Policy DSA1 Land South of Holbeach Lane /Wolverhampton Road, Kingswinford

Object

Representation ID: 21509

Received: 09/10/2021

Respondent: Mrs Zoe Mullen

DUH 208 Holbeache
DUH 211 The Triangle
DUH 217 Wollaston Farm
Loss of green belt - valuable access to countryside will be lost forever - an increase in light and noise pollution, destruction of natural habitats. Poor air quality will affect residents.
Pressure on local facilities - there is not the infrastructure in place to support the proposed number of houses. Doctors surgeries, schools, roads are all massively over-subscribed and very busy. More houses will place unbearable strain on already stretched resources.
These houses do not meet the affordable housing targets. Expensive housing destroying much valued, hugely important green belt are not what's needed. There is huge opposition from all parts of the local community.

Object

Representation ID: 21513

Received: 11/10/2021

Respondent: Mike Wood MP

Number of people: 986

We oppose releasing the Green Belt land at the Kingswinford Triangle and Holbeache for development, call for those sites to be removed from the draft Black Country Plan, and urge more work to be done to find alternative choices on brownfield sites.

Object

Representation ID: 21539

Received: 11/10/2021

Respondent: Mrs Wendy Mannings

Holbeache ref DUH 203, DSA1
The Triangle ref DUH211 DSA2
I wish to express my grave concerns over the proposed developments as referenced above. There are four main areas which I feel will have an adverse impact on the area:
1. It is already obvious that the local road infrastructure is struggling to cope with the amount of vehicles on them, borne out by the long delays created at peak times in the Wordesley, Kingswinford and Wall Heath areas. Future development will only add to these problems creating even greater pollution and damage to the environment.
2. Increased pressure on local services which are already struggling including schools, doctors, district nurses, dentists and Dudleys main hospital at Russells Hall.
3. Safety concerns for both young and elderly created by the increase of traffic and pollution.
4. Impact on local wildlife and open space for all to enjoy.

Object

Representation ID: 21549

Received: 08/10/2021

Respondent: Mr Trevor Oakley

Holbeache Lane BCP ref DUH208 / DSA1

The proposal to build executive homes on green belt land is totally unacceptable, especially as there are many brownfield sites available. These are areas of outstanding beauty which provide vital habitat for the local wildlife and play a vital role in reducing the risk of flooding in the area. Furthermore, these houses are not even affordable housing to help the first time buyers, this is greedy developers wanting to make big money on prime land that does not have the infrastructure to support it. The existing highways cannot cope with the extra demand leading to deterioration, more congestion and pollution. Medical services are already stretched to the limits with unacceptable waiting times for hospital and doctor appointments and longer waiting times for ambulances. Schools are also full, where will children have to travel to for their education?

Object

Representation ID: 21910

Received: 11/10/2021

Respondent: Michelle McCloskey

Objection to Black Country Plan
I wish to object in the strongest possible terms to ANY building on green belt in the Dudley Borough area.

In the Council Scrutiny meeting on 6.10.21 your officer admitted that NO bio diversity checks have been made or wildlife impact assessment.

Our roads are already gridlocked, schools over subscribed, GP's over subscribed, huge waiting lists
at hospitals.

People need green spaces for mental health and physical fitness. The impact on the environment and
climate by building over remaining green land has been underestimated. An audit of preserved or valuable trees has not been carried out.

The quality of life for existing residents will be greatly diminished, with more traffic, parking issues, nowhere to walk dogs or just take a walk in a green environment.

The plan mentions re-wilding - but where will that be as all available space is gradually eroded and built on. Why not just leave the existing habitat alone.

I do not believe that 'exceptional circumstances' apply in any of the areas listed. I do not believe that all brownfield sites have been identified. I do not believe that all empty Council houses that could be refurbished have been. It is clear that if there is a shortage of land that there should be a preference or flats or maisonettes thereby creating more housing from the same
brownfield plot.

A question was also raised in the Scrutiny meeting regarding the data upon which the housing
requirement has been calculated. Dudley Council should ask for this to be reviewed particularly post Brexit and post pandemic.

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH 206 Worcester Lane
DUH 207 Worcester Lane Central
DUH 209 Worcester Lane South
DUH 217 Wollaston Farm grazing land
DUH 210 Viewfield Crescent
DUH 041 Two Gates Lane Cradley
DUH 212 Lewis Road Lye
DUH 214 Seymour Road Wollescote
DUH 215 Bent Street Brierley Hill
I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for
residential or a industrial purpose.

Object

Representation ID: 22040

Received: 11/10/2021

Respondent: Ms Jan Norton

Holbeache - DUH 208

There are lots of reasons why Dudley should not be building on green spaces or green belt.

Informal green spaces are precious areas in which our children can play, especially if they are not near a park. If we are going to support our children to become healthy adults, it is key that they have opportunities to exercise both in and out of school. These spaces also support adults taking exercise and are positive for everyone’s mental health and wellbeing.

My concern is that once green belt land is developed, it will be followed by more and more erosion of green belt. I am also concerned about the potential erosion of the Borough’s precious other green spaces.

I live on a brownfield site which was developed with a mixture of homes including those for rent, some with affordability schemes, and those for people with disabilities. It works, and there is an expectation of all developments that a mix of homes and tenures are likely to be needed (BCP, p98)

Kingswinford and other areas along the A449 corridor are what some people would describe as semi-rural. The proposal to build on Holbeache and the Triangle will impact on the nature of the area and has been described as “urban creep”.

