Draft Black Country Plan

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Support

Draft Black Country Plan

A. Dudley

Representation ID: 23086

Received: 07/10/2021

Respondent: Halesowen Abbey Trust

Representation Summary:

Celebrating Halesowen's Countryside
Black Country Plan Consultation
The Halesowen Abbey Trust supports the Green Belt designation of countryside in our Area of Benefit, as shown on page 14 of our attached report, following the Green Belt review and assessments.
For many years, the Trust worked with Dudley Council to improve this historic countryside, which is an important amenity serving a large population. We will provide a comprehensive report, in due course to explain our support in more detail. In the meantime, I attach a report, dated March 2020, titled,
'Celebrating Halesowen's Countryside', which explains the trials, tribulations and pleasure we have
experienced in respect of this countryside.
Will you please acknowledge our support by confirming safe receipt of this email and attachment?
'When any of the jaded toilers in the district known as the Black Country have an afternoon to spare, and feel that a few hours passed amidst the beauties of nature would be a benefit to them, there is nothing more natural than that they should travel by train to Hagley Station, or obtain a horse and conveyance, and proceed with as little delay as possible to the foot of Adam's Hill, Clent, in preference to taking a much longer and more troublesome journey elsewhere with no better result. The time occupied in reaching Clent from the surrounding populous districts is so comparatively short, and the neighbourhood around Clent Hill so beautiful, that it is pre-eminently the place to select for the popular day or half-day outing.'
Clent, 1910 - E Blocksidge, Stone St, Dudley.
We are fortunate to have beautiful countryside adjacent to and within Halesowen. It is an important informal recreational and educational resource for the region and has hitherto been formally recognised for its historic; landscape and ecological importance.
Recognition pre-dates the modern era. The Premonstratensian Canons of Halesowen Abbey, noted for their love of natural beauty, chose the site that was later known as Lapal - derived from the French 'la' added to the Anglo Saxon 'pol', meaning 'the pool' - A clear reference to the fishponds created for the Abbey. The Canons occupied the Abbey from 1218 until the dissolution of 1538. The remains of the Abbey were scheduled as an Ancient Monument as early as 1915 - in recognition of the importance of the site.
We are fortunate that the remains are preserved in their original rural setting, which is important to the character and identity of historic Halesowen.
Unsurprisingly, the Dudley Historic Environment Record indicates an unusually high incidence of entries, ranging through the mesolithic; bronze and iron ages, as well as the Romano-British and mediaeval periods. There may have been a substantial Roman Villa.
It has long been accepted that any disturbance of the ground, at, or in the vicinity of Manor Farm, is likely to reveal artefacts of archaeological significance.

Watching Brief for Erection of a New Barn at Manor Farm - 2008/2009
The owner of Manor Farm was granted planning permission for the erection of a large modern barn, just outside of the scheduled area of the monument but in close proximity to the Abbey's Infirmary - the most complete of the monastic remains on the site.
The erection of the barn took place in the field known as 'Abbey Oaks' and commenced on the 17th December 2008. The Borough's Archaeological Officer was engaged to carry out a watching brief and report the results.

To those familiar with the area, it came as no surprise to find that the chosen site was rich in archaeological deposits. Many fragments of mediaeval encaustic clay tiles from the Abbey were found. A small selection is shown in the above image.

Green Lanes. Public Rights of Way and Mediaeval Ploughing
Superficially, it may appear strange to group 'green lanes', Public Rights of Way and medieval ploughing, but in this instance they are further links to the historic rural past of Lapal and llley. The photograph opposite shows Manor Lane, circa 1905, when it was little more than a 'green lane'. From 1218, until 1538, It was an highway maintained by the Abbot of Halesowen Abbey. Subsequent development meant that it was upgraded, the most extreme change being from the junction with Grange Hill through the new section to junction 3 of the M5, as a dual carriageway, now known as Manor Way. Not so extreme, but still notable is Lapal Lane, split by Manor Way. The northern section serving the Manor Abbey Estate has been upgraded as an urban road with footpaths, increased carriageway width and street lighting, whilst Lapal Lane South, separating Manor Farm from Lapal Farm, is still a narrow country lane. Development in the Lapal countryside would change that.

