Draft Black Country Plan

Comment

Representation ID: 17504

Received: 11/10/2021

Respondent: Kinver Parish Council

In general, we welcome the Local Plan, which sets out a planning framework for the entire Black Country. We support most of the policies relevant to rural areas such as Kinver and the edge of the Black Country, but do have reservations about some of the proposed allocations and potential policy implications in the wider area. Our concerns are set out in this letter.

As the neighbourhood plan qualifying body for Kinver Parish Council, we have embarked on the preparation of a neighbourhood plan. There is clearly a requirement for the local planning authority and neighbourhood plan body
to work in close liaison. The comments contained in this representation have been prepared against that context.

Comment

Representation ID: 17505

Received: 11/10/2021

Respondent: Kinver Parish Council

Highways Impact from Proposed Site Allocations:
In particular, sites DUH208 will have a serve impact on traffic on A449, an already busy road in both directions and will impact in South Staffs as detailed below as will site DUH211:

• Modeling and impact assessment on the wider highway network, including into Staffordshire and especially the intersection between the A458 Bridgnorth Road and A449 where there is already a
considerable volume of local traffic.
• Mitigation or necessary planned infrastructure improvements ahead of strategic allocations required to avoid a chicken and egg situation.
• Particular reference to A449 junction at Stourton, currently there is limited evidence to indicate mitigation, potential flow rates etc.

• Our community feedback makes clear that any right turn from the southern carriageway of the A449 onto the A4101 at peak times results in standing queuing traffic. This is adjacent to a proposed site allocation (DUH211 } and would therefore require junction improvements prior to any application or future development not to exacerbate existing issues on the main highway network. At present this is a serve impact on the movement of traffic along the A449. The free flow of traffic at and around this junction is of considerable concern to Kinver residents as it is the most direct route to both Russells Hall hospital and Moss Grove surgery (the group practice serving Kinver).

Comment

Representation ID: 17506

Received: 11/10/2021

Respondent: Kinver Parish Council

Highways Impact from Proposed Site Allocations:
In particular, sites DUH208 will have a serve impact on traffic on A449, an already busy road in both directions and will impact in South Staffs as detailed below as will site DUH211:

• Modeling and impact assessment on the wider highway network, including into Staffordshire and especially the intersection between the A458 Bridgnorth Road and A449 where there is already a
considerable volume of local traffic.
• Mitigation or necessary planned infrastructure improvements ahead of strategic allocations required to avoid a chicken and egg situation.
• Particular reference to A449 junction at Stourton, currently there is limited evidence to indicate mitigation, potential flow rates etc.

• Our community feedback makes clear that any right turn from the southern carriageway of the A449 onto the A4101 at peak times results in standing queuing traffic. This is adjacent to a proposed site allocation (DUH211 } and would therefore require junction improvements prior to any application or future development not to exacerbate existing issues on the main highway network. At present this is a serve impact on the movement of traffic along the A449. The free flow of traffic at and around this junction is of considerable concern to Kinver residents as it is the most direct route to both Russells Hall hospital and Moss Grove surgery (the group practice serving Kinver).


Proposed Site Allocation DUH211:


We find the following:


• Please explain the reason behind the coalescence.
• The considerations for this site fails to reflect the impact on adjoining areas outside of the plan boundary.
There is no reference to how this site fits with the South Staffs development strategy.
• Removal of green belt how does this comply with NPPF framework?
• Eroding the defensible and policy boundaries (such as green belt to prevent against urban sprawl).
• We would encourage the A449 to be established as the defensible boundary to protect any further impact on removal of additional green belt.
• A design brief in policy that should be created to ensure that the edge of any new development against the A449 boundary is loose in urban gain, maintains the existing established hedgerows and provides a soft transition into the open countryside from the urban area to the east.

Comment

Representation ID: 17507

Received: 11/10/2021

Respondent: Kinver Parish Council

Proposed Site Allocation DUH217:


• Any proposed site allocation that includes land to be released from the green belt must demonstrate how other sites of previously developed land have been discounted and what the rationale is to release this directly.
• Make clear how this site fails the 5 purposes of the Green Belt to enable the site to be allocated.
• It is an important green barrier between the two counties.
• The site includes substantial trees, mature established hedgerows.
• There is no existing vehicular access to the site to enable the development. How are you intending to gain access?
• High biodiversity value and wildlife within the green wedge in an urban area.
• Mature hedgerows are important to wildlife and must be maintained

Comment

Representation ID: 17508

Received: 11/10/2021

Respondent: Kinver Parish Council

Strategic Employment Areas:


• The evidence base has been revised from 2017 in 2021 to reflect post Covid-19 changes. The Employment Land Supply Technical Paper identifies a shortfall of land availability and a reliance on neighbouring areas to meet the need in full. How is this being addressed with South Staffs and what are the implications for the neighbouring authorities?