There is a direct relationship between our health and well-being, the quality of the air we breathe and having access to green spaces. (BPC, 3.74 Strategic priority - Improving the health and wellbeing of residents and promoting social inclusion). Dudley Borough faces health challenges because of low rates of physical activity, high rates of obesity, depression and social isolation. If the proposals in the plan go ahead, this will impact negatively on wellbeing through lack of green space as a social amenity. It will also bring poor air quality (BCP, 4.24, 5.12e, p 72 fig 3) noise and traffic, particularly during any building work.

I hope that the Council is constructively able to use any funding made available by the West Midlands Mayor to regenerate brownfield sites and that this can be factored into the next planning stage.

I recognise that green sites are “appealing to developers” – they are appealing to residents too!

When was it agreed that Holbeache and the Triangle sites were suitable for release from green belt for development? I would like to see the minutes of the meeting, a list of people present and a summary of the discussion. Was there local consultation about this?
Could you explain what is a Core Expansion Zone and what is the difference between Zone 1 and Zone 2.

Has there been an audit of derelict sites which could be compulsorily purchased so that green spaces can be retained?

Can you explain the process by which sites may have come into the Plan then disappeared, may be in the Plan and then taken out or may not have been in the Plan but may come in as new sites?

I understand that the sites of at Holdbeache and the Triangle are useful agricultural land, grade three and above.
How do you define "High Quality" and "High Value" arable land in order to explain the difference?

In relation to a number of sites (Severn Drive / Bryce Road , Triangle, Holbeache) residents have raised questions about the risk of flooding. Once land is cleared, the potential for soil erosion increases.
Has the Borough assessed the risk of flooding or specific drainage needs in relation to all proposed sites?
What plans do the Council have for mitigation?
I have seen no independent environmental impact assessment (which also involves speaking to local people who know the area from their own experience, flooding risk, local wildlife etc)

What is the Borough policy on maintaining ancient trees and woodland?

Retaining trees is vital to the environment, to air quality and for as part of a community’s amenities. They are part of the character of the area. Ancient trees cannot be replaced by saplings.

Wildlife, in particular protected species, wildlife corridors, hedgerows, meadows and fields should not be put under threat. It is essential that Sites of Local Importance for Nature Conservation and ootpaths are preserved. Wildlife Trusts will strongly oppose any development that will damage or destroy sites that are important to wildlife. https://www.bbcwildlife.org.uk/blackcountryplan

Proposals for house-building
Members of the public raise concerns about the types of houses that are planned. Many point to the possibility that there is an under-estimate of quality, affordable homes that people can afford to heat (BCP, 5.12 c – “a key priority for tackling health and wellbeing”; “an increased proportion of being affordable or in the social housing sector”)
I have heard the Black Country Plan described as both a “speculators’ charter” and a “landlords’ charter”.
Do the numbers reflect prioritisation of quality, affordable homes?
Is there an increased proportion in the plan of homes which are affordable or in the social housing sector?
How will a range of homes including affordable to buy, to rent, shared ownership and those specifically built for families with people with disabilities?
What horizon-scanning has been done regarding the changing / likely future population of Dudley and their housing needs?

Infrastructure
The Plan proposes significant developments. Many local people are concerned about pressures on education, health services and smaller, more local roads where there is already congestion.
I’m old enough to remember the concept of an “inverse care law” – the fact that in wealthy areas, articulate residents can put pressure on agencies for better quality or more services. The residents with the most and often most complex health and social needs often have to make do with a poorer quality service, less services or no service at all. Food for thought for the Council and
its partner agencies. Where are the proposals for improved public transport, walking and cycling? (BCP 3.74 Strategic priority – promoting sustainable transport)

Object

Representation ID: 22080

Received: 06/10/2021

Respondent: Raymond and Wendy Dovey

Number of people: 2

The Triangle and Holbeache Proposed Developments.

We OBJECT to the proposals.
We have not been given, in a coherent form, details of the origin, location of and type of housing demand that these developments seek to satisfy.

The proposals to build adjacent to Kingswinford and Wall Heath are irresponsible given the current traffic queues on A449, A491, A4101, B4175 and B4178.

The B4178 (Swindon Road) has become a bypass for Stallings Lane traffic lights and other controls on A491, allowing HGVs and other traffic to approach Dudley and the Trading Estates via A4101(Summerhill/ High St). Cot Lane continues the "bypass" to the Wordsley traffic lights for other vehicles.

If the developments were to proceed, the queues will obviously grow longer and result in even poorer air quality and additional noise and health risk for residents.

Other infrastructure problems, which currently exist and will be exacerbated, are waiting times at Russells Hall Hospital, GP availability and the continued building of homes near to the edges of DudleyMB by South Staffs.

Object

Representation ID: 22084

Received: 06/10/2021

Respondent: Robin Fisher

Ref the proposed housing developments at "The Triangle" Kingswinford and "Holbeache Lane "Wall Heath.

There is currently a problem for traffic trying to get through Kingswinford. At certain times of day, there is a traffic tailback from the Stallings Lane/A491 lights to the
A449/A491 roundabout. This causes traffic trying to get through Kingswinford, from the Wolverhampton direction, to detour along the A449 giving further build up at other junctions, particularly at Swindon Rd/A4101/Cot Lane.

This situation is already unacceptable and I object strongly to the above housing developments which will create even further gridlocks trashing the environment for existing residents and create chaos in already inadequate parking spaces in Kingswinford and Wall Heath.

Object

Representation ID: 22102

Received: 11/10/2021

Respondent: Mr Mitchell Churchman

Dudley appendix a, pages 75-78 Holbeach SA-0017-DUD

I strongly object to the planning of these houses to be built on our beautiful greenbelt land, the main reason we chose to live here was the countryside surrounding Wall Heath where numerous walks can be taken.

