11/10/2021

Respondent: Mrs Sally Finch

Representation Summary:

The nature reserve is one of the only remaining natural places in the area
•available for the public to roam.
•Essential to maintaining mental health
•Allowing nature to thrive
•Biodiversity
•Wetland
•Orchids and hundreds of other wild species of pants •provides a corridor into the city for people,
wild plants and animals
•an opportunity to use as a foundation for further work within Wolverhampton to ensure cleaner air, open spaces, tree planting, rewilding The WEC is not brownfield

I object to the housing on the WEC
the Black Country - page 608, ref WOH274WTNA, WEC Smestow Valley, Wolverhampton.

Object

Draft Black Country Plan

Representation ID: 14927

Received: 25/09/2021

Respondent: Ms Julia Stockhall

Representation Summary:

I write to register my objection to the building of new homes on the site located at
Smestow Valley.
This section of the greenbelt is an essential location for the community’s physical and
mental well-being, I visited regularly as I walk around the area. It is also necessary for
the local wildlife , being a location where Great crested Newts, row deer, muntjac
deer and badges all reside.
While I appreciate the need to build new homes in Wolverhampton it is not necessary
to build them on this location and other more appropriate locations can be found.

Object

Draft Black Country Plan

Representation ID: 14978

Received: 10/10/2021

Respondent: Kevin Sankey

Representation Summary:

Black Country Plan - page 608 ref WOH274 WTNA WEC
I am objecting to any plan to build housing on the WEC, Smestow Valley, Wolverhampton as access to
development would require vehicle access across greenway. This conflicts with Policy CSP4 Achieving
Well Designed Places - and Policy ENV8 - Open Space, Sport and Recreation.