Comment

Representation ID: 17509

Received: 11/10/2021

Respondent: Kinver Parish Council

Removal of Green Belt:


• Eroding the defensible and policy boundaries (such as green belt to prevent against urban sprawl) has a detrimental impact on the wider area.
• Do all the proposed strategic allocations that necessitate green belt release fail to meet the 5 purposes of green belt set in the NPPF? The evidence base does not make clear how the sites to be released fail part or all of the purposes.

Support

Representation ID: 22072

Received: 11/10/2021

Respondent: Kinver Parish Council

Planning and Compulsory Purchase Act 2004
Town and Country Planning (Local Planning) Regulations 2012
Black Country Plan Consultation – Regulation 18 Response of Kinver Parish Council

We are writing in response to the proposed Black Country Plan, Regulation 18 consultation.

In general, we welcome the Local Plan, which sets out a planning framework for the entire Black Country. We support most of the policies relevant to rural areas such as Kinver and the edge of the Black Country, but do have reservations about some of the proposed allocations and potential policy implications in the wider area. Our concerns are set out in this letter.

Comment

Representation ID: 22073

Received: 11/10/2021

Respondent: Kinver Parish Council

Highways Impact from Proposed Site Allocations:
In particular, sites DUH208 will have a serve impact on traffic on A449, an already busy road in both directions and will impact in South Staffs as detailed below as will site DUH211:

• Modeling and impact assessment on the wider highway network, including into Staffordshire and
especially the intersection between the A458 Bridgnorth Road and A449 where there is already a considerable volume of local traffic.
• Mitigation or necessary planned infrastructure improvements ahead of strategic allocations required to avoid a chicken and egg situation.
• Particular reference to A449 junction at Stourton, currently there is limited evidence to indicate mitigation, potential flow rates etc.

• Our community feedback makes clear that any right turn from the southern carriageway of the A449 onto the A4101 at peak times results in standing queuing traffic. This is adjacent to a proposed site allocation (DUH211) and would therefore require junction improvements prior to any application or future development not to exacerbate existing issues on the main highway network. At present this is a serve impact on the movement of traffic along the A449. The free flow of traffic at and
around this junction is of considerable concern to Kinver residents as it is the most direct route to both Russells Hall hospital and Moss Grove surgery (the group practice serving Kinver).

Comment

Representation ID: 22074

Received: 11/10/2021

Respondent: Kinver Parish Council

Proposed Site Allocation DUH211:

We find the following:

• Please explain the reason behind the coalescence.
• The considerations for this site fails to reflect the impact on adjoining areas outside of the plan boundary. There is no reference to how this site fits with the South Staffs development strategy.
• Removal of green belt how does this comply with NPPF framework?
• Eroding the defensible and policy boundaries (such as green belt to prevent against urban sprawl).
• We would encourage the A449 to be established as the defensible boundary to protect any further impact on removal of additional green belt.
• A design brief in policy that should be created to ensure that the edge of any new development against the A449 boundary is loose in urban gain, maintains the existing established hedgerows and provides a soft transition into the open countryside from the urban area to the east.

Proposed Site Allocation DUH217:

• Any proposed site allocation that includes land to be released from the green belt must demonstrate how other sites of previously developed land have been discounted and what the rationale is to release this directly.
• Make clear how this site fails the 5 purposes of the Green Belt to enable the site to be allocated.
• It is an important green barrier between the two counties.
• The site includes substantial trees, mature established hedgerows.
• There is no existing vehicular access to the site to enable the development. How are you intending to gain access?
• High biodiversity value and wildlife within the green wedge in an urban area.
• Mature hedgerows are important to wildlife and must be maintained

Comment

Representation ID: 22075

Received: 11/10/2021

Respondent: Kinver Parish Council

Strategic Employment Areas:

• The evidence base has been revised from 2017 in 2021 to reflect post Covid-19 changes. The Employment Land Supply Technical Paper identifies a shortfall of land availability and a reliance on neighbouring areas to meet the need in full. How is this being addressed with South Staffs and what are the implications for the neighbouring authorities?