Policy DSA3 - Land at Ketley Quarry, Kingswinford

Object

Representation ID: 21517

Received: 11/10/2021

Respondent: Mr Trevor Chester

Ref DUH 203 / DSA3 Ketley Quarry
As far the opening the cul-de-sac at the end of Lapwood Avenue to access 600 houses on Ketley Quarry this is madness. Try getting off the estate during school term - its dreadful as its chaos. I personally think the plans ill-thought out and counter-productive.

Object

Representation ID: 21912

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: 22144

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 !!

Comment

Representation ID: 22536

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

(DUH203, Ketley Quarry / Ketley Farm, Dudley Road,
Kingswinford)

WTBBC request that significant enhancements are required of the site redevelopment:
- The site contains a designated Site of Special Scientific Interest, Site of Importance for Nature
Conservation and a Site of Local Importance for Nature Conservation, all of which have been lost to
mineral extraction. The site has now been levelled.
- It is WTBBC’s position that substantial ecological compensation for this loss should be required of
the site development.

Comment

Representation ID: 22642

Received: 11/10/2021

Respondent: Crestwood Park Residents Action Group

Number of people: 692

[DUH203/ DSA3 - Ketley Quarry]

"The Crestwood Park Residents Action Group" would like to withdraw their objection to site DSA3 Land at Ketley Quarry, Kingswinford and DUH203 Ketley Quarry/Ketley Farm, Dudley Road, Kingswinford, and replace it with a comment on the site.

Our comments are as follows:

1. We support the proposal of this site for selection for housing, on the basis that it is originally brownfield land and in line with local objectives to utilise brownfield over greenfield spaces. We also recognise that in its current state, there are numerous issues, including local flooding down the main road into Kingswinford due to run off from the site, and local flooding of the Dawley Brook behind Oregon Close during periods of high rainfall, and additional anti-social behaviour issues with the site.

2. However, we object to the proposed number of houses to be built on the site (over 600). This will create a new estate almost the size of the Crestwood Park estate, and double the size of the Sandpipers/Ploverdale estate. This will have considerable impact on local infrastructure and the road network. A reduced number of houses on this site, although impacting developer profitability, would integrate better with the local infrastructure and community.

3. We also object to the proposal for a through road from this new site onto the bottom of Lapwood Avenue. This was not included in the plan on the Black Country Plan documents but was included in a feasibility study for the site on the Dudley Council Planning site July 2021. This proposed through road would increase traffic onto the Crestwood Park site/Lapwood Avenue, running directly past a primary school that is already considerably congested at numerous points through the day, and would significantly decrease road safety on the Crestwood Park estate."

[Previous submitted comments]


2. Effect on road safety (DUH213 Lapwood/BCP REF 203 Ketley). It is not yet confirmed whether a through road will be built from Lapwood Avenue through the new Ketley Quarry development; this would create a cut through shortcut between Bromley Lane and the main Dudley Road, which would likely cause a significant increase in traffic moving through the estate not only at peak times, but at all points throughout the day, and further problems leaving the estate at the Bromley Road junction. This would significantly increase traffic, and decrease road and pedestrian safety on the estate, especially at peak school times.

6. Ketley Quarry (BCP REF 203): Generally, residents support the development of houses on

the Ketley Quarry site, as it's expected this will decrease anti-social behaviour from individuals and groups unlawfully using the quarry for recreation at present, and remove what is considered locally to be a considerable eyesore, and also supports building on brownfield sites. However, residents do not support the provision of a through road
through to the Crestwood Estate, are concerned about access to the Ketley Quarry site from the proposed road over Dawley Brook from the Ploverdale estate, and do not support the building of such a large number of houses on the quarry site.

7. Effect on school admissions (all sites). There are insufficient school places for children across the area. For September 2021 admissions, the only secondary with places for Year 7 is Wordsley. Most other year groups are full. There are no places for Reception in Wall Heath for 2021; only one school in Kingswinford with places. Creating spaces by enlarging existing schools will change the character of them, or force buildings that take away car• parking, play areas or fields.
8. Effect on NHS (all sites).

- There are not enough local doctors and dentists in the local area. Residents are being forces to travel out the area to access care. Wall Heath and Kingswinford have a number of elderly residents who cannot physically do this - due to their own capabilities and lack of public transport
- Pre-lockdown, the average waiting time at Russell's Hall was over 4 hours (2019). April '21

inspections show it still 'requires improvement.'

