Draft Black Country Plan

Object

Representation ID: 23568

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

FORWARD

The Save the Seven Cornfields Campaign Group came into being after a series of requests, following the hard work of local residents and after widespread petitioning against housing development on the parts or the whole of the Seven Cornfields site. Running parallel but separate and independently to this was an ongoing Facebook-based campaign.

This site falls both in the jurisdiction of the independent sub-region of the Black Country and South Staffordshire Local Plans now being prepared and within their respective administrative territories.

GEOGRAPHICAL INCLUSIVITY
The campaign includes different and diverse young, older and old people, families, groups and communities from the Black Country and South Staffordshire; particularly those from the housing estates of Ettingshall Park, Penn, Goldthorn Park and the Northway - those areas which surround the Seven Cornfields site.

This document does not speak exclusively for the residents from those estates, as other groups have formed and remain active.

Individual responses from residents from those estates should have been received by Black Country authorities together those from local campaign groups.

CAMPAIGN TO PROTECT RURAL ENGLAND (CPRE)
The Countryside Charity, formerly known as the Campaign to Protect Rural England (CPRE) has also made a Joint Submission of different campaign groups from across the Black Country and neighbouring areas which is strongly supported by The Save the Seven Cornfields Campaign Group.

This response of The Save the Seven Cornfields Campaign Group includes some shared matters regarding common opposition to development on the Seven Cornfields, Green Belt and important Green Sites near residential areas. Other valid concerns and issues not easily captured in a singular response are presented.

OVER COMPLEX LOCAL PLANNING PROCESS
The Save the Seven Cornfields Campaign Group is fully aware of the complexity of this consultation process which is quite hard to comprehend unless you are part of the Planning Inspectorate. This and further phases, however, which follow soon will provide Developers or their agents with the opportunity to object to non-inclusion in the Black Country Plan 2039 of the Seven Cornfields Site (and, any number of other Green Belt and Green field sites).

It is for this reason that the Save the Seven Cornfields Campaign Group have produced this document anticipating possible attempts being forced by the developers, the landowner and others for reversals of two key decisions
(a) the Black Country Plan 2039 excludes the Seven Cornfields as a potential development site
(b) the decision in the Black Country Plan 2039 not build on this Green Belt

EQUITY AND EQUALITY WITHIN THE LOCAL PLANNING PROCESS
Ensuring residents and communities have as much equity in the processes as developers and their agents is an important consideration for public officials, politicians and the Planning Inspectorate.

Money and influence should not be the measure which determines the capacity to give voice and be heard in the process.

Ensuring comprehensive recruitment of interested residents wishing to participate but unaware of how to do that exactly is an important consideration at every stage.

AVOID LAND BANKING
Whilst short to medium term profit motivation drives activities to develop on the Green Belt, it is not uncommon to find developers seeking to increase their national and regional land banks to provide options and insurance, even though they have no immediate need to develop. In this way land values are increased and action to prevent competitors’ actions locally is reduced. Local and Land Use Planning should not be used as a means to encourage land banking but rather to get the best for residents and other stakeholders.

CONSIDERATIONS
Independent advice from elsewhere has been sought. Having deliberated upon these matters fully, here are our observations, criticisms and conclusions.

The conclusion was that there should be a broad response to the Black Country Local Plan 2039 whilst reminding all of the connectivity to the Seven Cornfield site within the category of Green Belt sites-at-risk and under threat.

The general considerations run in hand with those submitted by the CPRE.

The Save the Seven Cornfields online petition which has been in operation for a few years has 7,000 signatures.

POLITICAL ENDORSEMENTS IN SUPPORT OF SAVING THE SEVEN CORNFIELDS
Many MPs and local Councillors have publicly backed The Save the Seven Cornfields Campaign.

There are written endorsements of support from numerous political parties, some were first made at the last General Elections.

The site has been mentioned in the House of Commons questions and answers.

Currently, there are 4,000 users on the Save the Seven Cornfields Facebook site.


PART 1: KEY POINTS

OUT OF PHASE LOCAL PLANNING

Several Local Plans for the Black Country and South Staffordshire are running out of phase with each other though they often affect the same or similar communities. This brings problems. A decision in one Local Plan could pre-determine decisions in the neighbouring administrative and Local Plan area. This is illogical. A further phase ought to be added to allow communities at one point in time to integrate the several plans for understanding and cogency, providing co-production of clear, logical and convincing arguments that achieve compatible outcomes. Below is a brief excursion to outline the Save the Seven Cornfields Campaign’s response to South Staffordshire. This is presented to discourage isolationist thinking.

The Black Country Local Plan cannot be considered in isolation and it is particularly important that consideration is made of what is happening in neighbouring Local Plans. In relation to the Seven Cornfields the response to South Staffordshire Local Plan and Housing Strategy is important. The full report of The Save the Seven Cornfields Campaign Group to that Plan is available but there is a summary of key points which can be found in Appendix 1.

FAVOURED HOUSING STRATEGY OPTION A IN THE SOUTH STAFFS PLAN.

The Save the Seven Cornfields Campaign Group opposes any housing or built development on the Seven Cornfields. The Campaign, therefore, favoured the Housing Strategy Option A in the South Staffs Local Plan principally because it focuses on a location that is already adequately served by a strong traffic infrastructure comprising of a Motorway and Railway Network).

DUTY TO CO-OPERATE (See Para 3.20-3.27 (Duty to Co- operate) in the Black Country Plan 2039)
Obviously, it follows that The Save the Seven Cornfields Campaign Group objects to development on that part of the site in South Staffs under the Duty to Co-operate to meet neighbouring BLACK COUNTRY sub-regional housing needs.

Such Duty to Co-operate on sites are often and wrongly thought to respond easily and well to any extra gravitational pull of major surrounding employment centres such as Birmingham, Wolverhampton and those to the North. It can drain resources from adjoining authorities and may create negative planning outcomes. The actual benefits to the Black Country from development on sites adjacent to its boundary to meet their housing needs are often in totality negative.

Whilst the Black Country policy-makers think they obtain housing for their workers, the housing might go to others.

Furthermore, in the event of development on the South Staffs side of the Seven Cornfields providing houses on the Black Country Boundary, the income from residents would go to South Staffs but the infrastructure cost of roads, schools and health would fall immediately on two Black Country authorities.

PREJUDICIAL DECISION ON GREEN BELT LOSS & ADDITIONAL HOUSING BASED ON EXAGGERATED HOUSING FORECASTS (Policy HOU 1 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group insists that the decision to meet an over-exaggerated Housing Target of 76,000 unilaterally and automatically erodes important Green Belt provision and dismisses the concerns of local residents and campaign groups. It is ultimately prejudicial to the integrity, cogency and strategic and tactical decision-making of the Black Country Housing Review to presume any acceptability of development in the Green Belt.

The questionable forecasting of Housing Needs is dealt with adequately in the CPRE submission so won’t be dealt with in depth here (see later).

THE GREEN BELT IS A NATIONAL, REGIONAL, SUB-REGIONAL AND NEIGHBOURHOOD TREASURE (para 3.15 -3.16 (Gren Belt) in the Black Country Plan 2039)

Clearly, the public valuation and benefits of Green Belt outweigh those of Brownfield and Derelict sites. One is a treasure; the others are generally not. Yet in the quickness of a decision and immediacy of considerations of target grabbing this is forgotten. A questions arises: Who sells the family treasures (the Green Belt) when there is loose change about the house, coins in the piggy bank and money in bank accounts (Brownfield sites)?

The Green Belt is a Public Good. This is something which everybody benefits from but cannot be bought by any one person. The Seven Cornfields designation as a Green Belt means, therefore, it is a Public Good for those living within a compass of easy travel. This type of thinking wrongly is not given adequate priority in Land Use Planning although it should be.

BROWN FIELD AND DERELICT LAND SITES FIRST (Policy DEL2 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group considers that the changing evidence and absolute scale of Brownfield and Derelict Land sites development for housing purposes and needs has to be monitored thoroughly and plotted to understand the dynamics at play in the sub-region and neighbourhoods.

With few reservation, mostly relating to the characteristics and locality of specific sites, the Save the Seven Cornfields Campaign Group supports Housing Development on Brownfield and Derelict Land sites. The Save the Seven Cornfields Campaign Group opposes development on the Seven Cornfields Green Belt and other important Green Belt zones.