There are plenty of brownfield sites that can be used, and I personally don't think green belt land should even be considered, as this is an irreversable decision and once green belt land has gone it cannot be replaced.

The houses will bring more noise, increased traffic, which is already bad enough adding more pollution and increase in accidents in turn producing more pressure on other services which are already at the limit. The area has had so many changes already and enough is enough, we do not need more houses and the facilities we have will not cope either.

Object

Representation ID: 22109

Received: 22/09/2021

Respondent: Miss Jill Renmant

I travel between Oxford and Wordsley for work and home and would like to object to all development on greenbelt and green space.
For the purpose of this form the main sites I would like to oppose are DUH208 (Holbeache), DUH211 (The Triangle) and DUH217 (Wollaston Farm Grazing Fields). I see these areas as gateways to development for South Staffordshire's border which would be catastrophic for the Wordsley, K'ford & Stourbridge area, not to mention the devastation to wild life and the environment. Friars Gorse and Ridgehill are areas of beauty and should be protected. Equally the Stourbridge Canal is of notable beauty as well as it's key part in our local history. as someone who regularly drives from Wordsley to the M5 I can catagorically state that the road network is already at a standstill.
Three Key Objections: environment / climate change / flooding; historical preservation; inability of road networks to cope.

Object

Representation ID: 22113

Received: 11/10/2021

Respondent: Mr Trevor Proudler

I object to the green field residential development of two sites in Kingswinford, south of Holbeache Lane and The Triangle between the A449, Lodge Lane and Swindon Road. There is not enough doctors or dentists facilities nearby and the local hospitals are full and overflowing already.
The A449 is a very busy main road and is overloaded already as it is the main north to south route on the western side of the West Midlands. if more local traffic is going to be using it, the side roads will become a rat race and / or short cut, leading to potential injury for existing local residents.
There are queues and tailbacks already without any more residents, causing high C02 emissions and poor air quality on the A449 due to congestion in Wall Heat's two small 'islands' (have you seen the queues on Stollings Lane / A491 during peak periods?) - any more traffic will create gridlock in the area, including Kingswinford, A491 to Stourbridge and beyond. Wall Heath and Kingswinford residents will have more of a problem with schools, new houses near Summerhill School will effectively stop Wall Heath children getting a place there, the Holbeache proposal will magnify this issue.

Object

Representation ID: 22123

Received: 11/10/2021

Respondent: Miss Miriam Baker

I object to any development of the above mentioned green space

Object

Representation ID: 22137

Received: 11/10/2021

Respondent: Mrs Susan Pritchard

DUH208 pg371 and DUH211 pg371

Black Country Site: Assessment Report Dudley Appendix A, page 79
The Triangle SA0025 DUD

I was appalled to learn of Dudley Council's plans of losing Greenbelt at the Triangle and Holbeache Lane. This is pre destruction of Green Belt. I live just off Swindon Road and during a weekend it is almost impossible to get out of Brindley Way. Local Road infrastructure will not take further traffic already C02 emissions are poor air quality is high. Admissions to schools are already struggling for places. Moss Grove doctors are so busy they are having to send patients to their practice in Kinver. Loss of Green Belt will impact on local wildlife and the environment. I note that Marco Longhi, MP for Dudley North received £10,000 donations from developers NFC Homes (East) Ltd. and Countrywide Developments Ltd
Patrick Harley stated - There is no evidence that Dudley needs to encroach on its Green Belt at all. This was published in Stourbridge News 23/3/21
Once gone, gone forever

Object

Representation ID: 22141

Received: 04/10/2021

Respondent: Mrs Susan Slatter

I reject these applications for the buildings
SA 0199 DUD BCP Ref DUH222 Severn Drive
SA 0025 DUD BCP Ref DUH211 Summer Hill00
SA 0017 DUD BCP Ref DUH208 Holbeache
SA 0042 DUD BCP Ref DUH213 Lapwood Avenue
SA 0198 DUD BCP Ref DUH221 Stand Hills

Leave our Greens for what they are put there for 'Freedom' Roads Danger Zone 'already'. can we please have explanation how we are going to cope !!

Object

Representation ID: 22147

Received: 07/10/2021

Respondent: Mrs Susan Smith

Site Ref: DUH208 p371 (Holbeache)
and DUH211 p371 (The Triangle)

I object to the development of both sites because they are on greenbelt land, which should be preserved. Traffic conditions are appalling now, so the thought of 2 cars per household spilling out on to overcrowded roads is frightening - and causing further air pollution. There are plenty of brownfield sites in our area which could be used and would not cause such major disruption. There are also areas where buildings are run down and poorly insulated, could be taken down and new buildings take their place.
Our green spaces are important to our wellbeing - this has been accentuated during lockdown/coronavirus times.

Object

Representation ID: 22149

Received: 11/10/2021

Respondent: Mrs Susan Stevens

DUH208 p371 (Holbeache)
DUH211 p371 (The Triangle)

Local schooling unable to cope with extra pupils

Local doctors unable to cope with extra patients as difficult now arranging appointments
and
number of cars on roads increasing vastly

Object

Representation ID: 22151

Received: 11/10/2021

Respondent: Mr Mike Lee

Holbeach DUH208
Loss of green belt land with have a deverstating impact on the local community. The whole character of the area would be changed forever! So many people have always enjoyed these green belt areas but have provided places to escape to for a walk during lockdown and boosted everyone’s mental health.
Quality of life in our local area would be impacted. Far more traffic and pollution on our already over congested roads, additional road safety fears especially to teenagers at nearby schools. Not to mention noise, light and disruption.
Local facilities and infrastructures (doctor’s, schools, roads and emergency services) are already reaching capacity, and additional housing would provide too much of a strain on services.
The impact on the local environment and wildlife would also be devastating for the area.