In the 1980s the Halesowen Abbey Trust restored the Public Rights of Way of Lapal and Illey under the umbrella of the ‘Dudley Countryside Management Project’ jointly funded by Dudley Council and the Countryside Commission. As part of that work, the overgrown and neglected mediaeval ‘green lanes’ were restored. They were ditched either side for drainage, and in the steep section to Coopers Wood, wrought iron horseshoes from the medieval period were found, preserved in the clay. The presence of these, and hedgerow dating methods, helped to date the ‘green lanes’, the maintenance of which are referred to in the extant Court Rolls of Halesowen Abbey.
Today, the ‘green lanes’ are a valued relic, reminding us of the origins of some of our oldest local roads. They are also a source of pleasure and recreation for the hoards of walkers who enjoy this historic countryside. The value of the Public Rights of Way to the physical and metal well-being of those who enjoy them should never be under-estimated.
Ridge and Furrow appearing as undulations of the land, is a legacy of medieval ploughing. The Sites and Monument Records, held by Dudley Council, state that these date from between 1066 and 1485, and are found at Lapal and Illey on unimproved grassland. Where land has been under regular modern arable cultivation evidence of ridge and furrow has generally been erased. The photograph, taken at Illey Clearly shows the undulations with are best observed in a low oblique sunlight.
Below is an atmospheric photograph of Manor Farm, taken in the 1960s. It records the historic site as it was in its lengthy period as a working tenanted farm, which lasted from the dissolution of the monastery in 1538, until it was sold in 1993 by Viscount Cobham, whose family had held the site since 1560. A benefit of the long period of tenancy in farming was the lack of disturbance of most of the monument. Archaeological excavations took place in 1870 by J. R. Holliday and between 1925-1928 and 1934-1940 by the Duke of Rutland. Seven hundred and sixty of the Abbey's tiles are held in the British Museum and eight tiles are now in the Holliday Collection at the Victoria and Albert Museum, with six fragments in Halesowen Central Library and a case of tiles in St. John the Baptist Church, Halesowen. The long shadows in the photograph emphasise the earthworks of the Abbey. In the foreground is a dam to one of the former monastic fishponds.

Under the terms of a Guardianship Agreement of 1979, with the then owner, Viscount Cobham, English Heritage have the right to open the Abbey to the public along a defined and restricted route, with access to the Infirmary. A small car park is identified for visitors. For several years that right has not been enacted, but the public can walk the Public Rights of Way, giving limited access to some of the fishponds and allowing views of the monastic remains.
The six bedroom farmhouse, for Manor Farm (seen in the above photograph), built in the late 19th century, replaced a mediaeval building, the use of which is in doubt. The old building has been variously described as the former Abbot's lodging and as a mill. The impressive replacement was designed by Yeoville Thomason, the distinguished architect responsible for Birmingham's impressive Council House and other such fine buildings.

In the 18th Century, this was the landscape enjoyed by William Shenstone of the Leasowes; his relative and friend, Lord Dudley of the Grange and their literary associate, John Scott Hilton of Lapal House. Shenstone used stone from the Abbey to construct his ruined 'Priory'- a major feature of his landscape creation, the Leasowes. Sir George, Lord Lyttelton (1709- 1773), of Hagley Hall, allegedly took stone from the Abbey to create one of his fine parkland follies, the Castle.

Official Recognition, 1989
Hitherto, we have concentrated on llley and Lapal, but this is simply part of a swath of special countryside that in the mid nineteenth century was described as 'Clentine' because of its relationship to the famed Clent Hills. The Clent Hills are set within beautiful countryside and are inseparable from it and vice-versa.
Whilst the public are aware of the importance of the
'Clentine' countryside, unfortunately it is not afforded the protection of an 'Area of Outstanding Natural Beauty', or a 'Country Park'. Perhaps it should be? Nevertheless, in 1989, it was recognised in a statutory plan, produced, at that time, by an enlightened Dudley Council planning department, titled 'A Place for Leisure'. It was formally acknowledged by the Royal Town Planning Institute for its progressive and positive approach.