There is ample Brownfield and Derelict Land sites within the Black Country sub-region to service its needs for several years into the next decade and further. Incentives can assist developers to make the right decision.

When Derelict Land grant, sometime ago, was available to Local Authorities for tackling Dereliction, many sites where annually transformed into productive use including housing across the sub-region.

Taxation relief is another method to ensure a faster rate of transformation of Derelict and Brownfield sites. Governments should be lobbied to provide such assistance.

The failure to develop Brownfield sites has much to do with margins of profitability and economies of scale. This a private sector consideration and not necessarily an economic concept applicable to the public who instinctively know what is known as a Public Good in Economic Theory.

It is easier and more profitable to develop on most Green Belt and Green field sites than on Derelict and Brown Field sites. It is not, however, always easier and more profitable to develop on most Green Belt and Green Field sites when the infrastructure costs of over-intensification of use of services are taken into consideration.

In addition, Housing Developers and Speculators favour the acquisition and land banking of Greenfield sites to control the price of land already held by them and can be classed in their accounts as an investment. In the same manner, the most famous Diamond monopoly merchant buys and then withholds diamonds to ensure a higher price than would be naturally be the case if these diamonds where released on the open market. Artificial scarcity is created for Housing land (and diamonds).

Notwithstanding these facts, there is no logical reason for a Local Authority to release Greenfield sites or extinguish Green Belt status when there are many Brown Field and Derelict Land sites to develop first.

Allowing easy access to Green Belt development means the unsightly Brownfield and Derelict Land sites will remain for longer than necessary were the natural market mechanisms not distorted by Land Banking. They will not be transformed into useful use when they could have been.

Anybody with an eye to sustainable Land Use policy and environmental conservation in its largest sense would ensure the future Housing Demand was met by a policy of Brownfields first.

On 17th March 2017, West Midlands Combined Authority (WMCA) Board received a Report entitled Land Fund: Black Country Strategic Brownfield Land Programme. The Report noted:

“The Brown Field Strategic Brownfield Land Programme has identified a robust and deliverable pipeline of £342m of schemes, leveraging total investment of over £1.4b within three Priority Propositions of Delivering Black Country Garden City, Establishing High Value Manufacturing (HVM) Capital City and Strategic Population Centres.”

With investment from the WMCA Board, the Report made it clear that remediation would deliver 1600 houses. What higher levels of reclamation could be achieved over the Local Plan period with a more targeted approach? Enough to not need development of the Green Belt (or the additional 4,000 pledged by South Staffordshire Council).

Given the rising vacancy trends in retail, office and industrial property and the diminishing demand, the annual growth of the supply rate of unwanted commercial and Derelict Land and Brownfield sites will increase and the net result will be a year-on-year incremental growth and, therefore, a much higher total availability of such sites -unless of course there is a consequential turnover of reclamation for productive use like Housing. (This then suggests that less of the South Staffordshire Housing requirement -either normal (4,000) or exaggerated target (8,000) - will have to come from Green sites or the Green Belt.)

TRIPLE LOCK - PREVENTION OF PLANNING BLIGHT (policy Del 2 in the Black Country Plan 2039)

If the prospect of additional houses as planned and formally agreed in the Black Country Plan 2039 moves to that reality then measures must be in place to prevent the problems, recently witnessed, when retailers acquired land or development rights in cities to prevent expansion of their competitors. In Wolverhampton City Centre this created long standing problems.

If developers or builders were to start but not complete work on all the Green Belt sites then the worst of all worlds would have arrived; lost Green Belt but not completed sites with a few houses but no amenities.

Planning Blight is where the reduction of economic activity or property values in a particular area result from expected or possible development.

The Save the Seven Cornfields Campaign Group proposes that there should be a Triple Lock applied to Green Belts. There should be proper monitoring of housing development in Black Country (& South Staffordshire) and Green Belts at risk and other important Green Sites should not be released at once but a phasing should be operable.

The release of individual sites should then only occur when it is obvious that the available non-Green Belt sites in the Black Country (& South Staffordshire) and the Brownfield and Derelict Land sites in the districts within the Black Country have been developed, that the Black Country Housing figures have not been met year-on-year and the lowest graded Green Belt sites with the fewest constraints get released first.

This Triple Lock should be written within the Black Country 2039 Plan’s Objective and Planning and Development Briefs and it must form the basis of future agreements with developers and builders.

KEEP GREEN BELT STATUS AVOID ANY LOSS (Para 3.15-3.16 in the Black Country Plan 2039)

Green Belt Status is a treasure placed in trust to National and Local Government.

It is a Public Good. It is for the public good and once lost cannot be replaced. The Green Belt is not Wolverhampton’s, Walsall’s, Sandwell’s or Dudley’s, it is not singularly South Staffordshire’s either. It is our Green Belt and the Green Belt for future generations.

The post-war Land Use Planning resulted in newer thinking, like the Conurbation which categorically and absolutely defined the importance of Green Belt in maintaining the overall identity and coherence of the West Midlands Region. Later, the West Midlands Structure Plan did the same.

It is myopic to consider Green Belt extinguishment from anything less than a regional or sub-regional perspective. The decision on Green Belt extinguishment cannot simply be left to several Metropolitan Authorities or one small Shire local authority when the demand and gravitational pull of populations arrives from across the adjoining sub-region, region and country.

The Save the Seven Cornfields Campaign Group considers housing development on key Green Belt sites cannot be allowed because of the loss it creates to the Black Country Sub-region. In almost all of the cases, more demands on at-capacity infrastructure would be necessary and would have to be more than sufficient to serve the demands generated.

Additional infrastructure and upgrading will have to take place prior to development of housing.

Roads will have to be extended, possibly widened, and traffic management systems will also have to be upgraded to control flows productively and effectively. The critical educational issue will be the need to ensure immediate provision of a Secondary School. These will need to be built and the schools made fully operational prior to the housing development completion.

The building of houses on Green Belt will in turn mean that those living on existing housing estates adjacent to the site will suffer from among other things:
Loss of clean air
Serious local flooding due to lost natural water drainage
Shortage of local school places as competition increases will be dramatic
Class sizes will in turn increase poor education attainment
Hospital patients face longer waiting lists
Waiting times for doctor appointments will increase
The extent of traffic jams and grid lock on local feeder roads will increase
There will be less recreational space for walks or play
There will be a loss of local wildlife and plants

SAVE THE SEVEN CORNFIELDS

The Seven Cornfields site comes in the highest of five categories of Green Belt in the South Staffordshire Green Belt survey – loss would be of ‘very high harm’ to the Green Belt - and in the higher of two categories of Green Belt in the Greater Birmingham Housing Market Area (GBHMA) survey – ‘principle contribution’ - but much of the wedge further out towards Wombourne is categorised in the GBHMA survey in the lower ‘supporting contribution’ and the overall area west of Wolverhampton is one of the areas where it thought that ‘proportionate dispersal’ (small developments) might be appropriate. It is, however, much worse north of the Black Country, where two more proportional dispersal search areas, a ‘development area with an employment focus’, two ‘urban extensions’ and two possible ‘new settlements’ are postulated!
The Seven Cornfields are a microcosm, at present there are patches of woodland surrounded by arable fields, there are, however, wildlife corridors, hedgerows and footpaths where wildlife can move round at night passing unseen down these trails, so the woodland patches are not isolated one from the other. The wedge as a whole allows this connectivity to extend to the open countryside, thus physically linking large areas of Wolverhampton (and Dudley) with rural South Staffordshire.

The ecosystem has developed over centuries but has been able to adapt to minor intrusions of humankind.

If houses are built on all of the Seven Cornfields, hedgerows cleared and the Penn Brook banks manicured and landscaped for the residents of the new estate then these vulnerable corridors will disappear. The wildlife of the woodlands will vanish. Anthropogenic species like foxes will persist but bats, xxxxxx and butterflies and perhaps the birds of prey will be lost for this and future generations.

The road system around the Seven Cornfields site is congested and insufficient for any additional traffic. Access points to the site will become pinch points. At peak times all the housing estate’s feeder roads onto main highways are already gridlocked.

The roads from Penn, Ettingshall Park, Northway and Goldthorn estates towards Wolverhampton and Birmingham are congested and at capacity. Wolverhampton and Dudley residents will bear the brunt of the traffic increase.