Object

Representation ID: 22153

Received: 11/10/2021

Respondent: Mrs Susan Webster

DUH208 p371
DUH211 p371

(Relates to whole document)

Object

Representation ID: 22166

Received: 10/10/2021

Respondent: Mr Richard Westwood

Site Reference Numbers: The Triangle: DUH 211 page 371 and Holbeach: DUH 208 page 371
I have strong objections to the proposed development of greenbelt land sited at 'The Triangle', Swindon Road, Wall Heath, Kingswinford and the land south of Holbeache Lane, Wolverhampton Road, Kingswinford. My main objections being:

1. Highways and resultant traffic issues
I am confident that a visit by any of those in support of development on these sites would immediately reach the same conclusion that existing residents of Wall Heath are already well aware; that roads in our village are already heavily congested and in no way capable of sustaining the kinds of increased traffic we would incur, in the event new houses are built near the village.
At peak times queues of traffic stretch nose to tail along the stretch of A449 that runs through the village, belching carbon monoxide and other pollutants as it crawls along. I fail to see how this issue will not be exacerbated by developments on these sites.

2. Local Infrastructure and supporting services
Unless the developers plan to build a new Doctor’s surgery, Primary & Secondary schools, and a Hospital, I am intrigued to know how the existing strained and oversubscribed services that serve the local area will accommodate the increase in the population and resultant demand, that the introduction of 800+ new houses would bring.
3. Environmental Damage
Since moving to the village my family and I have spent many wonderful days exploring and enjoying the beautiful countryside on our doorstep. Through the pandemic, this was a major factor in our mental-health and well-being. When I explained to my two young daughters that there was a proposal to build houses on these beautiful and vibrant sites, they were both as dismayed as I, and queried why this had to happen. Their innocent and simplistic suggestion is the obvious and logical one here – build your new houses elsewhere. Only once all brown-field sites have been truly exhausted should one even consider building on green-field sites. The reality is there are plenty of viable alternatives in the Black Country, however, I expect they are more complicated & expensive to build on, and so the appetite of these mercenary developers quickly evaporates, and the ‘easy option’ gets favoured. The wildlife, flora and fauna that face eviction cannot object to this abhorrent proposal, but this does not mean they should be ignored. Development on green-belt land means irrevocable damage to the natural environment, which categorically cannot be allowed to happen.

Object

Representation ID: 22180

Received: 11/10/2021

Respondent: Mr Michael Hughes

This housing development is unsustainable as we just do not have the roads, schools, doctors to cope. We are stretched as it is, with doctors always full, schools bursting at the seams. Traffic is already taking its toll on our roads in the village and surrounding areas.
No need to ruin ur greenbelt as plenty of brownbelt sites available.

Object

Representation ID: 22307

Received: 09/10/2021

Respondent: Mr Robert Carter

Black Country Site Assessment Report
Holbeache DUH208, The Triangle Site DUH211
1. Effect on local services -roads
The local road infrastructure is already congested at all times of the day particularly the A449. This
remained a busy road even during lockdowns. There is very little scope for any road widening to ease
the congestion. Any extra vehicles will increase noise, increase CO2 emissions and lead to poorer air
quality as well as environmental damage. The proposed additional crossing will increase tailbacks and
delays. Drivers will cut through the Maidensbridge estate where many children walk to the local
schools increasing the risk of accidents. This would also be the case if there was a second access road
onto the A449 as drivers would use local village roads to avoid tailbacks. When I used this road to
commute to work over 8 years ago it was virtually nose to tail from Kingswinford to Stourbridge. Things
have only got worse since then. On 28 August 2021 between 16.30 and 18.00 there were over 5000
vehicles and this is during the peak holiday season and when many people are working from home.
The local road system is inadequate even at the present time. Houses being built at the moment on
Stallings Lane and at Wombourne will increase the pressure on the local roads.
2. Effect on local services- NHS
There are already not enough doctors and dentists in the area with patients having difficulties getting
appointments. Moss Grove surgery is having to send patients to the surgery in Kinver. I know
personally that at present you have to wait weeks for even a telephone consultation. Russells Hall
hospital has long waiting times and April 2021 inspections showed it 'requires improvement.' It is often
impossible to park at Russells Hall because of the number of patients. Even before the problems
caused by the pandemic there were unacceptable delays in local health services, mental health
services (particularly children's), hospital treatment and operations. The delays caused by the services
being overstretched are already causing stress to patients. There are also unacceptable wait times for
ambulances (in 2020 the turnaround time reached 60 minutes). The houses already currently being
built in the area will increase the pressure on these services.
3. Effect on local services- schools
There is no space in the local secondary schools for any more pupils. For the September 2021
admissions the only secondary school with places for year 7 was Wordsley. Most other year groups
are full. There were no places for reception in 2021 in Wall Heath and only one school in Kingswinford
with places. It is difficult to see how the existing schools can extend particularly the primary schools
and Kingswinford School. Playing fields are already in the main small and in the case of Church of
Ascension set away from the school building. Parents are already having difficulty in getting their first
choice of school and this will become worse with the houses currently being built in the area and
surrounding causing further travel. The brochure for the Stallings Lane development states that to
take advantage of what Kingswinford has to offer “families will be pleased to know there’s a great
choice of schools”. The increased numbers will also impact on class sizes to the detriment of the
children’s education.
4. Strains on local amenities.
There are few local amenities in the area and provision would definitely need to be improved and
increased with a further increase in the area’s population. The parks lack good quality equipment,
there is no youth centre in Wall Heath and no local sports centre.
5. Loss of Green Belt and impact on local wildlife and the environment.
The proposed development would result in the loss of very good agricultural land. Holbeache is Grade
2 where a range of crops can be used. The Government is committed to a 25 year plan to protect land
of this quality and use the soil in a sustainable way and this was updated as recently as February 2021.
All brownfield sites should be used before green belt and there are alternative brownfield sites
available.
The hedgerows all around Holbeache and a plot to the left form a Site of Local Importance for Nature
Conservation. The proposed development would mean the loss of a variety of wildlife including some
protected species such as red kites and badgers. It would also result in the loss of bees and butterflies
and biodiversity that the wildlife corridor is trying to protect due to declining numbers. The yearly
daffodil display is a joy to behold and is photographed across the region creating a positive image. The
report states that there are ‘significant tress’ and these will be lost at a time when globally the aim is
to prevent the loss of trees.
The report states that Holbeache would become a ‘permanent’ boundary if fully developed. This is not
the case because it is presently green belt which prevents the urban sprawl.
A grade II historical building, Holbeache House, is next to the proposed development.
The prosed development would have a visual impact on the landscape. Local people enjoy walking
and cycling in the green belt and appreciating it helps feelings of well-being and is important to mental
health and this needs to be protected for now and future generations. There does not appear to be
any exceptional circumstances to allow this Green Belt area to be used for development.