Besides being prepared to 'establish and define the boundaries of the Green Belt', the other main reasons for preparing the plan were:
• to give recreation and open space considerations significant place in decision making
• to provide land for the whole range of outdoor recreational activities in the Borough
• to contribute towards urban regeneration

The four main aims of the plan were:
1. to provide a positive context for the protection and enhancement of open land throughout the Borough
2. to establish a site specific basis for a programme of new development

3. to establish a land use context for the development of a nature conservation strategy
4. to provide an opportunity for the public to participate in planning decision

The implementation of 'A Place for Leisure' led to the employment of a Countryside Manager and the creation of the Dudley Countryside Management Project (DCMP}, which started a three year experimental phase in September 1988. A 'Biennial Report 1991-1993' indicated how successful the project was.
Betray?
The Dudley Countryside Management Project has been downgraded and no longer has planning department support, or recognition. Similarly, 'A Place for Leisure', and its aims and objectives, are not acknowledged and are even denied by the current planners. In 2015, Dudley's planners supported a huge enterprise zone on the countryside of Lapal and llley, as shown on the plan opposite. Ancer Spa were commissioned to pursue this. It would have decimated splendid historic countryside, important to the character and identity of Halesowen and its people. Understandably, this sorry episode damaged public confidence in Dudley's planners.

On that occasion, councillors, who had hitherto been sidelined by the planners, responded quickly and threw out the proposal at a meeting of full Council. However, with the employment of new staff, the planners have ever since been aggressively pursuing development of Dudley's countryside.

In spite of Dudley Borough having a surplus of urban housing land to meet its own needs beyond the end of the next plan period in 2038, the planners have provisionally agreed to 5,000 new houses in Dudley's Green Belt to meet the claimed needs of neighbouring authorities. This first came to light in a letter of the 9th September 2019 from Wolverhampton Council to Shropshire Council, which stated
"Given that the Black Country Green Belt is located primarily in Walsall and, to a lesser extent, in Dudley, these are the two main housing market areas for delivery of housing, with only small amounts of housing potential in Wolverhampton and Sandwell. Therefore, based on a scenario that there was sufficient unconstrained physical capacity identified within the Green Belt, it may well be that a Delivery Study (based on similar principles to that completed by PBA for Birmingham), could reasonably conclude that these two nominal housing market areas could only be expected to deliver up to 5,000 homes each over the 15-year Plan period, based on upon what the market can be expected to deliver. This would therefore only provide up to 10,000 homes in total."
It is fortunate that such revealing and premature comments have come to light. Again public confidence in the integrity of the planning process, has been justifiably damaged. In September 2019, we were led to believe that evidence was still being collected and collated, in advance of being considered. Then the matter should go to Cabinet before going public. It is a controversial decision for a Council, with no justification to develop its Green Belt for its own needs, to offer its precious countryside for the needs of others. Do such grounds, which would surely be ongoing, if agreed, constitute the 'exceptional circumstances' as required by the National Planning Policy Framework? The Green Belt, instead of having the protection required in guidance would become a perpetual resource for development.

Volunteers Support the Previous Policies of Dudley Council
Whilst the current Dudley planners have turned their backs on recognition, protection and improvement of our countryside, volunteers who pro-actively worked with their predecessors, continue with the task. Within the limits of available resources, footpaths are cleared and problems are addressed. Elected members are appreciative and supportive.
In the summer of 2017, volunteers of the Halesowen Abbey Trust, constructed a substantial footbridge at the Trust's Grade 1 Listed Leasowes Walled Garden (in the Green Belt); transported it to site, adjacent to Uffmoor Wood, in the vicinity of Tack Farm and installed it. This overcame a major flooding problem, which had prevented appropriate use of a popular Definitive Right of Way.

Promoting Appropriate Use & Enjoyment of the Countryside

The National Planning Policy Framework reflects the Government's positive attitude towards Green Belts, and states:
13. Protecting Green Belt land
133. 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
141. Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Paragraph 141 relates perfectly to the aims of 'A Place for Leisure', which defined the Green Belt boundaries of Dudley in 1989 and not in the 1970s as claimed by the Borough's planners.

The Halesowen Abbey Trust has produced eight walk leaflets to promote use and enjoyment of the local countryside in their area of benefit. An 'Index and Guide' has just been published to accompany the walk leaflets and explain how the walks link up. The illustrated leaflets are full of information to assist the user.