- Longer ambulance wait times (In 2020, the turnaround times reached 60 mins)

- Further delays in local health services, mental health services (rapidly growing), hospital treatment and operations for serious illness.
9. Effect on Mental Health (all sites). The BCP calls out that Kingswinford South and

Wordsley specifically have a below standard quantity of public open space. These spaces are very important to local residents, for many uses, but frequently including dog walking, and safe spaces for children of all ages to play and socialise, specifically they (DUH213 and DUH222) are within sight of many of the local houses, and considered safe by older residents too. Many residents purchased houses on these estates specifically because of
access to this space, and over the pandemic lockdowns the use of this space increased even further. Green spaces are proven to have a significant benefit on mental health, particularly for those who may not have gardens themselves, and they are providing more benefit than ever before.
a. The BCP identifies Ketley Field Open Space as a suitable alternate space to allow for loss of Lapwood Avenue; however, this site frequently floods (hence the recent planting of many young saplings across the field) and although it has a playground, it is of poor quality, with very little equipment for younger children, and much of the equipment that is there is damaged and broken.
b. Residents generally disagree that Ketley Fields is of higher quality and value.

c. For older residents at the opposite end of the estate, this may be too far to walk. d. The Lapwood field is generally always a busier space than the Ketley Fields space,
with more residents using it for a variety of purposes.

e. The open space review for Severn Drive (DUH222) failed to identify any activities taking place yet they it is very often used and any resident could have helped identify this, so the green space assessment is flawed.
f. The open spaces identified in the site assessment as replacements for Severn Drive (DUH222), Mayflower Drive and Derwent Close open spaces, together make up about a quarter of the space to be lost on Severn Drive, and neither are suitable in terms of terrain or shape to many of the activities carried out on Severn Drive. Neither of
these sites were large enough to be audited in the Open Space Review 2017, so the council obviously is not aware of the quality of these spaces and should not propose them as alternatives.
g. Each of the open space reviews identify that the open spaces in question suffer

in their quality/value ratings solely due to lack of council investment in them rather than lack of resident usage, which happens in spite of the lack of investment!
10. Loss of Biodiversity (all sites). Although not designated as SLINC or similar, there are frequent sightings of foxes, and bats over Lapwood Avenue, Bryce Road, and Severn Drive sites, owls are heard over all the sites every year, and numerous species of birds are observed. Loss of the sites would lead to loss or displacement of these animals.

Object

Representation ID: 23303

Received: 25/09/2021

Respondent: Mr Darren Potter

DSA3 - Ketley Quarry

Objections against building on our green spaces:
- noise overcrowding in area.
- loss of places for children to play.
- loss of dog walking places.
- if more houses are built in the area there will be more cars on the road.
- threat of wildlife.
- the GPs and hospitals will be stretched to capacity.
- pressure on schools.
- also lack of parking.
- increase of accident risk.
We need to preserve green spaces for the future