Object

Representation ID: 22328

Received: 02/10/2021

Respondent: Mr Robert Davison

DUH 208 Holbeache

As a proud resident of Kingswinford I strongly object to the development of these green open spaces. The area is steeped in history and borders countryside to be envied.
Nationally, we have lost an incredible amount of green belt and this is just a further erosion of the open spaces we have available. At the rate we are currently losing green belt my daughters children will only be able to read about and see photo`s of what we were lucky enough to have enjoyed. These open spaces are the lungs of the community. By allowing mass developement like this we will surely be increasing cases of asthma and other respiratory diseases which will put further pressure on an already stretched NHS.
During the Covid lockdown of 2020 I spent many hours walking these fields and they were, without doubt, a massive contribution to my physical and mental wellbeing during those umprecidented times. If we were to suffer another worldwide pandemic then where are we to exercise if these open spaces are lost?
In the past number of years we have seen extensive developemnt at the top of Stallings Lane with more to come on the former Ibstock Himley Brickworks site. The impact on traffic has been very noticable. Most times during rush hour Stallings Lane and Moss Grove traffic lights are gridlocked. If we allow these developments then it is likely, based on 2 cars per household, there will be a further 1726 cars using these roads. As most residents of Kingswinford and Wall Heath will confirm, the availability of public transport in the area is at best poor.
These developments will also have a catastrophic impact on the local wildlife and ecology. Again, I want my daughter and her children to be able to see and hear the wonderful wildlfe that we are blessed with. As a nation we are doing many things to help the environment. Electric cars, solar and enewable energy and household recycling.
I was originally from Dudley but moved to Kingswinford [x] years ago. I cannot imagine living anywhere else. The area borders some stunning countryside which makes it the desirable place it is. I do not want to live in an area where open spaces and countryside are a cars drive away. I hope that the generations that follow me are afforded the same chances to enjoy the benefits of these open spaces. This is why these developments MUST be stopped!

Object

Representation ID: 22471

Received: 11/10/2021

Respondent: Mr William Lawson

Holbeach site DUH 208 page 371

OBJECTION

I am writing to object to the development of parts of our Green Belt.

Significant loss of countryside will no doubt impact on wildlife in the local area. As well as loss of important habitats such as hedgerows and significant tree species. This will be
devastating to those of us who enjoy nature and enjoy that it is so close and easy to access.

Roads such as Cot Lane and Stream Road are bumper to bumper with traffic; it is regularly a long wait to pass through the traffic lights by the Harvester Pub at the junction of Cot Lane and Lodge Lane. The A449 also has an extremely large volume of traffic throughout the day.

Additionally more local residents would put increasing pressure on our local services such as schools, doctors and Russell’s Hall hospital.

There has been no real investment in the area in terms of leisure and recreation other than an improvement to Cot Lane park lead and funded by a local action group.

In the Black Country we have much in the way of brownfield sites, some of which have already been
developed.

I hope you see sense and listen to the objections I know friends, neighbours and local residents will make against this particular part of your Black Country Action Plan.

Support

Representation ID: 22503

Received: 07/10/2021

Respondent: Persimmon Homes West Midlands

Agent: Planning Prospects Ltd

Policy DSA1 (DUH208) - Land South of Holbeache Lane, Kingswinford


Persimmon Homes are concerned to ensure in these representations that the BCP;


• Identifies and meets the full development needs of the Black Country
• That a balanced range of sites are identified in order to address the failings of the previous BCCS
• The sources of supply of land for housing are robust, reliable, suitable and deliverable
• That undue reliance is not placed on sources of supply that are unlikely to deliver and the plan properly plans for development without undue reliance on unplanned windfall
• That the need for Green Belt release is acknowledged as an essential part of the
Development Strategy to meet development needs
• That the maximum level of development is provided for within the Plan before a residual unmet need is identified
• A clear strategy is identified to address such unmet need, evidenced through commitments in the Duty to Co-operate

What is evident from these concerns is that the sites currently identified within the plan are critical to meeting need, but in themselves alone will not meet the needs identified and more land beyond those identified will certainly be needed.

