Table 1 – Black Country Plan - Objectives and Strategic Priorities

Comment

Representation ID: 11254

Received: 28/09/2021

Respondent: Mrs Catherine Wilson

The site WAH231, Sutton Rd/ Longwood Lane is unsuitable.
50% of proposed development is owned by Friel and a resident of Sutton Rd who were never consulted and do not support it. Why was this site included in plan before the owners were consulted?
Sutton Rd will not be able to cope with any increase in traffic as it is very busy and congested already. Extra pollution from increased traffic will be a serious health risk to residents.
Local schools will be unable to accommodate any increase in pupils.
Green space , vital for health and wellbeing will be lost.

Object

Representation ID: 11384

Received: 30/09/2021

Respondent: Mr David Miller

Why isn't food security mentioned. It's the easiest method for helping to mitigate climate change

Comment

Representation ID: 11552

Received: 06/10/2021

Respondent: Mrs Emily Curtis

Health and Wellbeing - I don't find 3/4 of my surroundings have a great affect on my mental health The fly tipping and litter is overwhelming. People openly take drugs along our school routes.

Object

Representation ID: 11592

Received: 07/10/2021

Respondent: Mrs Frances Deakin

Flawed policy, which does not investigate or outline infrastructure in the proposed areas - schools, doctors, hospital capacity, roads, water, sewage, flooding.
Building on green belt is not providing affordable housing for Black Country residents - it just gives to those who can afford expensive houses, and a huge profit to building contractors.
Looks at regenerating high streets, changing building use, and be more imaginative- this plan is more of the same - driving those who can afford to live closer to the country out, and leaving many residents in run down and under funded towns.

Comment

Representation ID: 11715

Received: 08/10/2021

Respondent: Woodsetton Charitable Trust

Greater Priority needs to be given to Conserving and Improving Open Space in the Black Country

Comment

Representation ID: 11808

Received: 09/10/2021

Respondent: Mrs Marilyn Aspinall

Two aspects are of particular concern to me
Can we rely on the number of houses government says must be built? Are figures accurate given the recent impact of people leaving the country following Brexit and the death toll of Covid. Doesn't empty retail space offer potential conversion to homes?
Secondly, to combat climate change we must plant more trees and hedgerows, not build over green spaces.

Object

Representation ID: 11819

Received: 09/10/2021

Respondent: Mr Richard Knight

There appears to be evidence that this plan will fail to meet the Black Country's strategic objectives and in some cases have a negative impact.

Object

Representation ID: 12057

Received: 10/10/2021

Respondent: Miss Kim Barrow

Building houses on Queslett Road seats will only destroy the natural surroundings and habitats of wildlife, destroying the natural environment.
It will also create chaos on the surrounding roads which are all busy and speeding is rife, as evidenced by the fact that the police regularly monitor this area for speeding traffic.

Object

Representation ID: 12124

Received: 11/10/2021

Respondent: Mr nicolas crombie

The NPPF sets out the strategic policies to be contained within a local plan

these are
a) housing
b) infrastructure
c) community facilities
d) conservation, enhancement of the natural, built and historic landscapes and green infrastructure, planning measures to address climate mitigation and adaptation

the tabulation of objectives sets out strategic priorities in terms of preferred outputs and generally fails to identify policy outcomes in terms of quality of provision, opportunities and aspirations for residents and nature , quality of place.

The use of the term climate change is outdated and should be reviewed.

Comment

Representation ID: 16550

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Strategic Priorities: (BC Plan pg. 10-70)
As part of Dudley MBC’s priorities, we urge you to embed the following Climate
Emergency principles in all areas of policy and practice:
• Put our climate at the heart of all local decision making: Develop a
Climate Action Plan with measurable targets to address Dudley’s Climate
Emergency.
• Protect the most vulnerable: to ensure that those most vulnerable to the
effects of climate change are properly supported and protected.
• Land Use and Nature: restore nature to increase biodiversity, help
drawdown carbon pollution from the atmosphere and to ensure everyone has
access to nature in nearby green spaces
• Transport: reduce air pollution to meet World Health Organisation levels.
Match European best practice in the use of public transport; trains; buses;
cycling and walking and ensure all vehicles are zero emission.
• Power: enable and support the growth and use of green energy, ensure
energy is not wasted and prevent the development of new fossil fuel
extraction. Make a commitment to net zero carbon emissions by 2030
and ensure political commitment is in line with Climate Change Act carbon
budgets.
• Buildings: ensure all homes are well insulated to minimum EPC C level,
eradicate fuel poverty as fast as possible and make a proportional
contribution to the 1 million eco-heating heat pumps that need to be fitted in
the UK each year.
• Waste: achieve a zero-waste area by 2030 where all waste reused or recycled as
part of a circular economy approach.
• Influencing others: encourage and support other entities with their
contribution to the fight against the climate emergency.
• Resources and raising money: have sufficient resource to invest in the
changes needed to substantially improve Dudley MBC’s performance, restore
nature and meet climate goals so that Dudley Borough can reap the dividends
and deliver our fair share of greenhouse gas reductions.