Comment

Representation ID: 23576

Received: 08/10/2021

Respondent: Urban Remediation Ltd

1.2. MAPPING/STRATEGIC ALLOCATION BOUNDARY
1.2.1. There are errors on mapping boundaries regarding allocated site DUH203 on the Black Country Draft Policies Map and also the application of the Strategic Allocation boundary. These should be rectified for clarity.
1.2.2. Both the Ketley Quarry site and Ketley Farm site were remediated in 2019/2020 and have been prepared for onward housing development. There are no physical boundaries between the two areas and indeed, they are in the same ownership. In all practical sense, they can be considered as the same site.
1.2.3. The Dudley Metropolitan Borough Council (DMBC), Strategic Housing Land Availability Assessment (SHLAA) (2019-2020) update correctly identifies both the Ketley Quarry and Ketley Farm sites in their entirety. This covers a combined area of 22Ha (see Appendix 1). The Site is identified as Site 206.
1.2.4. The Black Country Draft Policies Map only shows the boundary of the Ketley Quarry Site (DUH203). To accord with the DMBC SHLAA (2019-2020), the Strategic Allocation mapping should also incorporate the Ketley Farm site. This is referenced as Site ID 247 (Ketley Farm, Dudley Road, Kingswinford) in the Black Country Call for Sites Submissions. (see Appendix 2)
1.3. SITE ALLOCATION DETAILS
1.3.1. Clarification is necessary regarding the development areas, housing numbers and deliverability with reference to the development strategy as set out in Chapter 13 Sub Areas and Site Allocations (Section A. Dudley).
1.3.2. Table 14 Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) refers to Site reference DUH203. The Site name and address is given as Ketley Quarry/Ketley Farm, Dudley Road, Kingswinford. It has not been previously allocated and appropriate uses are noted as for housing. It identifies the indicative development capacity (net new homes) as 612 houses at 40/45 dph, The gross site area (ha) is 20.81 Ha and net site area is 13.52Ha. Anticipated delivery timescales are stated as 2024 - 2029 (50 homes), 2030 - 2035 (250 homes) and 2035 - 2039 (312 homes). It is a Strategic Allocation under Policy DSA3.
1.3.3. The Site area of Ketley Quarry and Ketley Farm is accurately measured to be 22Ha. Applying the 65% proportionality for net areas, this equates to a 14.3Ha (net) and a delivery of 644 dwellings. There are active discussions ongoing with DMBC Planning Officers as part of a pre-application process (reference PRE20/00485) with a predicted development of up to 650 dwellings. Housing availability is forecasted to commence in 2024 with an annual delivery of up to 100 dwellings per year.

Comment

Representation ID: 23577

Received: 08/10/2021

Respondent: Urban Remediation Ltd

1.5. POLICY DSA3 LAND AT KETLEY QUARRY KINGSWINFORD
1.5.1. This concerns an assumption of school provision within the Site and also the out of date Site descriptions which are used, given that it has now been remediated in preparation for housing development. We address each paragraph in turn. In addition, a submission is made from Highgate Land and Development concerning matters relating to affordable housing, viability assessment and education provision which have informed the development description in the Policy.
1.5.2. Paragraph A98 estimates delivery as 50 homes until 2029, 250 home between 2030 and 2035 and the remaining between 2035 and 2039. As noted above in Section 1.3, the estimated delivery will commence in 2024 with an annual release of approximately 100 dwellings.
1.5.3. School Place Requirements are set out in Paragraph A 103 and states 'Should it be determined that some form of primary school provision is required as the BCP progresses towards adoption, this may need to be accommodated on the site and land will need to be allocated to accommodate a two-form entry primary school (approximately 2.4ha)'. It is considered that the location of current school provision at both primary and secondary level is adequate. Existing facilities, necessary extensions to such facilities and the allocation can be met through required developer contributions.
1.5.4. Nature Conservation and Net Biodiversity Gain Requirements are set out in Paragraphs A105 and A106. The description of the Site is not correct. In fact, the quarry has been infilled and engineered in preparation for housing. Nor is it vegetated with ruderal species. Reference is made to a disused farmhouse for bat interest, however, this building has now been demolished under a previous planning consent.
1.5.5. The Site description is better represented by stating that both the Ketley Quarry site and adjacent Ketley Farm are bare of vegetation and is left as a levelled ground in readiness for future development.
1.5.6. Further submissions are made on the matters relating to the provision of affordable housing, the viability assessments undertaken as part of the Black Country Plan, education provision and related matters that are of concern in the application of Policy DSA3.these are contained in the copy of correspondence in Appendix 3.