Support is given to land at Holbeache Lane which is a site which is viable, suitable, available and deliverable to meet housing needs and has been promoted for development by Persimmon for some time. It is a critical site in the projected supply in the context of the above wider concerns regarding the Plan and should be earmarked for early delivery in the trajectory- in the Plan, the site is anticipated for delivery from 2030 to 2035 (155 homes) with the balance (175 homes) from 2035 to 2039 but the site could be brought forward immediately and to a much quick delivery timeframe with full delivery within 5-7 years.

Appended here is a supporting promotional document which explains fully the merits of the site and vision for a sustainable, high quality residential development. The site is in an ideal accessible location for new housing. It has no technical constraints to its development and would deliver a high quality mix of new homes. The site would make an important contribution to meeting the considerable future needs for housing, including affordable housing in the Black Country in coming years. The Document provides a detailed description of the site and the surrounding area. It sets out the future vision for the development and explains how the proposals respond positively to the opportunities which the site presents, in particular in terms of landscape and biodiversity. The aim is to deliver a scheme with a distinctive sense of place. Attractive new homes will be provided in a mature landscape setting with extensive new areas of public open space and areas managed for ecology and biodiversity gains.

The Masterplan sets out how the site could be developed to deliver a high quality, residential development in a sustainable location on the edge of Kingswinford. Careful consideration has been given to the site's development, with a scheme that will deliver up



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to 350 new homes (the site is allocated with an indicative net capacity of 330 dwellings within the plan but Persimmons own masterplanning shows a potential for around 350 dwellings, only slightly above 40 dpa). There will be a mix of types and tenures including affordable housing, a new site access, links to existing footpaths, protection of established hedgerows and trees and the creation of new public footpaths, cycle routes and public open space for new and existing residents alike. The site has particular merit, in line with the principles for the site's development which are set out in the Plan, in that;


• When assessed against Green Belt objectives, the site contributes little to Green Belt purposes and would not undermine wider objects of the Green Belt in this area
• The site will establish a new community with integrated Green Infrastructure and connected areas of public open space.
• It provides informal recreation opportunities through generous public open green space incorporating recreational routes as well as children's equipped play.
• The site will provide much needed new housing, easily accessed directly off Wolverhampton Road which is the main transport corridor entering Kingswinford from the north.
• Consideration has been made of opportunities for greenway connections to employment areas to the south and east of the site.
• The proposal retains the majority of existing vegetation (access will require some removal but can be readily mitigated); trees and hedgerows as well as protecting and incorporating the area of woodland to the east of the site.
• It creates significant publicly accessible green space which enhances and reinforces the existing site features, through new woodland, trees and hedgerow planting together with a well- considered SuDS scheme, combining to provide an extensive network of green infrastructure for the residential development.
• The layout protects and improves existing wildlife habitats as well as creating new features to improve the overall local biodiversity gain.
• It seeks to embrace climate change measures where practicable.

Policy CSP1 -- Development Strategy


It is fundamentally important that the Black Country Plan (BCP) properly identifies the development needs of the Black Country and fully provides for them within the Plan through to 2039. In this regard it has to be recognised that the current Black Country Core
Strategy (BCCS) has not been successful in its approach and a new Strategy is essential if the growth needs of the Black Country are to be successfully met. The BCCS focused on the re• use of brownfield, often previous employment, land to meet development needs, including for housing. However, the challenges to their delivery have not been over come and the market has consistently shown a requirement for choice and variety in sites for residential development. The experience during the BCCS period has shown that whilst making best
use of existing brownfield land within the urban area is important, a strategy that focuses
too heavily on this, particularly in seeking to meet the need for residential development, will not succeed and will result in a shortfall of available development land to meet needs. A more balanced approach is needed and seeking to continue an approach which has only
been partly successful would not be sound.


Support is given to the Objectives of the BCP which include the provision of, "housing that meets fill our needs". The Strategic Priorities in seeking to meet that objective include, "to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents", and, "to improve and diversify the Black Country housing offer". These points - around comprehensively meeting need; providing range and choice; and delivering improvement and diversification in housing provision -are important and must influence the policies of the BCP. Paragraph 1.43, and elsewhere highlights key challenges to deliver provision of good quality housing to meet the needs of a growing population and accommodating significant housing and employment needs. It acknowledges that to meet those needs there is a requirement to assess and review the
Green Belt and identify areas for growth in the context of a deficit in the supply of brownfield land. Exceptional circumstances clearly exist in this context such that it is essential that Green Belt land is released for development as there is simply not enough brownfield land which suitable, available and deliverable to meet development needs.

Policy CSP1 -- Development Strategy should be explicit in recognising the need for the release of Green Belt land. Reference is made to, "delivering the majority of development in the existing urban area", and whilst that remains relevant, the BCP must also acknowledge that a change in strategic direction away from the BCCS is necessary and this will include the delivery of development in other areas including Green Belt. This is implicit in the reference to growth in locations on the edge of the Urban Area, but the only explicit mention of the Green Belt in Policy CSPl refers to its protection.

Equally, the BCP very clearly relies on exporting a significant amount of its development requirement -some 28,239 new homes, and 210ha of employment land - to other authorities through the Duty to Co-operate. Whilst we comment on this further in our
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representations elsewhere below, exporting development need must be reflected and made absolutely explicit in the Development Strategy.