Object

Representation ID: 16857

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

The Plan does not include a target for reaching net-zero carbon emissions.
This should be included in a Strategic Climate Change Policy which is one of
the strategic CSP policies and the location of all developments in the plan
should be tested against that target. We consider that while CC1 and the
subsequent policies on Climate Change are welcome in general terms the
urgent need to reduce emissions is relegated in the plan against other goals,
notably housing and economic targets. Unless climate change is central to the
plan, we do not believe it fulfils its role in assisting to meet the urgent
national and international need to reduce emissions so as to avoid
catastrophic climate change.

Support

Representation ID: 17519

Received: 11/10/2021

Respondent: Sport England

Sport England supports the inclusion of Strategic Priorities 5 (relating to health and well-being, physical activity, active travel etc), 10 (active travel), and 15 (infrastructure needs), as they relate well to Sport England's new strategy : Uniting the Movement. https://www.sportengland.org/why-were-here/uniting-the-movement

Comment

Representation ID: 18503

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment:
- Climate Change: WTBBC welcome enhancing the Black Country’s Green and Blue Infrastructure, however, investing in nature-based solutions should also be included.
- Improving the Health and Wellbeing of residents and promoting social inclusion: WTBBC welcome providing a built and natural environment that supports the making of healthier choices, however, equal access for all to high quality natural green space should also be included.
WTBBC welcome providing a natural environment that protects health and wellbeing and the reference to the benefits to society this provides.
Comment:
- Enhancing our natural & built environment: WTBBC welcome the protection and enhancement of the natural environment, biodiversity, wildlife corridors, geological resources, countryside, and landscapes, whilst ensuring that residents have good access to interlinked green infrastructure.
WTBBC welcome protecting, sustaining and enhancing the quality of the built and historic environment whilst ensuring the delivery of distinctive and attractive places.
WTBBC are of the view, however, that the BCP would be stronger if the built and natural environment are included as separate objectives.

Support

Representation ID: 20972

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Objectives and Strategic Priorities
DB welcomes the inclusion of ‘Housing that meets all our needs’ as a Strategic Priority and consider themselves well placed to assist with helping meet these needs. We return to this point below.

Comment

Representation ID: 22184

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

We welcome the inclusion of ‘Housing that meets all our needs’ as a Strategic Priority. In order for this priority to be met it is imperative that the housing delivery strategy within the emerging Plan is robust and based on an appropriate evidence base. However, as detailed in our response to Policy CSP1 below, we are concerned that the housing requirement in the Plan is insufficient to meet the Black Country’s growth requirements. In addition, the sources of housing supply that have been identified will not deliver the quantum of housing that is suggested. There is, however, additional land that is suitable for allocation to help address the housing requirement, such as the land being promoted for development by the Club.

Comment

Representation ID: 22239

Received: 11/10/2021

Respondent: Steve Crutchley

Objectives and Strategic Priorities

We welcome the inclusion of ‘Housing that meets all our needs’ as a Strategic Priority. In order for this priority to be met it is imperative that the housing delivery strategy within the emerging Plan is robust and based on an appropriate evidence base. However, as detailed in our response to Policy CSP1, we are concerned that the housing requirement in the Plan is insufficient to meet the Black Country’s growth requirements. In addition, the sources of housing supply that have been identified will not deliver the quantum of housing that is suggested. There is, however, additional land that is suitable for allocation to help address the housing requirement, such as our client’s site at Barr Beacon. The case for the allocation of this site is set out in this letter.

Support

Representation ID: 22264

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Objectives and Strategic Priorities

2.2 The Vision is supported by eight objectives and the policies that will be most important in achieving each objective and the Black Country Authorities’ strategic priorities. These include, but are not limited to, the provision of housing that meets all our needs and enabling a strong, stable and inclusive economy. We agree that the strategic priorities and objectives set out provide a positive vision and a framework for local people to shape their surroundings.

Support

Representation ID: 22368

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Objectives and Strategic Priorities
RSL fully support the 8 Objectives and 15 Strategic Priorities identified in Table 1, as these have been informed by the challenges that the Black Country Authorities (BCA) are likely to face over the Plan period, and provide a clear structure against which individual policies and proposals within the BCP can be developed, thereby helping to maximise their effectiveness.

Comment

Representation ID: 23185

Received: 11/10/2021

Respondent: Historic England

Page 23, Strategic Policy 12 – on built and historic environment – suggest amend ‘sustain’ with ‘protect’. We encourage looking at protecting the significance of heritage assets and assessing cultural heritage. Ensuring not just built assets but also landscape and features etc

Comment

Representation ID: 46173

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The identification of sites proposed for development should have regard to the vision and objectives of a plan, in this instance the strategic priorities and objectives of the draft Black Country Plan, taking account of national policy and guidance and other material considerations and the need to minimise the impact of climate change whilst adapting to its effects and mitigating is current and potential future impacts.

Comment

Representation ID: 46174

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Strategic Priority 3 (within the objective Housing that meets all our needs) is to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents.
Strategic Priority 3 should be explicit that meeting the needs of current and future residents requires a strategic policy-making authority to establish a housing requirement figure or its whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.

It is important for Strategic Priority 3 to be set within the context of the requirement upon a strategic plan making authority to identify sufficient land for homes.

Strategic Priority 3 should commit to meeting this obligation of identifying sufficient land for homes.

Support

Representation ID: 46175

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Strategic Priority 4, to improve and diversify the Black Country housing offer, is supported.