Comment

Representation ID: 23580

Received: 08/10/2021

Respondent: Urban Remediation Ltd

Agent: Bright & Associates

1.2. MAPPING/STRATEGIC ALLOCATION BOUNDARY
1.2.1. There are errors on mapping boundaries regarding allocated site DUH203 on the Black Country Draft Policies Map and also the application of the Strategic Allocation boundary. These should be rectified for clarity.
1.2.2. Both the Ketley Quarry site and Ketley Farm site were remediated in 2019/2020 and have been prepared for onward housing development. There are no physical boundaries between the two areas and indeed, they are in the same ownership. In all practical sense, they can be considered as the same site.
1.2.3. The Dudley Metropolitan Borough Council (DMBC), Strategic Housing Land Availability Assessment (SHLAA) (2019-2020) update correctly identifies both the Ketley Quarry and Ketley Farm sites in their entirety. This covers a combined area of 22Ha (see Appendix 1). The Site is identified as Site 206.
1.2.4. The Black Country Draft Policies Map only shows the boundary of the Ketley Quarry Site (DUH203). To accord with the DMBC SHLAA (2019-2020), the Strategic Allocation mapping should also incorporate the Ketley Farm site. This is referenced as Site ID 247 (Ketley Farm, Dudley Road, Kingswinford) in the Black Country Call for Sites Submissions. (see Appendix 2)
1.3. SITE ALLOCATION DETAILS
1.3.1. Clarification is necessary regarding the development areas, housing numbers and deliverability with reference to the development strategy as set out in Chapter 13 Sub Areas and Site Allocations (Section A. Dudley).
1.3.2. Table 14 Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) refers to Site reference DUH203. The Site name and address is given as Ketley Quarry/Ketley Farm, Dudley Road, Kingswinford. It has not been previously allocated and appropriate uses are noted as for housing. It identifies the indicative development capacity (net new homes) as 612 houses at 40/45 dph, The gross site area (ha) is 20.81 Ha and net site area is 13.52Ha. Anticipated delivery timescales are stated as 2024 - 2029 (50 homes), 2030 - 2035 (250 homes) and 2035 - 2039 (312 homes). It is a Strategic Allocation under Policy DSA3.
1.3.3. The Site area of Ketley Quarry and Ketley Farm is accurately measured to be 22Ha. Applying the 65% proportionality for net areas, this equates to a 14.3Ha (net) and a delivery of 644 dwellings. There are active discussions ongoing with DMBC Planning Officers as part of a pre-application process (reference PRE20/00485) with a predicted development of up to 650 dwellings. Housing availability is forecasted to commence in 2024 with an annual delivery of up to 100 dwellings per year.

1.5. POLICY DSA3 LAND AT KETLEY QUARRY KINGSWINFORD
1.5.1. This concerns an assumption of school provision within the Site and also the out of date Site descriptions which are used, given that it has now been remediated in preparation for housing development. We address each paragraph in turn. In addition, a submission is made from Highgate Land and Development concerning matters relating to affordable housing, viability assessment and education provision which have informed the development description in the Policy.
1.5.2. Paragraph A98 estimates delivery as 50 homes until 2029, 250 home between 2030 and 2035 and the remaining between 2035 and 2039. As noted above in Section 1.3, the estimated delivery will commence in 2024 with an annual release of approximately 100 dwellings.
1.5.3. School Place Requirements are set out in Paragraph A 103 and states 'Should it be determined that some form of primary school provision is required as the BCP progresses towards adoption, this may need to be accommodated on the site and land will need to be allocated to accommodate a two-form entry primary school (approximately 2.4ha)'. It is considered that the location of current school provision at both primary and secondary level is adequate. Existing facilities, necessary extensions to such facilities and the allocation can be met through required developer contributions.
1.5.4. Nature Conservation and Net Biodiversity Gain Requirements are set out in Paragraphs A105 and A106. The description of the Site is not correct. In fact, the quarry has been infilled and engineered in preparation for housing. Nor is it vegetated with ruderal species. Reference is made to a disused farmhouse for bat interest, however, this building has now been demolished under a previous planning consent.
1.5.5. The Site description is better represented by stating that both the Ketley Quarry site and adjacent Ketley Farm are bare of vegetation and is left as a levelled ground in readiness for future development.
1.5.6. Further submissions are made on the matters relating to the provision of affordable housing, the viability assessments undertaken as part of the Black Country Plan, education provision and related matters that are of concern in the application of Policy DSA3.these are contained in the copy of correspondence in Appendix 3.

Support

Representation ID: 43812

Received: 11/10/2021

Respondent: Crestwood Park Residents Action Group

2. The potential for a through road from the Ketley Quarry site (BCP REF 203) would create a cut through shortcut between Bromley Lane and the main Dudley Road via the Ploverdale/Sandpipers estate, which would likely cause a significant increase in traffic moving through the estate not only at peak times, but at all points throughout the day, and further problems leaving the estate at the Bromley Road junction. This would significantly increase traffic, and decrease road and pedestrian safety on the estate, especially at peak school times. No through road is mentioned within the Black Country plan, but it is indicated on the site plan submitted in planning application [xxx].

I do however support the development of houses on the Ketley Quarry site, as it's expected
this will decrease anti-social behaviour from individuals and groups unlawfully using the
quarry for recreation at present, and remove what is considered locally to be a considerable
eyesore, and also supports building on brownfield sites.