A Development Strategy that relies on Green Belt release to help meet development needs must refer and commit to that release, and Policy CSPl is not explicit in that regard, neither is it explicit in the strategy approach which is exporting very substantial development needs (equivalent to some 37% of the overall requirement) to other areas and must be explicit on this point.

In summary;


• It is important that the plan meets the full needs for development in the area
• A revised Development Strategy is supported which recognises the failings in the approach of the previous BCCS and a more balanced provision of sites to support delivery is essential
• Exceptional Circumstances are clearly evident given the lack of supply of sites from other sources to meet development needs
• The Development Strategy should be explicit in recognising that Green Belt will be required to be released to meet needs
• Further it should be explicit in recognising that a component of need will not be accommodated within the Black Country and will need to be delivered across boundaries

Policy HOU1 - Development Strategy


As drafted the BCP raises some very serious concerns over its inability to meet the minimum housing needs of the Black Country over the Plan period, and by some considerable margin. The Plan does not properly address the scale of unmet need it has identified and relies too heavily on neighbouring authorities to deliver its unmet needs. In doing so it fails to address in any tangible way how the homes needed in the Black Country during the BCP period can ever be delivered and fails to meet the tests of soundness set out in the Framework.

Even those sites that are relied upon in the draft BCP, as set out in its Table 3, are unlikely to deliver even the 47,837 net new homes it anticipates over the Plan period, such that the
true extent of unmet need within the BCA areas is likely to be significantly greater than the already substantial 28,239 homes it acknowledges.

In this respect, Paragraph 61 points directly to the "positively prepared" test of soundness (in particular) as set out at Paragraph 35 of the Framework. Plans are "positively prepared" if they provide a strategy which "as a minimum, seeks to meet the area's objectively
assessed needs1; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development" (our emphasis underlined).




1 Footnote 21 of the Framework sets out that "where this relates to housing, such needs should be assessed using a clear and justified method, as set out in paragraph 61 of this Framework".


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Policy HOUl of the draft BCP sets out that sufficient land will be provided to deliver at least
47,837 net new homes over the period 2020 - 2039. In its justification to Policy HOUl the draft BCP sets out that this will deliver a 10% increase in housing stock but confirms that will accommodate only 63% of current Local Housing Need up to 2039 within the Black Country, noting the Local Housing Need (LHN), or the minimum number of homes needed, in the Black Country over the BCP plan period is 76,076 homes when calculated following the
PPG's Standard Method2• The draft BCP (paragraph 3.21 for example) recognises that this amounts to a shortfall of 28,239 homes, or in other words 37% of the minimum number of homes needed in the Black Country will not be delivered by the Black Country Authorities
{BCA) between 2020 and 2039.


The BCP sets out that the BCA are asking their neighbouring authorities to work with them to meet this substantial shortfall under the "Duty to Cooperate" {DTC). The draft BCP refers to the current position being set out in the Draft Plan Statement of Consultation which will be elaborated on at Publication stage.

The Statement of Consultation sets out that those neighbouring authorities being relied on by the BCA include South Staffordshire, Lichfield, Cannock Chase, Shropshire and Telford & Wrekin and indicates that currently there have been offers from those authorities amounting to between 8,000 and 9,500 homes. This approach will not, by some margin, deliver the minimum number of homes currently needed in the Black Country over the BCP period. There is no explanation in the plan as to how the sizeable shortfall, or the homes that are needed in the Black Country over the BCP period, will be made up merely that "the engagement will extend beyond the adoption of this plan and will build on the partnership approach developed across the Greater Birmingham and Black Country Housing Market Area to address the combined housing shortfalls of the Birmingham and Black Country Authorities in particular". In essence, the draft BCP appears to be suggesting that its very significant unmet housing need will be dealt with at some point in the future as part of an already significant regional scale strategic challenge, without any clear or specific indication
of exactly how that will be achieved, or what guarantees or fallback mechanisms will be put in place to ensure that the Black Country's housing needs will be met.

This approach has not been successful in the Region previously as the West Midlands has struggled to meet the unmet needs of Birmingham for a number of years, following the adoption of the Birmingham Development Plan {2011 to 2031) in January 2017 with its stated housing shortfall of circa 37,900 homes. Indeed, the Black Country Authorities are relying on some of the same authorities that Birmingham City Council was relying upon to meet their unmet need including South Staffordshire and Lichfield for example. This unmet need is only likely to increase post 2031 as Birmingham grapples with an increased requirement for housing under the new Standard Methodology, a period commensurate with the latter part of the BCP period.

In essence the BCP need to;






2 Calculated in the Black Country Housing Market Assessment: Final Report (March 2021)


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• More clearly address its inability to meet the minimum identified housing needs of the BCA over the Plan period

• Reconsider its over reliance on neighbouring GBBCHMA authorities to address its needs.

The net plan requirement is exacerbated even by a cursory review of the component sources of housing land supply, not least the following;

Increasing Housing Density- whilst some additional supply will be achieved through increasing density, this must be balanced with market demands. Whilst some sites could achieve a slightly higher density where market evidence supports this and still makes the site deliverable, it will not be suitable for all sites. Even then, increasing development densities on existing BCCS allocation sites will result in minimal increases to the Black Country's housing supply over the Plan period.

Converting Employment Land to Residential Use - It is clear that there are numerous challenges associated with bringing housing development forward on employment sites and a number of those relied upon in the BCCS have been removed as they are not suitable or developable for housing. Despite this, Table 3 nonetheless indicates that 3,091 homes (6.5% of the total anticipated supply) are still anticipated from occupied employment sites, even with the 15% discount - raising questions as to whether these sites in the anticipated housing supply are truly suitable or developable for residential use and also why these sites are being lost for employment use when the BCA have such a significant shortfall in employment land supply and cannot meet their identified employment needs to the tune of
211 ha of land.