The 'Area Map' clearly illustrates the link up of the walks over an extensive area. We are fortunate to have such an asset, but at present the future of that countryside is in doubt. It need not and should not be that way

Support

Draft Black Country Plan

Policy GB1 – The Black Country Green Belt

Representation ID: 23087

Received: 07/10/2021

Respondent: Halesowen Abbey Trust

Representation Summary:

Celebrating Halesowen's Countryside
Black Country Plan Consultation
The Halesowen Abbey Trust supports the Green Belt designation of countryside in our Area of Benefit, as shown on page 14 of our attached report, following the Green Belt review and assessments.
For many years, the Trust worked with Dudley Council to improve this historic countryside, which is an important amenity serving a large population. We will provide a comprehensive report, in due course to explain our support in more detail. In the meantime, I attach a report, dated March 2020, titled,
'Celebrating Halesowen's Countryside', which explains the trials, tribulations and pleasure we have
experienced in respect of this countryside.
Will you please acknowledge our support by confirming safe receipt of this email and attachment?
'When any of the jaded toilers in the district known as the Black Country have an afternoon to spare, and feel that a few hours passed amidst the beauties of nature would be a benefit to them, there is nothing more natural than that they should travel by train to Hagley Station, or obtain a horse and conveyance, and proceed with as little delay as possible to the foot of Adam's Hill, Clent, in preference to taking a much longer and more troublesome journey elsewhere with no better result. The time occupied in reaching Clent from the surrounding populous districts is so comparatively short, and the neighbourhood around Clent Hill so beautiful, that it is pre-eminently the place to select for the popular day or half-day outing.'
Clent, 1910 - E Blocksidge, Stone St, Dudley.
We are fortunate to have beautiful countryside adjacent to and within Halesowen. It is an important informal recreational and educational resource for the region and has hitherto been formally recognised for its historic; landscape and ecological importance.
Recognition pre-dates the modern era. The Premonstratensian Canons of Halesowen Abbey, noted for their love of natural beauty, chose the site that was later known as Lapal - derived from the French 'la' added to the Anglo Saxon 'pol', meaning 'the pool' - A clear reference to the fishponds created for the Abbey. The Canons occupied the Abbey from 1218 until the dissolution of 1538. The remains of the Abbey were scheduled as an Ancient Monument as early as 1915 - in recognition of the importance of the site.
We are fortunate that the remains are preserved in their original rural setting, which is important to the character and identity of historic Halesowen.
Unsurprisingly, the Dudley Historic Environment Record indicates an unusually high incidence of entries, ranging through the mesolithic; bronze and iron ages, as well as the Romano-British and mediaeval periods. There may have been a substantial Roman Villa.
It has long been accepted that any disturbance of the ground, at, or in the vicinity of Manor Farm, is likely to reveal artefacts of archaeological significance.

Watching Brief for Erection of a New Barn at Manor Farm - 2008/2009
The owner of Manor Farm was granted planning permission for the erection of a large modern barn, just outside of the scheduled area of the monument but in close proximity to the Abbey's Infirmary - the most complete of the monastic remains on the site.
The erection of the barn took place in the field known as 'Abbey Oaks' and commenced on the 17th December 2008. The Borough's Archaeological Officer was engaged to carry out a watching brief and report the results.

To those familiar with the area, it came as no surprise to find that the chosen site was rich in archaeological deposits. Many fragments of mediaeval encaustic clay tiles from the Abbey were found. A small selection is shown in the above image.

Green Lanes. Public Rights of Way and Mediaeval Ploughing
Superficially, it may appear strange to group 'green lanes', Public Rights of Way and medieval ploughing, but in this instance they are further links to the historic rural past of Lapal and llley. The photograph opposite shows Manor Lane, circa 1905, when it was little more than a 'green lane'. From 1218, until 1538, It was an highway maintained by the Abbot of Halesowen Abbey. Subsequent development meant that it was upgraded, the most extreme change being from the junction with Grange Hill through the new section to junction 3 of the M5, as a dual carriageway, now known as Manor Way. Not so extreme, but still notable is Lapal Lane, split by Manor Way. The northern section serving the Manor Abbey Estate has been upgraded as an urban road with footpaths, increased carriageway width and street lighting, whilst Lapal Lane South, separating Manor Farm from Lapal Farm, is still a narrow country lane. Development in the Lapal countryside would change that.