Standhills Road Open Space - DUH221

15. I object to building on the Standhills Road Open Space. This will be an important boundary corridor of green space when the Ketley Quarry site is built over, and if this open space is lost, all these housing estates will merge into one. Ketley Quarry will be bordered on the Eastern Side by Dawley Brook with a retained green corridor, and it should similarly be bordered on the Western Side.

Object

Representation ID: 45356

Received: 11/10/2021

Respondent: Mr Nigel Wellings

1) SA-0050-DUD / BCP REF DUH 216 - Bryce Road (Green Space)
2) SA-0199-DUD / BCP REF DUH 222 - Severn Drive (Green Space)
3) SA-0025-DUD / BCP REF DUH 211 - Summerhill Triangle (Green Space)
4) SA-0017-DUD / BCP REF DUH 208 - Holbeache (Green Belt)
5) SA-0042-DUD / BCP REF DUH 213 - Lapwood Avenue (Green Space)
6) SA-0198-DUD / BCP REF DUH 221 - Standhills(Green Space)
7) BCP REF DUH 218 - Guys Lane
8) BCP REF 203 - Ketley Quarry (Policy DSA3)

1) SA-0050-DUD / BCP REF DUH 216 -
Absolutely fantastic ground for locals/youngsters playing sports - dog walking. Also I recall watching/seeing/observing the HAWKSHEAD MOTH catapillar along the adjacent disused "Round Oak" steelworks railway line cira 1978 - 1982 - Great Place to explore/+ History of old disused canal - please let it be. I grew up around these places :-(
2) Unsure of this - but object
3) Not to be touched - As the "Poppy Fields" are to remember! Very useful cut through for school children.
4) Perfect - GreenBelt - I'm sure Sandiacre (Richard & Anne) disapprove (my cousins)
5) Nature Reserve! (The Kracker?) High acres - Bach Pool N.R.?)
6) Football Sports Fields - Once again - which should be available for use/Local Community
7) As per #?
8) Ketley Quarry - Marc Hole - very dangerous - 50 + years but great for a green space
I'm 51 years old, and lived in Kingswinford & Pensnett all my life. We need areas to walk/play socialise. Please don't take the ("our spaces and heritage") away.

Please considere the few spaces which are remaining around Pensnett, BRockmore, Wordsley & Kingswinford. The sub-structure has now, nothings...schools, Doctors, (Aw Surgeries)…..nothing to offer. 26-09-21 - Not to mention the Road traffic!!!!
I could go on...

Object

Representation ID: 45357

Received: 11/10/2021

Respondent: Mr Nigel Wellings

1) SA-0050-DUD / BCP REF DUH 216 - Bryce Road (Green Space)
2) SA-0199-DUD / BCP REF DUH 222 - Severn Drive (Green Space)
3) SA-0025-DUD / BCP REF DUH 211 - Summerhill Triangle (Green Space)
4) SA-0017-DUD / BCP REF DUH 208 - Holbeache (Green Belt)
5) SA-0042-DUD / BCP REF DUH 213 - Lapwood Avenue (Green Space)
6) SA-0198-DUD / BCP REF DUH 221 - Standhills(Green Space)
7) BCP REF DUH 218 - Guys Lane
8) BCP REF 203 - Ketley Quarry (Policy DSA3)

1) SA-0050-DUD / BCP REF DUH 216 -
Absolutely fantastic ground for locals/youngsters playing sports - dog walking. Also I recall watching/seeing/observing the HAWKSHEAD MOTH catapillar along the adjacent disused "Round Oak" steelworks railway line cira 1978 - 1982 - Great Place to explore/+ History of old disused canal - please let it be. I grew up around these places :-(
2) Unsure of this - but object
3) Not to be touched - As the "Poppy Fields" are to remember! Very useful cut through for school children.
4) Perfect - GreenBelt - I'm sure Sandiacre (Richard & Anne) disapprove (my cousins)
5) Nature Reserve! (The Kracker?) High acres - Bach Pool N.R.?)
6) Football Sports Fields - Once again - which should be available for use/Local Community
7) As per #?
8) Ketley Quarry - Marc Hole - very dangerous - 50 + years but great for a green space
I'm 51 years old, and lived in Kingswinford & Pensnett all my life. We need areas to walk/play socialise. Please don't take the ("our spaces and heritage") away.

