Development Allocations

Object

Representation ID: 45946

Received: 11/10/2021

Respondent: Ms Jan Norton

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: 45947

Received: 11/10/2021

Respondent: Ms Jan Norton

Bryce Road - DUH 216

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: 45948

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: 45949

Received: 11/10/2021

Respondent: Ms Jan Norton

Wollaston Farm DUH 217

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: 45950

Received: 11/10/2021

Respondent: Ms Jan Norton

Bent Street - DUH 215

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: 45952

Received: 11/10/2021

Respondent: Ms Jan Norton

Standhills Road - DUH 221

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: 45953

Received: 11/10/2021

Respondent: Ms Jan Norton

Standhills Road - DUH 221

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: 45956

Received: 04/10/2021

Respondent: Mr Jonathan Baker

[Severn Drive - DUH 222]

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

Object

Representation ID: 45959

Received: 04/10/2021

Respondent: Mr Jonathan Baker

[Lapwood Avenue - DUH213

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

Object

Representation ID: 45960

Received: 04/10/2021

Respondent: Mr Jonathan Baker

[Standhills - DUH221]

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

Object

Representation ID: 45961

Received: 04/10/2021

Respondent: Mr Jonathan Baker

[DUH 218 - Guys Lane]

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

Object

Representation ID: 45963

Received: 24/09/2021

Respondent: Mrs Beryl Baldock

[No site specific reference given]

Building on these green spaces will encourage more traffic and it's a thing we don't want (we have enough already) so it will put more pressure on our schools and emergency services so you need trees and green spaces for your mental health.

Support

Representation ID: 45964

Received: 11/10/2021

Respondent: Jayne and Olivia Marsh

Number of people: 3

I support site Brick kiln pastures S005 DudB and SA0153-DUD not being included to be released from greenbelt due to being an area of protected environment, SLINC Wallows Wood Pastures. and has ancient woodland, and historic environmental records Nic himley colliery and gornalwood railway, site of askew bridge ref Dud
Dudley and Bob’s brook being in floodplain 3. it is also entirely SINC an absolute constraint GB04 greenbelt policy .

Object

Representation ID: 45965

Received: 11/10/2021

Respondent: Jayne and Olivia Marsh

Number of people: 3

I object STRONGLY to site DUH 031 DBDS.NETH.H13 The Straits Lower Gornal being included for housing as it is a greenfield paddock ,adjoining Staffordshire greenbelt with poor access to site and has been rejected for planning permission 7 times since 1960s .It is by a blind junction .
The doctors closed many years ago, so access to doctors is very poor ,we have one hourly bus that finishes early evening and does not start early enough to get to work without taking car. There will be impact to adjoining houses for light pollution, noise and impact on the environment as the field adjoins grazing land with a huge diversity of wildlife including [Redacted-sensitive information] etc and adjoins the neighbouring SLINC of Wallows Wood pastures. Any building will affect the environment of these adjoining sites ENV 1

Object

Representation ID: 45966

Received: 11/10/2021

Respondent: Jayne and Olivia Marsh

Number of people: 3

DUH218

I strongly object to sites DUH 218 Guys Lane,DUH210 Viewfield Crescent and DUH031 The Straits, Lower Gornal Additionally DUH 208 Holbeach and DUH 211 Summerhill Triangle , all being chosen to be released from greenbelt/greenfield when Dudley does not have a need for additional housing but Sandwell does. Build where the need is ,rather than displace families and take them from their family locations, jobs,and family environment, causing additional car journeys to return back to their jobs, families and friends, that surely is not helping the environment. It is not NPPF compliant I hope you take note of my comments and decide not to release greenbelt/greenfield and to not enforce duty to cooperate on south Staffordshire greenbelt bordering Dudley.

Object

Representation ID: 45967

Received: 11/10/2021

Respondent: Jayne and Olivia Marsh

Number of people: 3

DUH 210

I strongly object to sites DUH 218 Guys Lane,DUH210 Viewfield Crescent and DUH031 The Straits, Lower Gornal Additionally DUH 208 Holbeach and DUH 211 Summerhill Triangle , all being chosen to be released from greenbelt/greenfield when Dudley does not have a need for additional housing but Sandwell does. Build where the need is ,rather than displace families and take them from their family locations,jobs,and family environment, causing additional car journeys to return back to their jobs, families and friends, that surely is not helping the environment.It is not NPPF compliant I hope you take note of my comments and decide not to release greenbelt/greenfield and to not enforce duty to cooperate on south Staffordshire greenbelt bordering Dudley.