Windfall - The draft BCP's anticipated supply also includes a sizeable windfall allowance of
8,463 homes (or 17.3% of the total anticipated supply). The Policy justification sets out that this allowance is robust as it "reflects historic completion rates for sites of less than ten homes". Paragraph 71 of the Framework says Local Planning Authorities may make an allowance for windfall sites if they have compelling evidence that such sites will provide a reliable source of supply and any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends (our emphasis underlined). The BCA's reliance on historic completion rates only suggests that its windfall allowance is not supported by compelling evidence that such sites will continue to provide a reliable source of supply as required by the Framework.

Demolitions - The total net housing supply identified in Table 3 (amounting to the 47,837 net new homes referenced in Policy HOU1) is derived from a gross figure of 48,908 homes and deducting 323 homes from "Dudley Estimated Housing Renewal Demolitions" and 748 homes from "Small-scale demolition windfalls". The Urban Capacity Review Update (May
2021), however, sets out that Dudley's 10 Year Asset Management Strategy (October 2018) identified around 2,500 homes (some 12% of the Council's stock) considered not viable and red-flagged for review for strategic investment, de-investment or demolition.

Comment

Representation ID: 22539

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

(DUH208, Land south of Holbeache Lane/ Wolverhampton,
Kingswinford)

WTBBC strongly recommend that alternative development sites are sought in order to prevent loss of
green belt.
Features within the site should be retained:
- The site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National
Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local
wildlife-rich habitats and wider ecological networks, including locally designated sites of importance
for biodiversity. It is therefore WTBBC’s position that the SLINC and a suitable buffer between this
and the development area be retained, thereby providing an area of high quality accessible natural
greenspace.

Object

Representation ID: 22574

Received: 11/10/2021

Respondent: Mr Michael Reeve

Against building on local greenbelt areas.
Already the infrastructure struggles to cope with the volume of traffic without building more houses in the area.
Then there is the lovely countryside which will be spoilt and there are plenty of brownfield sites which would be more suitable.
Loss of wildlife.
Hospitals, schools, doctors are nearly at capacity.

Object

Representation ID: 22576

Received: 30/09/2021

Respondent: Mr Michael Thompson

Here are some of the points I object to
1. Loss of green belt and very good agricultural land this cannot be replaced
2. Effect on local roads the A449 is already very busy and this will make things worse People are already cutting through beechcroft estate this will increase.
3. Effect on local services i.e schools with no places available. NHS hospitals and Doctors sending patients to Kinver for appointments.
Overall these are very bad plans for the local area

Object

Representation ID: 22578

Received: 11/10/2021

Respondent: Mr Michael Tomkins

Holbeach and The Triangle
In my opinion the proposal & application contraviens totally the aims of all government offices of either persuasion to create an improved environment both living and visual for future populations. It would clearly overpopulate Wall Heath, Kingswinford, contest and destroy the area totally.
The approach between Himley & the Holbeach island (A449) would transform from grass to bricks! NOT A PRETTY SIGHT. The glorious mass of spring colour of trees and daffodils is "IRREPLACEABLE" it would be an extremely dumb idea indeed to impact the A449 & surrounding roads with yet more cars. Please be assured it is already over capacity at peak times & extremely dangerous.
The Triangle Swindon Rd island, Summerhill is probably a worst idea with a total over spill already of dense high speed traffic.
I have experience living in Wall Heath [personal details redacted] you will commit a great error if you impact more danger to these already over crowded roads.
School children need safety. One fatality is one too many. Please re-think

Object

Representation ID: 22583

Received: 11/10/2021

Respondent: Mr Michael Wiggins

Not enough infrastructure in surrounding area to support new houses. Primarly the road network which is already congested
Additionally not enough schools and doctors

Object

Representation ID: 22586

Received: 11/10/2021

Respondent: Mrs Michelle Cox

Holbeache
I am objecting to this plan for a number of reasons that will directly impact myself, my family and the local community.
1. Roads. The A449 which is very close to our house is already extremely busy, the noise pollution and air pollution would be significantly be increased if new houses were to be built and not only that but have seen many accidents on this road over the last few years. More cars would not doubt make it even more dangerous.
2. Health. We moved to the area for the cleaner air [personal details redacted] and increasing the pollution and taking away the green spaces would have a deteramental effect on my health along with many others.
3. SAVE OUR GREENBELT!!
Do you not realise that climate change is real! When will we stop distroying the little greenbelt we have left, killing animals as their homes are distroyed, taking away the trees and making everywhere an overpopulated, pollution filled area> I've seen many brownfield sites that are vacant, surely these should ALWAYS be used first?
4. Schools, doctors, NHS
How are all of these supposed to cope with the influx of new people to the area?
People are already struggling to get school places at their preffered choice.
There are not enough doctors as there is at Moss grove Surgery with patients already having to go to Kinver instead, not ideal if you can't drive, have kids that you need to take to the doctors etc. this would only get worse!
5. wellbeing, mental health
As alot of people, we moved to the area for the closeness of the rural area, not only for our health with the cleaner air but our mental health. We walk the dogs regularly over the fields and the children love it too, we want to be able to give our kids the joys of the local area and be able to enjoy it, not having to get in the car to drive somewhere else with greenbelt left! That would just cause yet again more pollution.