The development of houses will place a huge strain on the infrastructure of the Goldthorn Park, Northway, Ettingshall Park and Penn estates which are adjoining areas to the Green Belt under threat.

THE STAFFORDSHIRE BIODIVERSITY ACTION PLAN

The Staffordshire Biodiversity Action Plan (SBAP) to which South Staffordshire Council are joint partners with other organisations, has been in place since 1998 in order to co-ordinate conservation efforts to deliver the UK Biodiversity Action Plan.

Several pairs of Skylark breed on the rough grassland at Penwood Farm (The Seven Cornfields) and this species has its own Action Plan in the SBAP.

PART 2.

1. THE BACKGROUND

The demand for housing across Wolverhampton, Dudley and South Staffs is placing pressure on the Green Belt and green spaces.

The government expects Councils to meet certain targets.

But the issue isn’t just about more housing, it is about the right sort of affordable housing.

The mathematical additions in the Black Country Local Plan fails a simple test of mathematics and logic because adding an apple to an orange is as ridiculous as adding two 6 bedroomed detached houses to two 2 bedroomed semi-detached houses and arriving at four dwellings which is meant to cater for all the sets of demands. The Housing Forecast and model are heavily criticised in the CPRE report submitted and there is little that can be added to their well thought out critique. Other than with the addition of several points.

Sensitivity Analysis
Given, however, the importance on the forecast model and its trends in directing major decisions it is very important that the assumptions being made are explained and contested. Much more important is that a Sensitivity Analysis is undertaken on the components and indicators used in the model. In this way, the indicators or measure used are revealed that can corrupt or hugely move an overall or total output more than others in the formula or model. This evidence is important. When the level of over influence or exaggeration is understood then there is a need to properly ensure that the indicator is up to date and not based on spurious data.

Higher educational drift
The local university like many other universities has many foreign students but unlike other universities around two thirds of the undergraduates come from the Black Country. This is quite unique. What is becoming more common is that that following graduation a high proportion of the graduates seek to leave the sub-region.

Net migration from abroad had fallen
Furthermore, given changes following Brexit, the demand from International Students appears less strong than before.

The net level of immigration from abroad to the nation, west midlands region, black country and neighbourhood sub-regions and its cities and districts is already falling. Overseas workers are no longer coming here in anywhere the numbers as before. This will impact heavily and negatively on the demand for housing.

Both these factors are likely to affect the housing forecast and do not appear to have been factored into the housing forecast model which is based on more general considerations from elsewhere.


As a sub-regional cluster, the Black Country Local Authorities are jointly reviewing their Housing Strategy and Local Plan now to say how they will achieve the Government’s Housing targets.

Meanwhile, South Staffordshire is going to a further phase of Local Planning and Housing Strategy alongside the early stage of Black Country Local Planning. The sequencing of these neighbouring Strategic Housing endeavours brings problems and gains which should have been considered, stated and negotiated openly and through consultation.

The Seven Cornfields and Pennwood Farm site mostly falls in both South Staffordshire and Wolverhampton Local Authority areas. Therefore, the site will be dealt with in two different Housing Reviews and Local Plans which will not happen at the same times.

What must be avoided is exploitative or extractive Housing development as proposed on the Green Belt, where large wealth is created by extinguishing the Green Belt - a Public Good (in economic terms).

The Green Belt was and is an asset of the community held in trust by National and Local Government.

When the Green Belt is lost and farmers and builders living elsewhere make huge sums of money that get spent outside the area, the Public Good is lost and the wealth created by Change of Use to residential is fully lost to the community.

The Green Belt is everyone’s treasure. It works because of its unity to prevent Urban Sprawl across the Country, region, sub-region and between and within districts. Does the Black Country want to become more unattractive or want to be creative of a more richer character that creates a synergy with a Green-ness that overlays onto the once industrial might and energy implied in the title of Black Country? If so, it does not then need to reconsider the protection once afforded to the title of Green Belt.

The wrong decision around Black Country Housing Review now (and the South Staffordshire Review which follows next year) will create the real possibility for extinguishment of much Green Belt. [It has been commented on that the farmer who lives in a leafy village elsewhere and owns the Seven Cornfields site appears to have provided housing developers with options to acquire parts of the site for development, probably if certain conditions are met (for example, extinguishment of Green Belt and inclusion of the site in the Housing Strategy)].

In any event, whether that is right or wrong, the response and challenges of national developers is likely to mean high grade Green Belt sites like the Seven Cornfields will be lost unless opposition is constant and focused.

Even though, the Seven Cornfields is not currently indicated as a site for development in Black Country Local Plan and has been dropped from the South Staffordshire Plan, communities and campaigners have arrived at certain conclusions:

The Save the Seven Cornfields Campaign Group and other campaign groups conclude there is a need for an absolute, rigorous and continuous opposition to potential and real challenges for inclusion of the Seven Cornfields for development from developers and owners by any legal means. This is a chance to block the loss of the Seven Cornfields and save the Green Belt.

It is for this reason that the Save the Seven Cornfields Campaign Group have produced this document anticipating possible attempts being forced by the developers, the landowner and others for reversals of two key decisions
(a) the Black Country Plan 2039 excludes the Seven Cornfields as a potential development site
(b) the decision in the Black Country Plan 2039 not build on this Green Belt


2. STANDARDS TO BE UPHELD & REVIEW OF THE FAILURES OF THE CONSULTATION AND INACCESSIBILITY OF THE LOCAL PLAN REVIEW AND HOUSING STRATEGY DOCUMENTATION

Before proceeding certain ground rules and standards need to be brought to the fore:

Standards and Equality perspectives that apply to the Local Plan and Housing Strategy work.

The National Planning Framework guided the trajectory of the Local Plan Review and the Housing Strategy work. The objections, observations, conclusions and favoured positions stated here respond to these but it is important to remember that Local Planning and other activities undertaken by Local Authorities have to comply and objectively demonstrate compliance to other important regulations, standards and legislation that protect people’s rights (eg. Equality).

Nolan Principles of Public Office applied to the Local Plan and Housing Strategy

The Nolan Committee was established in 1994 in response to concerns that the conduct of some politicians was unethical in ‘cash for questions’and other matters.

The many failures of public offices demanded the establishment of minimal standards to be observed by those in public office.

In any arena, where public decisions can result in the creation of substantial wealth, it becomes especially important to ensure that the Nolan Principles are not found wanting in the arrival of key decisions or through the dispatch of duties. Consider, for example, the relevant fact that overnight there can be a rise in the capital value on a site by millions of pounds where Green Belt status is extinguished in favour of residential use through a Local Plan Option decision or allocation.

It is important that the documentation, responses and collation, categorisation, assessments and evaluations of this Consultation Process too are seen within the light of Nolan.

The Nolan Principles should not only be applied but must be seen to be consistently and constantly applied at every stage of the Planning and Consultations by Elected Members, Planners and the Inspectorate too.

Here are the Nolan Principles:

1.Selflessness: Holders of public office should act solely in terms of the public interest.
2. Integrity: Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.
3. Objectivity: Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
4. Accountability: Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
5. Openness: Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
6. Honesty: Holders of public office should be truthful.
7. Leadership: Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.

The Nolan Standards - not met in the Local Plan and Housing Strategy

At this point, it seems that some of Nolan Principles are to be considered as not having been fully met. This is an important issue for Officers and the Inspectorate to consider.

For instance, to be a professional is to be objective through the use of the universally accepted practices and tools of a profession to arrive at a decision. Objectivity means that it would be normal for people with the same evidence to arrive at the same or similar decision.

The algorithm, flow of decisions or decision-tree that results in the Black Country Councils choosing to simply accept the Government’s required housing target is not seen through the documentation. Throughout the documentation, the lines of reasoning which might lead to the excessive target choice are absent and much of the text appears post hoc justification. Consider the decision to select and state:

The Black Country and Staffordshire Local Plans present a real spirit to co-operate. Both the Black Country and South Staffordshire Councils could have also included the innovation of joint Neighbourhood Plans where potential Green Belts site abutting or straddling local administrative boundaries are brought into a neighbourhood plan developed and co-produced between respective authorities.