Comment

Representation ID: 45968

Received: 11/10/2021

Respondent: Jayne and Olivia Marsh

Number of people: 3

DUH031

I strongly object to sites DUH 218 Guys Lane,DUH210 Viewfield Crescent and DUH031 The Straits, Lower Gornal Additionally DUH 208 Holbeach and DUH 211 Summerhill Triangle , all being chosen to be released from greenbelt/greenfield when Dudley does not have a need for additional housing but Sandwell does. Build where the need is ,rather than displace families and take them from their family locations,jobs,and family environment, causing additional car journeys to return back to their jobs, families and friends, that surely is not helping the environment.It is not NPPF compliant I hope you take note of my comments and decide not to release greenbelt/greenfield and to not enforce duty to cooperate on south Staffordshire greenbelt bordering Dudley.

Object

Representation ID: 45971

Received: 05/10/2021

Respondent: Mr Mark Dunckley

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:

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

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

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

Object

Representation ID: 45972

Received: 08/10/2021

Respondent: Marilyn Tennant

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:

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

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

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

Object

Representation ID: 45973

Received: 11/10/2021

Respondent: Miss Kerri Leeson

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:
Public open space: The site is located within Community Forum 7, where there is a below average quantity of open space. It was well-used by local residents in the past for informal recreation and has a high value to the local community. I believe the site should be re-opened to the public to provide a much-needed green space in this area. The site could additionally be enhanced for nature, for example by developing it as a wildflower meadow.

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

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

Object

Representation ID: 45974

Received: 11/10/2021

Respondent: Mrs Kay Cook

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:

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

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

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

Object

Representation ID: 45975

Received: 05/10/2021

Respondent: Ms Maxine Palmer

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:

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

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

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

Object

Representation ID: 45976

Received: 11/10/2021

Respondent: Mr Mike Davis

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.
I object to the allocation of the above site for development on the following bases:

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

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

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

Object

Representation ID: 45977

Received: 11/10/2021

Respondent: Member of Parliament

I am writing to oppose proposed development on several sites in my parliamentary constituency of Stourbridge, covering two main areas:


- Former grazing land at Wollaston Farm (Ref: DUH217)


I object to these proposals on four main grounds: -

1. Brownfield First
The Prime Minister has recently said that we should be "building beautiful homes on brownfield land in places that make sense". I agree completely with his statement.
I believe that the region should also adopt a brownfield first policy so these unnecessary proposals can be stopped.
I have always believed very strongly in building on brownfield sites before any green belt site can be considered. It is my belief that there is more work to be done to identify brownfield sites in the Dudley Borough. In this way, the homes earmarked for the sites could be built elsewhere, preserving precious green belt for residents.
Not only does this preserve existing green belt sites, but it also regenerates and invigorates areas that have often been left to decay or have at the very least been grossly underused. In my view, extra resources deployed to identifying and analysing brownfield sites would considerably outweigh the damage that could be done to green belt land. Evidence has also shown that building on these sites is often quicker than building on green belt sites.
The West Midlands Combined Authority (WMCA) has also secured £33m from the Brownfield Housing Fund (BHF), which allocates cash to bring old industrial sites back into use. Whilst I note this will not reduce housing targets in the Black Country Plan, it is a welcome move to expedite the use of brownfield sites that require remediation over releasing land from the Green Belt.

2. Preventing Urban Sprawl and Building Back Beautiful
We need housing targets reduced in the region to stem the flood of high-density development, which is creating immense pressure in commuter areas and our infrastructure and creating urban sprawl.
In 2017, Birmingham City Council adopted its Development Plan which paved the way for a monolithic urban extension of 6,000 homes on green belt land, mainly in Sutton Coldfield. The plan failed to consider thousands of negative responses during the consultation. It is expected that only around 2,000 – perhaps fewer – will be delivered by the Plan's end date of 2031. Residents have been left with a plan that fails to address the real housing need of local people.
There is a real risk the same could happen should the Black Country Plan be approved in its current state. An increasing body of evidence supports the fact that increasing densification and fragmentation of green spaces, propagated by 'filling in the gaps' around urban development, feeds a plethora of negative outcomes. These include increased traffic congestion (with the resultant pollution), greater energy use and the destruction of wildlife habitats.
These points are particularly relevant to site ref DUH217 (though sites DUH206, 207 and 209 also suffer) at Wollaston Farm – a slither of green space amongst hundreds of other homes. As well as the negative consequences mentioned above, development here would further degrade the distinctiveness and character of the area. A hard to measure metric, but certainly one that is mentioned time and again by residents.
For many years, urbanism has been turbo-charged with a mandate for place-making on the edge of our cities. We must let the environment be the turbo-charge for future place-making and build homes for the future that are truly environmentally led and that reflect both the surrounding community and the land that is used.