In the 1980s the Halesowen Abbey Trust restored the Public Rights of Way of Lapal and Illey under the umbrella of the ‘Dudley Countryside Management Project’ jointly funded by Dudley Council and the Countryside Commission. As part of that work, the overgrown and neglected mediaeval ‘green lanes’ were restored. They were ditched either side for drainage, and in the steep section to Coopers Wood, wrought iron horseshoes from the medieval period were found, preserved in the clay. The presence of these, and hedgerow dating methods, helped to date the ‘green lanes’, the maintenance of which are referred to in the extant Court Rolls of Halesowen Abbey.
Today, the ‘green lanes’ are a valued relic, reminding us of the origins of some of our oldest local roads. They are also a source of pleasure and recreation for the hoards of walkers who enjoy this historic countryside. The value of the Public Rights of Way to the physical and metal well-being of those who enjoy them should never be under-estimated.
Ridge and Furrow appearing as undulations of the land, is a legacy of medieval ploughing. The Sites and Monument Records, held by Dudley Council, state that these date from between 1066 and 1485, and are found at Lapal and Illey on unimproved grassland. Where land has been under regular modern arable cultivation evidence of ridge and furrow has generally been erased. The photograph, taken at Illey Clearly shows the undulations with are best observed in a low oblique sunlight.
Below is an atmospheric photograph of Manor Farm, taken in the 1960s. It records the historic site as it was in its lengthy period as a working tenanted farm, which lasted from the dissolution of the monastery in 1538, until it was sold in 1993 by Viscount Cobham, whose family had held the site since 1560. A benefit of the long period of tenancy in farming was the lack of disturbance of most of the monument. Archaeological excavations took place in 1870 by J. R. Holliday and between 1925-1928 and 1934-1940 by the Duke of Rutland. Seven hundred and sixty of the Abbey's tiles are held in the British Museum and eight tiles are now in the Holliday Collection at the Victoria and Albert Museum, with six fragments in Halesowen Central Library and a case of tiles in St. John the Baptist Church, Halesowen. The long shadows in the photograph emphasise the earthworks of the Abbey. In the foreground is a dam to one of the former monastic fishponds.

Under the terms of a Guardianship Agreement of 1979, with the then owner, Viscount Cobham, English Heritage have the right to open the Abbey to the public along a defined and restricted route, with access to the Infirmary. A small car park is identified for visitors. For several years that right has not been enacted, but the public can walk the Public Rights of Way, giving limited access to some of the fishponds and allowing views of the monastic remains.
The six bedroom farmhouse, for Manor Farm (seen in the above photograph), built in the late 19th century, replaced a mediaeval building, the use of which is in doubt. The old building has been variously described as the former Abbot's lodging and as a mill. The impressive replacement was designed by Yeoville Thomason, the distinguished architect responsible for Birmingham's impressive Council House and other such fine buildings.

In the 18th Century, this was the landscape enjoyed by William Shenstone of the Leasowes; his relative and friend, Lord Dudley of the Grange and their literary associate, John Scott Hilton of Lapal House. Shenstone used stone from the Abbey to construct his ruined 'Priory'- a major feature of his landscape creation, the Leasowes. Sir George, Lord Lyttelton (1709- 1773), of Hagley Hall, allegedly took stone from the Abbey to create one of his fine parkland follies, the Castle.

Official Recognition, 1989
Hitherto, we have concentrated on llley and Lapal, but this is simply part of a swath of special countryside that in the mid nineteenth century was described as 'Clentine' because of its relationship to the famed Clent Hills. The Clent Hills are set within beautiful countryside and are inseparable from it and vice-versa.
Whilst the public are aware of the importance of the
'Clentine' countryside, unfortunately it is not afforded the protection of an 'Area of Outstanding Natural Beauty', or a 'Country Park'. Perhaps it should be? Nevertheless, in 1989, it was recognised in a statutory plan, produced, at that time, by an enlightened Dudley Council planning department, titled 'A Place for Leisure'. It was formally acknowledged by the Royal Town Planning Institute for its progressive and positive approach.