Please considere the few spaces which are remaining around Pensnett, BRockmore, Wordsley & Kingswinford. The sub-structure has now, nothings...schools, Doctors, (Aw Surgeries)…..nothing to offer. 26-09-21 - Not to mention the Road traffic!!!!
I could go on...

Object

Representation ID: 45449

Received: 11/10/2021

Respondent: Mr Shaun Parker

BCP Ref: DUH213, DUH216, DUH222, 203 Ketley Quarry (Policy DSA3)

Collectively I feel that there will be a significant impact on the road network, increasing traffic on already extremely busy junctions. This could give rise to road traffic incidents.
Another consideration is the effect upon local amenities which are already stretched, ie doctors surgeries, hospital, and education establishments.
In addition, in the loss of more open, green space - once lost this is never reclaimed

Object

Representation ID: 45466

Received: 04/10/2021

Respondent: Mr Stanley Pickett

SA - 0050 - DUD / BCP Ref DUH 216 - Bruce Road (Green Space)
SA - 0199 - DUD / BCP Ref DUH 222 - Severn Drive (Green Space)
SA - 0025 - DUD / BCP Ref DUH 211 - Summer Hill Triangle (Green Space)
SA - 0017 - DUD / BCP Ref DUH 208 - Holbeache (Green Space)
SA - 0198 - DUD / BCP Ref DUH 221 - Stanhills (Green Space)
BCP Ref DUH 218 - Guys Lane
BCP Ref DUH 203 - Ketley Quarry (Policy DSAS)

Wildlife will be negatively affected by loss of green belt and spaces. Too many houses will cause problems for emergency services, the traffic congestion would cause vast problems for Russels Hall hospital and local residents. People will lose valuable places to walk and exercise dogs and children have little enough safe places to play already.

Object

Representation ID: 45924

Received: 04/10/2021

Respondent: James & May Timmins

Number of people: 2

Standhills/Ketley DUH221

Myself and my husband strongly object to these plans of building new houses on the Green Belt. Especially on the Crestwood park area as there is too much traffic already on this estate and the schools will be overcrowded already.

Object

Representation ID: 45951

Received: 11/10/2021

Respondent: Ms Jan Norton

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)

[45946]


Draft Black Country Plan
Object Development Allocations, Development Allocations

has attrachmentsHas attachments
Respondent: Ms Jan Norton [7887]

Received: 11/10/2021 via Email

Summary: Severn Drive - DUH 222

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. One key issue which has been raised by members of the public in Pensnett (Severn Drive / Bryce Road) is the fact that there is no local GP practice to serve the local population. It seems bizarre that there is a plan for new homes to be built when the basic local primary care infrastructure is not in place.
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: 45962

Received: 04/10/2021

Respondent: Mr Jonathan Baker

There is an overflow of traffic now and more would cause increase in pollution.

Object

Representation ID: 46000

Received: 10/10/2021

Respondent: Geri King

I wish to object in the strongest possible terms to ANY building on green belt in the Dudley Borough area.
In the Council Scrutiny meeting on 6.10.21 your officer [Redacted- Sensitive information] admitted that NO bio diversity checks have been made or wildlife impact assessment.
Our roads are already gridlocked, schools over subscribed, GP's over subscribed, huge waiting lists at hospitals.
People need green spaces for mental health and physical fitness. The impact on the environment and climate by building over remaining green land has been underestimated. An audit of preserved or valuable trees has not been carried out.
The quality of life for existing residents will be greatly diminished, with more traffic, parking issues, nowhere to walk dogs or just take a walk in a green environment.
The plan mentions re-wilding - but where will that be as all available space is gradually eroded and built on. Why not just leave the existing habitat alone.
I do not believe that 'exceptional circumstances' apply in any of the areas listed. I do not believe that all brownfield sites have been identified. I do not believe that all empty Council houses that could be refurbished have been. It is clear that if there is a shortage of land that there should be a preference or flats or maisonettes thereby creating more housing from the same brownfield plot.
A question was also raised in the Scrutiny meeting regarding the data upon which the housing requirement has been calculated. Dudley Council should ask for this to be reviewed particularly post Brexit and post pandemic.

Listed as follows please register my objection
DUH208 Holbeache

DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane

DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

I strongly object to the Conclusions in the draft plan that do not protect our greenbelt and green spaces in Dudley borough, by assessing sites there as suitable for development.