Strategies within the Black Country Local Plan and Housing Review should include 3 quite different forms of monitoring:-

a) There should be regular strategic monitoring to ensure the direction of travel of the Plan or Strategy is as intended and that it is achieving the desired outcomes. This requires that objectives are framed in a way that they can be measured (they are not in the Local Plan - see later).

b)There should then be efficiency monitoring to show that there is an efficient use of resources to achieve the plan’s objectives; this considers pace and resource savings - and asks the question has public money and resources been used wisely?

c)Then policy and plan need to be monitored for effectiveness to evaluate if the plan is having the right and anticipated impact. Effectiveness can never be done in isolation, it requires regular feedback from stakeholders; this means talking and listening to individuals, residents, communities and groups.

There is no evidence of a cogent framework to assess and evaluate the Housing Strategy and Local Plan. This means it cannot be placed under thorough and transparent scrutiny. Remember Accountability demands that holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this happens.

There has been a failure in Leadership to ensure that the Consultation Process, Documentation and Options were and are real and accessible for all stakeholders and that the most democratic means to develop the plan was chosen (see what follows).

Equality Impact Assessments Non-conformance

The obligation to produce an Equality Impact Assessment has not been fully met in spirit, comprehensiveness and application to all phases of the Housing Strategy and Local Plan Review. The statements made in the Equality Impact Assessment have not been made on full and proper consideration of the Protected Categories of stakeholders affected.

a. Failure to ensure proper equality impact assessment on the Consultation material and process.

How have or will Blind or Partially Sighted people address the Housing Strategy and Local Plan Review? This is an example of the type of thinking that should have been applied to the Local Planning and Housing Strategy process.

Access to the documentation was made available electronically and at a few public buildings. Several well-educated Information Technology literate individuals - who professionally, regularly and actively extract information from web-sites - attempted to navigate the Local Plan and Housing Strategy site. All found the exercise unduly cumbersome and unfriendly to the potential user. The index of documents to be considered was overwhelming and not categorised in terms of usefulness. The complexities of the different phases of the Local Plan system are only understood by a few - the Inspectorate, relevant council officers and developers agents

The forms to be used where presented in pre-loaded questions which did not focus on the critically important decisions but rather on intermediate ones.

Broadly, many less young who do not own computers or smart phones and many who do are reluctant to fully engage with complex interfaces and are prevented from fully engaging or participating in the Consultation process.

Given these problems, how then would people suffering from learning difficulties enter the Local Plan site and use the information?

Given, that a ward Blakenhall abutting a key Green Belt site has a substantial minority ethnic population, what provision was made for translation?

Given that accessible public transport is not common, how would carless people with poor computer literacy and physical disabilities easily get to see and comment on the documents?

The Equality Impact Assessment did not consider these Protected Categories fully and properly.

a. Failure to ensure proper equality impact assessment on the generation and applicability of Housing Options and Local Plan Review

The Black Country Councils do not say how they have contacted people it notes to be important and how it amended its processes to ensure greater inclusion from lessons learnt. “People who have an interest in the activities and achievements of the Council, including residents, local communities of interest, partners, employees, customers, shareholders, suppliers, opinion leaders, regulators and “hard to reach” groups.” How did the Council continue to reach ‘hard-to-reach’ groups?

None of the Options or other actions make it clear how they work to favour, help or otherwise assist any of the Protected Categories described by Equality Legislation.

Community facilities for certain groups are focused around their temples and places of worship and there has been an increasing migration of affluent minority ethnic families from Wolverhampton and Dudley to South Staffordshire, what consideration has been made for them? What consideration has been made for Faith Schools? Have they been afforded equal consideration as other groups in the Plan?

Those people with physical disabilities who own cars require easy access to parking spaces and not a competition for spaces. Those without cars, require careful planning to ensure adequate and relevant provision is made that caters for their needs at interchange points between key modes of transport. To what extent has this been taken account in the Spatial Planning?

Why has not technology been considered both as an economic development tool and as a means to help the increasingly elderly population with disabilities in need of assistance, help and care? 4G, augmented and virtual reality tools and other forms of advanced technology are all means to aid and assist and reduce dependency on travel for care services.

The points made here could be peppered with more examples but they are made to demonstrate the short fall in thinking around ensuring there has been an adequate Equality Impact Assessment for the Housing Strategy and Local Plan Review. These policies are found wanting.

3. A FUNDAMENTAL OBJECTION TO THE CHOICE AND DECISIONS REGARDING PLANNING POLICY MODEL AND PHASING

Choices on the ways of doing Local Planning create different consequences. The decisions behind ways of doing planning brings the Nolan’s Principles of Openness, Transparency, Leadership and Accountability into the frame of consideration.


Clearly, residents in Dudley and Wolverhampton should have the right to expect the same things as the best offers from neighbouring plans. Equally, there should be an avoidance of the worst aspects.

A closer examination of what fundamentally separates Wolverhampton’s and Dudley’s oppositional position to South Staffordshire’s Local Plan and Housing Strategy reveals important matters. At a fundamental base assumption level, it simply is the degrees of democracy behind each position.

The South Staffordshire Housing Strategy and Local Plan represent a series of policies manufactured from a “top-down’ perspective where a cadre of individuals have determined the desired outcome for themselves.

The opposition previously to South Staffs and here to the Black Country Plan is exactly different because it is a ‘bottom-up’ approach where communities, groups, families and individuals are making clear their policy determination and articulating a strategy to be properly and fully considered in this ‘top-down’ review. This tension could have been avoided.

The following statement is entirely contestable and hides an undetermined or invidious Democratic and Planning philosophy.

In most Western national (like Britain) and local government states (like Black Country) it is proudly proclaimed that we live in a Democracy and we support the advancement of Democratic Principles.

Democracy means one man or one woman votes to determine future plans and actions.

Indirect democracy is just that indirect, however, where possible action should be taken to ensure that governance and policy planning move towards direct democracy not away from it. There are policy planning tools and techniques that allow for that democratic movement, for example, Real Time Strategic or System Wide Alignment: This is policy planning formed from a Critical Mass or representative sample of the population. There are other more democratic forms of policy design and aligning strategy like Future Search.

In this case, a democratic way forward would have been to develop neighbourhood plans which then fed into and built a framework for the Black Country Plan 2039. The foundations of democracy are then built from the “bottom upwards”.

The Black Country does not currently have any neighbourhood plans in its area; however, these smaller more localised plans are something which are not unsupported through national policy.

The role of neighbourhood plans has much to with the promotion of a local shared vision - the idea of locality. They seek to identify more specific local policies for the neighbourhood area, rather than broad-brush strategic policies dropped down from a Local Plan designed by officers with limited consultation.

Crucially, a question to be asked because of the different nature and tiers of Black Country towns is why neighbourhood plans were not considered at the earliest as the starting point for dialogue with residents and communities for strategy development?

4. TAKING UP THE INVITATION FOR ANOTHER OPTION
(Policy EMP1)

It is quite strange that the Black Country Local Plan has not given proper Spatial Land Use Planning Consideration for Employment or Economic Development. It is unfortunate and untimely that the Black Country Employment Area Review Or BEAR will not be available until August.

It has premised growth through Housing but not materially considered alternative perspectives.

For instance, it would not be out of the question to adopt a thriving no growth strategy which is about making Black Country capable of standing alone in a sustainable local economic development model. Such a strategy being more akin to current vectors of change and not positioned on continuous sustained consumption.

It might also have been a strategic decision to promote micro-enterprises and venture capital investment which fostered business that were not dependent on travel to and from the major business hubs. After all the networked world has demonstrated the potential for different kinds of business and, during Covid shut down, the attractiveness of working from home.

This refreshed option builds upon the strength of adding a more current and real employment perspective which seeks to broaden the economic base. This needs to be interdependent, agile, far-sighted, current and inclusive rather than orthodox, rigid, myopic and exclusive.

The fallacy of linear projection of employment applies in the current Local Plan and its preparation, this is where agencies such as the Council act as institutions of continuity as they show themselves loathe to innovate, preferring incremental change of a known order rather than violent transformations in line with emerging trends.

The Black Country plan demonstrates the popularity and longevity of the dominant paradigm regarding unchecked growth which may not prove sustainable.

Local Planning was meant to take on sociological, technological and economical change

The whole point of a Local Plan for the Black Country is to provide an integrated and comprehensive series of policies which draws together the inter-related aspects of a complex world. For instance, to consider Homelessness (which is not given proper consideration) is to treat a problem of inequality which is multifaceted and not just a matter of buildings and availability. Local Plans are meant to go beyond simple Land Use Planning considerations.