Besides being prepared to 'establish and define the boundaries of the Green Belt', the other main reasons for preparing the plan were:
• to give recreation and open space considerations significant place in decision making
• to provide land for the whole range of outdoor recreational activities in the Borough
• to contribute towards urban regeneration

The four main aims of the plan were:
1. to provide a positive context for the protection and enhancement of open land throughout the Borough
2. to establish a site specific basis for a programme of new development

3. to establish a land use context for the development of a nature conservation strategy
4. to provide an opportunity for the public to participate in planning decision

The implementation of 'A Place for Leisure' led to the employment of a Countryside Manager and the creation of the Dudley Countryside Management Project (DCMP}, which started a three year experimental phase in September 1988. A 'Biennial Report 1991-1993' indicated how successful the project was.
Betray?
The Dudley Countryside Management Project has been downgraded and no longer has planning department support, or recognition. Similarly, 'A Place for Leisure', and its aims and objectives, are not acknowledged and are even denied by the current planners. In 2015, Dudley's planners supported a huge enterprise zone on the countryside of Lapal and llley, as shown on the plan opposite. Ancer Spa were commissioned to pursue this. It would have decimated splendid historic countryside, important to the character and identity of Halesowen and its people. Understandably, this sorry episode damaged public confidence in Dudley's planners.

On that occasion, councillors, who had hitherto been sidelined by the planners, responded quickly and threw out the proposal at a meeting of full Council. However, with the employment of new staff, the planners have ever since been aggressively pursuing development of Dudley's countryside.

In spite of Dudley Borough having a surplus of urban housing land to meet its own needs beyond the end of the next plan period in 2038, the planners have provisionally agreed to 5,000 new houses in Dudley's Green Belt to meet the claimed needs of neighbouring authorities. This first came to light in a letter of the 9th September 2019 from Wolverhampton Council to Shropshire Council, which stated
"Given that the Black Country Green Belt is located primarily in Walsall and, to a lesser extent, in Dudley, these are the two main housing market areas for delivery of housing, with only small amounts of housing potential in Wolverhampton and Sandwell. Therefore, based on a scenario that there was sufficient unconstrained physical capacity identified within the Green Belt, it may well be that a Delivery Study (based on similar principles to that completed by PBA for Birmingham), could reasonably conclude that these two nominal housing market areas could only be expected to deliver up to 5,000 homes each over the 15-year Plan period, based on upon what the market can be expected to deliver. This would therefore only provide up to 10,000 homes in total."
It is fortunate that such revealing and premature comments have come to light. Again public confidence in the integrity of the planning process, has been justifiably damaged. In September 2019, we were led to believe that evidence was still being collected and collated, in advance of being considered. Then the matter should go to Cabinet before going public. It is a controversial decision for a Council, with no justification to develop its Green Belt for its own needs, to offer its precious countryside for the needs of others. Do such grounds, which would surely be ongoing, if agreed, constitute the 'exceptional circumstances' as required by the National Planning Policy Framework? The Green Belt, instead of having the protection required in guidance would become a perpetual resource for development.

Volunteers Support the Previous Policies of Dudley Council
Whilst the current Dudley planners have turned their backs on recognition, protection and improvement of our countryside, volunteers who pro-actively worked with their predecessors, continue with the task. Within the limits of available resources, footpaths are cleared and problems are addressed. Elected members are appreciative and supportive.
In the summer of 2017, volunteers of the Halesowen Abbey Trust, constructed a substantial footbridge at the Trust's Grade 1 Listed Leasowes Walled Garden (in the Green Belt); transported it to site, adjacent to Uffmoor Wood, in the vicinity of Tack Farm and installed it. This overcame a major flooding problem, which had prevented appropriate use of a popular Definitive Right of Way.

Promoting Appropriate Use & Enjoyment of the Countryside

The National Planning Policy Framework reflects the Government's positive attitude towards Green Belts, and states:
13. Protecting Green Belt land
133. 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
141. Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Paragraph 141 relates perfectly to the aims of 'A Place for Leisure', which defined the Green Belt boundaries of Dudley in 1989 and not in the 1970s as claimed by the Borough's planners.

The Halesowen Abbey Trust has produced eight walk leaflets to promote use and enjoyment of the local countryside in their area of benefit. An 'Index and Guide' has just been published to accompany the walk leaflets and explain how the walks link up. The illustrated leaflets are full of information to assist the user.

The 'Area Map' clearly illustrates the link up of the walks over an extensive area. We are fortunate to have such an asset, but at present the future of that countryside is in doubt. It need not and should not be that way

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