3. The value of Green Belt land
Green belt land is precious and once lost can almost never be reclaimed.
National Planning Policy Framework (NPPF) Section 13: Protecting Green Belt Land – Paragraphs 137-151. The policy makes it very clear that “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
That Green Belt boundaries should only be altered where exceptional circumstances exist. It is not clear what the exceptional circumstances are thought to be for the inclusion of DUH206, 207,209 and 217 in the plan.
Each piece of green belt land lost to development degrades the environment and weakens the long-term health of our communities.
As well as being a rich habitat for many different species, we cannot undervalue the benefits to our mental health that green spaces provide. Throughout the pandemic, people have been telling me how useful walking in the fields and in nature have been to their mental health. If ever there is a time to protect local green space, it is now. Living near a piece of land on which you can walk freely in the fresh air is a necessity in a major residential area. Each site I have mentioned in this response falls within this category. In a Borough which has been historically highly industrialised, local people defend their green spaces vigorously for these reasons.
Whilst both the Wollaston site and the Pedmore sites share these benefits, each has its own unique risks. The Wollaston site, Ref DUH217, as I have mentioned, is a green oasis in an otherwise built-up area. To build here would be to remove access to rare green space in a heavily residential area. In Pedmore, the sites Ref DUH206, 207 and 209 enhance the character of the area. People value the green space dividing Hagley and Pedmore, and many move to the area for its benefits. Similarly, visitors to the area are attracted from nearby Birmingham and Wolverhampton to enjoy the more rural surroundings.
Importantly if the land is released, it would mean houses in the wrong place –denying people the chance of home ownership, leaving many in a long term rental trap. It leaves people without aspirational living. It would leave a region bordering on urban sprawl.

4. Infrastructure
Services are under pressure in and around Stourbridge, so much so that any increase in population could push at-risk infrastructure past a tipping point. Schools, GP surgeries, dentistry, social care, parking, and emergency services are all under pressure. Without sufficient provision to support an increased population, any housing development – whether on green belt or not – should be seriously questioned.
In addition, traffic is a major and worsening issue in Stourbridge. Congestion throughout the area causes disruption and environmental damage. Some roads in Stourbridge are amongst the worst for air pollution in the Borough. There is no doubt that further significant development, resulting in hundreds more cars on local roads, will worsen the local situation. More specifically, considering sites DUH206, 207 and 209, Worcester Lane – a busy, single track road - would struggle to support any further service roads to residential developments. The same could be said for Kingsway in Wollaston, which is also very close to a local school.

Object

Representation ID: 45978

Received: 10/10/2021

Respondent: Mrs Lynn Sawyer

Site: DUH217, Grazing Land Wollaston Farm, Stourbridge.

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

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

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

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

Object

Representation ID: 45979

Received: 10/10/2021

Respondent: Mr John Coyne

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

Object

Representation ID: 45980

Received: 08/10/2021

Respondent: Mr Terry Davis

[Worcester lane]

I object to the removal of land from the Green Belt at Wollaston Farm and Worcester Lane in Stourbridge before all brownfield sites have been developed and existing approvals of development in Stourbridge have been implemented. These proposed reductions in the Green Belt are inconsistent with the need to reduce air pollution and to tackle climate change.
I am especially concerned about the proposal to allow another 115 houses to be built in Worcester Lane. Such development would be bound to increase traffic along Redlake Road which is used as southern bypass by drivers who want to avoid Stourbridge Town Centre on their way to Lye, Brierley Hill and Dudley or to Sandwell, West Bromwich or Birmingham. The increased traffic from Worcester Lane would increase air pollution with consequent effects on the health of residents in Redlake Road. If the land in Worcester Lane is no longer required for agriculture, I would prefer it to be used for planting trees and the creation of a new wood which would improve the environment for everyone in the area

Object

Representation ID: 45981

Received: 08/10/2021

Respondent: Nikki Roadley

DUH222 Severn Drive

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

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

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

Object

Representation ID: 45982

Received: 08/10/2021

Respondent: Nikki Roadley

DUH213 Lapwood Avenue

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

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

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

Object

Representation ID: 45983

Received: 08/10/2021

Respondent: Nikki Roadley

DUH218 Guys Lane

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

Listed as follows please register my objection
DUH208 Holbeache
DUH211 Summerhill Triangle
DUH216 Bryce Road
DUH222 Severn Drive
DUH213 Lapwood Avenue
DUH218 Guys Lane
DUH221 Standhills Road
DUH203 Ketley Quarry (policy DSA3)
DUH206 Worcester Lane
DUH207 Worcester Lane Central
DUH209 Worcester Lane South
DUH217 Wollaston Farm grazing land
DUH210 Viewfield Crescent
DUH041Two Gates Lane Cradley
DUH212 Lewis Road Lye
DUH214 Seymour Road Wollescote
DUH215 Bent Street Brierley Hill

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