Likewise, providing the right dwellings at the right time is not about providing, for instance, building 4 bedroom luxury homes at points unconnected to future growth points, technological assets and demands created by changing sociological characteristics.

Much of the Black Country Local Plan appears a ‘gold rush’ to release the national treasure of the Green Belt and important greenfield sites without a comprehensive consideration of inter-related aspects that determine quality of life, real life chances and opportunities for all.

Planning, simply is about making decisions and taking actions, now or in the very near future, to make sure total future benefits are maximised and / or the overall direct and indirect costs are reduced.

When applied to Land Use, it seeks to consider the allocation, benefits and costs of Town Planning Classes of Use to meet interdependent activities required by individuals, groups, communities and populations within a Local Authority Area or, as in this case, four Local Authorities.

Many of options and considerations within the Black Country Local Plan do not attempt to draw together the interconnected aspects of service provision with the broadest possible set of features arising from the 4 Council’s corporate organisational policies. To do this would be to ensure the best of all futures and quality of life for its stakeholders.

The Plan simply considers Land for Housing but does not consider how to ensure its service or those of the sub-region and neighbouring areas can be better focused with Land Use Planning to enrich the area. For example, Widening Participation and Life Long Learning can be perspectives that bring education, training and learning relationships with economic development and local planning for the benefit of an area.

Local Planning should extend corporate planning, amenities and wrap round services around major new residential build. Briefly, but relevant here is an understanding of Local Plans which depends to some extent on its genesis. It arose out of the knowledge that Land Use Planning was linked to sociological, economic and technological change. There was a clear link between Economic Development and Planning. These grew out of a disaffected population pressure to ensure that the public ought to participate in the process - as there was disenchantment with planning generally. Development control had been a success when it avoided development in the wrong places and when better results were achieved than would otherwise be the case. There was in many cases a lack of correspondence between the Development Control and Development Planning.

DO WHAT YOU HAVE ALWAYS DONE GET WHAT YOU HAVE ALWAYS GOT
- NEW THINKING AND PLANNING PLEASE

The Black Country Plan 2039 policy on Climate Change is inadequate and falls within other objections about lack of innovation and total reliance on sustained growth of existing models of production, wealth generation and income generation. Alternatives don’t have to be absolutely alternative than present ones but, in many instances, just require a bit more creativity and imagination from policy makers and employers.

Applying the right discretion to the Black Country Local Plan and Local Planning process can ensure that the pioneering and guiding principles are adhered to and this ought to be the genesis of an Option that takes proper account of:

1.Exercise Free at the point of participation.
Quality of Life especially in relation to Health Improvement and declining provision of Health Care and Treatment. In essence, wise decisions and actions should result in more people exercising and undertaking mental exercises to reduce mental ill health. Exercises such as walking in Green Spaces provides such overall health benefits which are free at the point of participation. More so than in richer areas where residents have the residual income to purchase subscriptions, poor folk have difficulty with ensuring capacity to buy and rely on free at point of participation facilities.

2.Life choice changes following Covid 19The pandemic and consequential lock downs has informed many of the different life choices available. None of these are considered in the assumptions generated in Housing Demand forecasts. Spending more time and working at home has highlighted the dis-benefits of daily commutes. It has also raised the question of a life well lived which need not be premised on full time work and constant consumptions.

3.The Care of the Planet and Protection of Green Belt paradigm In less than a decade the realisation that the Planet needs to be protected from polluting industries and unthinking exploitation, this is coupled with a need to safe important clusters of flora and fauna. Natures Carbon Sinks must be sustained. Fundamentally, investors and developers should not be able to make income or wealth destroying the planet or a locality. (Policy CC1)

4.Dramatic Weather Patterns and Flooding Few could dispute in Britain, Europe and the World dramatic changes in weather patterns have resulted in Floods which the consequential economic, social and physical damages and costs. It is beyond stupid to develop on sites where the risks of Flooding on the site and adjacent areas is probable or already demonstrated. The Seven Cornfields site, for instance, has suffered from changes in the water layers and there has been frequent flooding of the Penn Golf Club site. This problem will in every likelihood of greater flooding and damage on the Golf course if the Seven Cornfields site is developed. Policy CC1

5.Fungal diversification
Increasingly, scientists are realising that the microscopic action of fungi are important in maintaining a viable ecosystem. These takes a long period to develop and cannot easily be built up once lost. Many Green Belt and important green field sites are hosts to a very diverse biosphere of fungal networks that are important to above ground plant life. Policy CC1

6.Pollution
Air pollution increases with development and traffic. Some but not all air borne pollutants are reduced where large green tracks exists. Put another way, a fully developed and built area with
stagnant air leads to respiratory problems. Policy CC1

7.Business Growth does not always require extra buildings
(In reality, it is people and their activities - not buildings and physical infrastructure - which release and realise creativity and productive potential that then creates income and wealth. Relationships between individuals, groups and communities create income and wealth. Traditional economics and that contained in the Local Plan considered an old formulae which is entrepreneur plus land, labour and capital creates wealth. A brief consideration of some of the largest businesses to date with phenomenal growth, these demonstrate Land is not so critical. Consider Facebook, Bit Coin, Uber, Amazon and Google. Policy CC1

8.Begin with the End in Mind
Furthermore even with a traditional model of economics, it is often forgotten that houses, buildings and housing estates are not actually ends in themselves. Rather it is the quality and range of activities of life that take place in those building that are the ends. For example, living a good life, having the best shelter to raise families et cetera. In public policy making, too often secondary and less important considerations intervene to prevent the best of all possible worlds being realised to ensure individuals, residents, employees and entrepreneurs achieve their potential through use of the spaces. Often important priorities go unmet.

9.Closing the Gap of Inequality

At least two things either globally or locally are creative of dissatisfied electorates. The first obvious - often invisible or silent in all its manifestations - is the increasing gap of inequality. Whether between Black Country Metropolitan areas or within the confines of them, the growing inequalities between those who have and those who have not income, wealth, health, care and environmental quality results in spiralling problems, some of which manifest themselves as the symptom of low educational attainment, mental health problems, delinquency, business crime, geographical criminality and drug, alcohol and solvent abuse.

Homelessness seen on the streets is not simply the lack of affordable or accessible accommodation.

The Local Plan and Housing Strategy makes no attempt to address the inequalities found within its boundaries. There is well documented evidence [see, for instance, The Spirit Level Why Equality is Better for Everyone by Kate Pickett. Penguin. 2010. Also, see Health Inequity in England The Marmot Review 10 Years On and various books by the author and others dealing with Health, Inequality and Inequity] that shows that increasing the gap of inequality is correlated with higher incidences of violence, death from ill health and rising incidence of self harm, addiction and homelessness.

10.“No Decision about Me without Me”

The second common problem evident locally and globally is that the voice of the electorate is too frequently ignored. People have the right and the wish, often on specific single issues or matters, to self-determine the outcome as it affects them. In the early days, the initial impetus for Black Country Local Plans was to address the criticism that people did not participate in decisions which affect their lives. It is a shame that the foundational reason has been lost in the process of driving forward the preparation, design and adoption of the Local Plan.

In relation to the small consideration of employment activity, which wrongly focusses narrowly on providing Land for employment, Black Country can be characterised as a largely aging population with less than average earning unlike the neighbouring shire areas where professionals who have extracted their income from the wealth of businesses in Metropolitan local authority areas but who then build their wealth and invest in shires. There is a get rich or get qualified and then move trend in the Black Country. If this is to be reversed then the Quality of Life and ambience of the Black Country must be lifted.

Other than the multiplier effect of income spent this model does not directly or significantly benefit the younger non-professional and some evaluation and assessment of their needs should have taken place.

11. Not just buildings - Building a future for the younger generation

The Local Plan has been endorsed and decided upon by members - near to or from 65+ year age group - that constitutes the Planning Committee. Their world view has metaphorically and literally a limited horizon and broadly remains out of touch with the urban younger generations that they seek to attract and keep within the Black Country sub-region.

The Local Plan speaks volumes of an old guard that has presented a document which would not have been out of place in 1950s, it does not breathe the climate of a gig economy, nor does it address the mobility of a fluid and moving generation. It does not recognise the type of facilities sought by younger generations.

