Draft Black Country Plan

Comment

Representation ID: 22076

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.

Comment

Representation ID: 22077

Received: 11/10/2021

Respondent: Kinver Parish Council

Duty to Cooperate
We note the plan indicates a shortfall of circa 28000 new homes and feel:

• There is a presumption that these can be accommodated in adjacent authorities.
• This appears to be an over reliance on the duty to cooperate (which may not remain a statutory obligation in the future).
• Has the impact of increasing the pressure to release neighbouring protected Green Belt sites.

Comment

Representation ID: 22078

Received: 11/10/2021

Respondent: Kinver Parish Council

Flood Risk and Water Quality:
• We welcome the revised policy CC6 Sustainable drainage and surface water management to protect the
blue infrastructure of the plan area and wider water catchment including the river Stour and its tributaries.

Comment

Representation ID: 22079

Received: 11/10/2021

Respondent: Kinver Parish Council

In conclusion, we feel the key issues for the adjacent parish of Kinver are:

• The lack of liaison with Kinver Parish Council as a statutory planning body. Kinver parish is in the process of making a neighbourhood plan.
• Lack of evidence and modelling to demonstrate the impact of additional traffic movement on the
main highway network including the A449 and roads off.
• The premature decision to remove land from the Green Belt, before it is established that it is capable of being developed.
• Increasing development pressure in Kinver, and the further erosion of Green Belt land.