Increasingly, the proportion of young people owning cars has declined so without taxis and public transport how does the younger generation obtain access to attractive employment generators?

Opportunity is not evenly distributed and land use planning can ensure better distribution but certain age groupings need better attention in the Local Plan. Cycling and cycle lanes have no prominence in the plan nor has provision been made for embedding 5G networks across the Local Plan area - literally this is the future and self-drive cars require a 5G coverage of networked points these linked to electric motor charge points will be the great enablers of a new form of mobility.

No consideration is given within the Plan to ensure younger generations have a varied range of income generating opportunities. They have neither the prospect of a guaranteed living wage or building wealth for themselves and their families. The disposable income of many younger generations does not match the familial needs of parenting or caring for elderly with low net worth.

The cry of opportunities for younger generations is writ small but who and how they have been involved in the Local Planning process? There are obvious groupings to consider, given the scale of the housing schedule for build within the Local Plan period, who will build these houses? Will it be built by young people trained and living in South Staffordshire? There are shortages in the building trade.

The economic perspective presents a certainty to a world when it is quite uncertain. Trade wars and protectionism are beginning to take shape. Many business sectors have unexpectedly declined. Banking had its crisis. Retail land and parts of the property market has collapsed across the country and office space is no longer wanted at scale. The ratio of employee to land has changed -less land is required.

White van man and women working on zero hour contracts are evident in most estates. Warehousing is fueled by online shopping but what job opportunities are planned for the younger generation in Black Country’s Local Plan?

12. Social and affordable housing, really the only consideration?

The issue for young people is not just about affordable housing it is also about creating an economy where they are guaranteed a salary or something better than a zero hour contract so that they can apply and obtain a mortgage.

The Housing Strategy and Local Plan have an ill-formed consideration regarding making homes for younger generations over the plan period.

Furthermore, there is wisdom in considering what categories and types of professions and jobs are available. There is much evidence of the growth of a Precariat usually young people who hold down several different jobs in order to make ends meet. [Precariat is a social class formed by people suffering from precarity, which is a condition of existence without predictability or security, affecting psychological and material welfare]

An innovative and relevant option seeks to have a more up to date and relevant consideration of the economy of growth of a newer age, one relevant for the young. An economy where travel to a business hub is minimal or not relevant. Where work is on the doorstep.

Providing opportunities for sustainable innovative rural-like economic growth on Greener sites whilst protecting the environment, including supporting green production and diversification and tourism.

Increasing the recognition of the need to diversify the rural aspects of a Metropolitan economy whilst enabling green site users and producers to continue managing the those limited rural landscapes and. providing training and jobs for innovators of production on Green sites.

Developing Green site production complexes, with a range of different sized buildings some connected to IT technologies, that might offer scope for alternative employment uses that support the rural-type economy, including tourism, in preference to other uses which may be less sustainable, such as conversions to residential uses.

Advancement of Forestry and Carbon saving and sinking economies. Alternative energy sources like wind farms.

The re-use of rural buildings for entrepreneurship and employment uses could provide opportunities for residents to gain employment locally, reducing the need to travel. Think for example, of mini science parks where the application of science (technology) is transferred to another industry (innovation) to farming and allied industries.

And importantly matching economic growth of Green perspectives, sustainability and carbon reducing work to the aspirations of the younger generation- think technologies to Save the Planet.

The number of adults with no qualifications although below the national average requires attention and focus. There are pockets of deprivation in South Staffordshire with higher levels of unemployment. Real and relevant support is required to tailor the development of the necessary skills. Widening the participation and improving access to education and local training opportunities is a key issue to be tackled smartly in the Local Plan, to ensure that all residents can benefit from economic gain and the necessary steps to closing the inequality gap should be spelt out in detail.

When Local Planning and Economic Development starts with ascertaining the qualitative and quantitative needs of individuals, groups, families and communities in a community or neighbourhood policies develop that are real, effective and wanted. Although harder to develop, neighbourhood participation and engagement activities provide a richness of information and perspectives for Economic Development and Local Planning. Usually, these exercises are thought to quite wrongly take power away from those with structural authority, done well they can enhance it.

13. High Rise and Higher Rise Build and Participative decision-making (Black Country Plan 2039 Hou2)

Too often, Land Use Planning has forgotten that good or great housing is determined by great architecture and sympathetic landscaping or simply community-based planning. Consider, for example, how the Dutch manage car, cycle and pedestrian conflict in the closeness of housing development matters which results in greater benefit for all at low cost. This is done through a far more discursive, collaborative and negotiable process than that normally found or chosen in Britain.

This idea and practice of a more involved and inclusive process of Planning is not prevented by the National Planning Framework and other forms of UK guidance. It does not happen more often in the UK for a number of reasons, although found in Europe and other parts of the World. One reason, has to do with the knowledge, expertise, culture and ethos of planners which, other than a few exceptions, is no longer as sympathetic - as it once was in 1960s - to participative decision-making. Some might say, the loss of faith in politics and broader distrust of public decision-makers and professionals is because they fail to embrace practices which result in stronger engagement with communities, groups and people affected by their decisions. The failures of urban design usually results from poor community and stakeholder participation and engagement.

More collaborative land use planning avoids many knowable mistakes and reveals activities that make unacceptable general ideas into to failsafe and future proof designs for development. The failure of municipal High Rise buildings in the UK was not due to building too high but truly and simply to the fact that architects and planners did not take into account the need to provide accessible social spaces to build community infrastructure for occupants.

In most Capital cities High Rise is the first choice of the Uber rich, so why hasn’t Black Country given more thought to sympathetic and community-focused High Rise and Higher Rise housing development to meet its housing targets and extraordinary additional provision?

Some cultures respect their natural resources that the restrictive development opportunities on green sites leaves them with few choices other than to build taller residential accommodation to match demand.

Here you have it, is the failure to achieve consensus of the Black Country Housing Strategy and Local Plan Review because it is too polarised and myopic being focused on Housing development through Green Belt loss? - a strategy that elsewhere would be avoided at any cost.


14. Carbon Sink
The Seven Cornfields provide a carbon sink for Wolverhampton. The importance of this asset to address air pollution and store atoms like carbon cannot be overestimated. It is fundamental to survival on this planet and locally that carbon is captured and stored.

5. LOCAL PLAN AND HOUSING STRATEGY CONSIDERED

Communities in Wolverhampton and Dudley say that we have the same right to expect certain things for our area (the Seven Cornfields is does not immediately affect residents living in Sandwell and Walsall although walkers do come from those boroughs). So we say;

“Here in Wolverhampton and Dudley, we are extremely proud of the district’s historic and distinctive character, along with the thriving communities sustained by residents who truly care about the places in which they live. ‘

The Black Country Local Plan proposals will fundamentally affect the chances of Wolverhampton , Sandwell, Walsall and Dudley residents to achieve the above aim for ourselves.

And at this point, it is useful to remind all of the Golden Rule which can be considered a moral or ethical principle of reciprocity:

‘one should treat others as one would like to be treated by others’ or ‘do not treat others in a way that one would not be liked to be treated.’


6. BROWNFIELD AND DERELICT LAND SITES FIRST

The Save the Seven Cornfields Campaign Group considers that the evidence for Brownfield and Derelict Land sites development to match housing needs has to be monitored thoroughly. Who sells the family treasures when there is loose change around the house, coins in the piggy bank and money in the bank accounts? There is ample Brown Field and Derelict Land sites within in the Black Country Sub-region to service its needs for several years into the next decade and further.

When Derelict Land grant was available for tackling Dereliction many sites where annually transformed into productive use including housing. Taxation relief is another method to ensure a faster rate of transformation.

The failure to develop Brownfields has much to do with margins of profitability and economies of scale. It is easier and more profitable to develop on most Greenfield sites than on Derelict and Brownfield sites. In addition, Housing Developers and Speculators favour the acquisition and land banking of Green Fields sites. Notwithstanding these facts, there is no logical reason for a Local Authority to release Greenfield sites or extinguish Green Belt status when there are many Brown Field and Derelict Land sites to develop first. Allowing easy access to Green Belt development means the Brownfield and Derelict Land sites will remain and they will not be transformed into useful use. Anybody with an eye to sustainable Land use policy and environmental conservation in its largest sense would ensure the future Housing Demand was met by a policy of Brown Fields first.

On 17th March 2017, West Midlands Combined Authority Board received a Report entitled Land Fund: Black Country Strategic Brownfield Land Programme. The Report noted:

“The Brown Field Strategic Brownfield Land Programme has identified a robust and deliverable pipeline of £342m of schemes, leveraging total investment of over £1.4b within three Priority Propositions of Delivering Black Country Garden City, Establishing High Value Manufacturing (HVM) Capital City and Strategic Population Centres.”

Given the rising vacancy trends in retail, office and industrial property and the diminishing demand, the annual growth of the supply rate of Brownfield and Derelict Land will increase, and the net result will be a year-on-year incremental growth and, therefore, a much higher total availability of such sites -unless of course there is a consequential turnover of reclamation for productive use like Housing. This then suggests less of the South Staffordshire Housing requirement - either normal (4,000) or exaggerated target (8,000) - will have to come from green sites or the Green Belt.

With investment from the WMCA Board, the Report made it clear that remediation would deliver 1600 houses. What higher levels of reclamation could be achieved over the Local Plan period with a more targeted approach, enough to not need the additional 4,000 pledged by South Staffordshire Council.


7. TRIPLE LOCK - PREVENTION OF PLANNING BLIGHT

If the prospect of 8,000 houses becomes accepted in its totality and formally agreed in the Local Plan then immediate measures must be put in place to prevent the problems witnessed when elsewhere where developers and speculators blight areas. For example nearby, national retailers made speculative purchases and acquired land or development rights within a City to block and prevent expansion of their competitors. This created long-standing problems and prevented the amenities of the area being used and shared by nearby residents. It also prevented other forms of investment. This should not happen in South Staffordshire. If developer or builders were to start but not complete work on all the Green Belt sites released at once then the worst of all worlds would have arrived; lost Green Belt but not completed sites with a few houses but no amenities.

Planning Blight is where the reduction of economic activity or property values in a particular area results from expected or possible development.

Should their opposition to Options B to G not result in the choice of Option A, The Save the Seven Cornfields Campaign Group proposes that there should be a Triple Lock applied to Green Belts. There should be proper monitoring of housing development in South Staffordshire and Green Belts should not be released at once but a phasing should be operable. The release of individual sites should then only occur when it is obvious that the available non-Green Belt sites in South Staffordshire and the Brownfield and Derelict Land sites in the district and Black Country have been developed, that the Black Country Housing have not been met year-on-year and the lowest graded Green Belt sites with the fewest constraints get released first.

This Triple Lock should be written within a Local Plan Objective and Planning and Development Briefs and it must form the basis of future agreements with developers and builders.

8. THE SAVE THE SEVEN CORNFIELDS CAMPAIGN GROUP
FAVOURS OPTIONS FOR DEVELOPMENTS CLOSE TO MOTORWAY LINKS AND THOSE NEAR TO TRANSPORT LINKS THAT HAVE ADEQUATE CAPACITY


The Save the Seven Cornfields Campaign Group favours options for development which are far less detrimental to the overall environment than others. This a fairly self-evident position.
On balance, those non-Green Belt sites embedded in spaces close to Motorways and near to major transport links with adequate capacity ought to be considered more sustainable, realistic and achievable. These makes use of the existing Motorway networks between housing and major job centres in Midland business cities and towns.

The access to job opportunities through the Motorway network does not create further
a) immediate air pollution index rises in residential pollution in residential (obviously most car travel generates pollution);
b) hazards close to homes and schools.
c)congestion on already congested primary roads connected to residential areas.
d)it does not conflict with so many existing planning and housing conditions.

The motorways of the M6, M6 Toll and the M54 run through the Black Country and South Staffordshire districts giving access to the Midlands motorway network and beyond. (There are proposals for a new M6/M54/M6(Toll) link road from Junction 1 M54 to Junction 11 M6, however as yet no definitive route proposal has been identified. The M6 has just been upgraded to a smart motorway to manage traffic flows effectively at peak traffic times (but is already congested and a more dangerous for the motorist, raising the issue of having economic policies not premised on sustained growth - see elsewhere)). Thus, making it more attractive to consider job opportunities in employment hubs in City Centres and their hinterlands from Wolverhampton to Manchester City centre.

(It is for these reasons that the Save the Seven Cornfields favoured Only Option A completely avoids Green Belt loss and fulfils the South Staffordshire’s perceived housing need, but cuts the contribution to Greater Birmingham’s unmet needs (see the GBHMA Strategic Growth Study by 969 houses from the unnecessary (up to) 4,000 proposed. )


9. THE SAVE THE SEVEN CORNFIELDS CAMPAIGN GROUP HAS OBJECTIONS TO EXCESS HOUSING TARGETS IN THE BLACK COUNTRY PLAN (& SOUTH STAFFS PLAN).

The Plan involves allocation of growth to Green Belt areas and this must be objected to on a number of grounds. Either the National, Regional and Sub-regional have Comprehensive Planning Frameworks based on consensus or they do not. A Planning Framework premised on Greed and Neo-Liberal Economic theory isn’t a comprehensive Planning basis. The Green Belt was the cornerstone of post war Planning and growth management. It acknowledged everyone had a right to some quality spaces away and between urban sprawl.

It simply is not good enough to have professionals evaluate whose loss is graded as of high or very high harm to the Green Belt. Such grading may have value if arrived at by participative decision-making.

The Save the Seven Cornfields Campaign Group do not consider the loss of the Seven Cornfields and other Green Belt sites this is a price worth paying for additional houses. Especially when the forecasting model is questionable and based on assumptions from a economic and social world that was so different prior to Covid 19 than after its emergence.


Here a list of planning reasons behind the objections to development on the Seven Cornfields:
Affordable Housing Mix

The mix of much needed affordable social housing provided is unclear and cannot be guaranteed.

Insufficient local infrastructure

Transport and Traffic Congestion - too much extra housing around the borders of Wolverhampton and Dudley will lead to further pollution and congestion on busy roads.

The road system around Seven Cornfields site is congested and insufficient for any additional traffic. At peak times all the estates feeder roads onto main roads are already gridlocked.

The roads from Penn, Ettingshall Park, Northway and Goldthorn estates towards Wolverhampton and Birmingham are congested and at capacity. Wolverhampton and Dudley residents will bear the brunt of the traffic increase.

The development of thousands of houses will place a huge strain on the infrastructure of the Goldthorn Park, Northway, Ettingshall Park and Penn estates which are adjoining areas to the Green Belt.

No Accident and Emergency facilities exist in the South Staffordshire. Additional pressure will be placed on Russells Hall Hospital in Dudley or New Cross Wolverhampton Hospitals. Both hospitals are at capacity.

Primary and Secondary Schooling provision will be exhausted.

The development of the Wolverhampton part of the Seven Cornfields will make it easy of a developer or developers to build on the South Staffs part of the site. And Vice Versa. There are infrastructure issues which revolve around Policing, Fire Service coverage and Ambulance callouts. Is South Staffordshire likely to increase funding of policing and Fire Coverage at Wombourne? Ambulances would have to respond from New Cross and Russells Hall Hospitals.

Health and Well Being will be affected badly because of the further strain on GP surgeries, hospitals and dental services

There will be a loss of spare service capacity, for example, waste disposal

Environmental issues

The proposed developments are over-bearing, out-of-scale and out of character in terms of appearance compared with existing development in the vicinity

Increasing hazards and dangers on the roads will follow excess road traffic, there will be a decline in road safety, an increase in accident hot spots, increased noise, floods, fire risks from local warming

Negative Environmental Impact across the area with a loss of wildlife, biodiversity, air quality, open spaces,

Scale of developments would affect the water table and massively increase the extent and duration of flooding, for instance at Penn Golf Course

Unacceptably high density / over-development of the Penn Wood or Seven Cornfields site.

Adverse effects on residential amenity of adjoining estates and neighbours, by reason of -among other factors - noise*, disturbance*, overlooking, loss of privacy, overshadowing, etc. [ note noise or disturbance arising from the actual execution of the works, which will have to be taken into account, in relation to conditions that may be imposed on the planning permission, dealing with hours and methods of working, etc. during the development around sites where vulnerable people are present - Sedgley Blind Institute]

Quality of life of existing residents will suffer.

Loss of Green Belt will result in urban sprawl, the merging of towns and housing estates

Linked directly to the increase in traffic and the loss of green belt land is the deterioration of environmental factors such as air quality.

Penn, Goldthorn, Blakenhall, Ettingshall Park and Northway estates suffer from stationary traffic during commuting hours, as a result the level of air pollution from vehicle fumes is excessive. An additional 1000s of vehicles would increase the likelihood of respiratory illness like Asthma.

Increased associated vehicle noise levels is inevitable together with accident rates associated with the increase in vehicle numbers.

Public transport would need to be reviewed and would in all likelihood require increased investment

Loss of recreation, play and open spaces especially important for people with mental health problems

Access to the rail infrastructure is distant and prohibitive but Option A has the right level of infrastructure in play.

Visual impact of the development making area unattractive to inward investment.

Effect of the development on the character of the neighbourhood will be detrimental.

Loss of existing views from neighbouring properties and estates would adversely affect the residential amenity of neighbouring owners

The development would adversely affect highway safety or the convenience of road users.
.
Green belt destruction.

Development of green belt land will negatively contribute to climate change issues in every case.

Loss of enjoyment, discovery and exploration,

Loss of family, exercise and health benefits of fields for walkers, dog-walkers, naturalists

Areas proposed for development clearly on established green belt are close to ancient woodlands, large parts of the established eco systems would be destroyed together with the associated wildlife

Mental Health problems are on the rise and everyone needs quiet places to relax and meditate on established and well used public open space accessible without the use of vehicles. Local residents have a place to relax using a network of very well established footpaths and highways through historic agricultural land.

Loss of habitat and wildlife from the area would be irreversible.

The new roads for homes and associated driveways would contribute to flooding and effect the natural balance of the area.

Massive loss of Green Belt, footpaths and open aspect of the neighbourhood (‘green belt grabbing’ on an unnecessary and industrial scale )


10. THE SEVEN CORNFIELDS CAMPAIGN GROUP
OPPOSES HOUSING DEVELOPMENT ON THE GREEN BELT AND THE SEVEN CORNFIELDS AND OBJECTS TO ANY LOSS OF GREEN BELT SITES IN OR AROUND WOLVERHAMPTON OR DUDLEY


There should be a basic opposition to dismantling any part of the Green Belt - it is a simple concept which has served Britain well in comparison with other countries in protecting our countryside. Indeed, it might be said that rural - and urban in leafy suburbs - tourism has been a success because of Green Belt status sustained in large visitor centres.

The purposes of the Green Belt include the protection against encroachment from and between adjoining major urban areas. They prevent regions, counties, sub-regions like the Black Country and districts swallowing their green boundaries and then as if by accident become an urban sprawl. They act as a barrier to the coalescence of rural and urban settlements in order to retain the attractive distinctive character of each rural or urban setting of settlements. The original land use planning developed with titles like the Town and Country Act - this showed the importance of the distinction.

Housing development on key Green Belt sites adjacent to housing estates cannot be allowed because infrastructure is necessary and must be sufficient to serve the demands generated.

Additional infrastructure and upgrading will have to take place prior to development of housing. Roads will have to extended possibly widened and traffic management systems upgraded to control flows productively and effectively. Their critical educational issue will be the provision of a secondary school. This will need to be built and the schools made operational prior to the housing development completion.

This in turn will mean that those living on estates adjacent to the site will suffer from:
Loss of clean air
Serious local flooding due to lost natural water drainage
Shortage of local school places as competition increases will be dramatic
Class sizes will in turn increase poor education attainment
Hospital patient face longer waiting lists
Waiting time for doctor appointments will increase
The extent of traffic jams and grid lock on local feeder roads will increase
There will be less recreational space for walks or play
There will be a loss of local wildlife and plants

The Black Country Plan 2039 needs to take account of the Green Belt Review published by LUCs, which seek to assess parcels of land within the Green Belt against the five tests set out in Paragraph 134 of the National Planning Policy Framework (NPPF):
1. to check the unrestricted sprawl of large built-up areas.
2. to prevent neighbouring towns merging into one another.
3. to assist in safeguarding the countryside from encroachment.
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.


11. THE SEVEN CORNFIELDS CAMPAIGN GROUP
OPPOSES HOUSING DEVELOPMENT ON PENNWOOD FARM AND THE SEVEN CORNFIELDS SITE


The Seven Cornfields site comes in the highest of five categories of Green Belt in the South Staffordshire Green Belt survey – loss would be of ‘very high harm’ to the Green Belt - and in the higher of two categories of Green Belt in the Greater Birmingham Housing Market Area (GBHMA) survey – ‘principle contribution’ - but much of the wedge further out towards Wombourne is categorised in the GBHMA survey in the lower ‘supporting contribution’ and the overall area west of Wolverhampton is one of the areas where it thought that ‘proportionate dispersal’ (small developments) might be appropriate. It is however much worse north of the Black Country, where two more proportional dispersal search areas, a ‘development area with an employment focus’, two ‘urban extensions’ and two possible ‘new settlements’ are postulated!

The Seven Cornfields are a microcosm, at present there are patches of woodland surrounded by arable fields, there are, however, wildlife corridors, hedgerows and footpaths where wildlife can move round at night passing unseen down these trails, so the woodland patches are not isolated one from the other. The ecosystem has developed over centuries but has adapted to minor intrusions of humankind. If houses are built on all of the Seven Cornfields, hedgerows cleared and the Penn Brook banks manicured and landscaped for the residents of the new estate then these vulnerable corridors will disappear. The wildlife of the woodlands will vanish. Anthropogenic species like foxes will persist but bats, xxxxxs and butterflies and perhaps the birds of prey will be lost for this and future generations.

Pennwood Farm is an important wildlife corridor and represents one of the more ecologically rich and varied mosaics of habitats in the wider farming community, where the wildflowers on adjoining farms have been destroyed by spraying, and these farms have been virtually sterilised by over-intensification and are much less rich in invertebrates and the birds that breed and feed on them.

The farm has important hedgerows for breeding Yellowhammers and the rough grassland supports several pairs of Skylark. Both species are Red Listed by the Royal Society for the Protection of Birds as species of National Conservation Concern.
The Horse paddocks and associated bridleways and rough ground support good populations of nectar sources which in turn support 22 species of butterflies, making it a 'hot spot' in South Staffordshire.
Ancient woodland and hedgerows around the farm are important breeding areas for a variety of birds and 72 species have been recorded on the farm in recent years.

The Staffordshire Biodiversity Action Plan

The Staffordshire Biodiversity Action Plan (SBAP) to which South Staffordshire Council are joint partners with other organisations, has been in place since 1998 in order to co-ordinate conservation efforts to deliver the UK Biodiversity Action Plan.

Several pairs of Skylark breed on the rough grassland at Penwood Farm (The Seven Cornfields) and this species has its own Action Plan in the SBAP.

See Appendix 2. Extracts from Staffordshire County Council Protected Species Advice Document
which includes planning advice and guidance on biodiversity conservation.

Detail of Butterflies population on the Seven Cornfields can be found in Appendix 3. Butterflies recorded annually at the Seven Cornfields, Pennwood Farm.

Flooding

Currently, Penn Golf Course suffers from frequent flooding and there are concerns that the water table will be affected to bring other areas into zones of high risk of flooding if development of housing proceeds on the Green Belt without an assessment of the likelihood of flooding in a particular area so that development needs and mitigation measures should be carefully considered.

There is an important water course on the Seven Cornfields known as Penn Brook, this was originally called Lloyd brook, it flows westwards across the common from its source on Colton Hills. When the brook leaves the common it becomes the River Wom (after which Wombourne is named).

Penn Brook is one of the key tributaries of Smestow Brook. It falls 90 metres (300 feet) in 8 kilometres (5 miles). The Penn Brook rises in the natural amphitheatre created by the heights of Goldthorn Park, the Northway and Colton Hills.

Development of the sloping site of the Seven Cornfields is likely to cause additional flooding problems especially as annual rainfall appears to be increasing.

Significant transport investment is needed to support options.

The thinking on growth is wanting and depends too heavily on extinguishing Green Belt status.

Economic Development perspectives are weak within the policies and the proper benefits of a Local Plan are lost as no attempt has been made to link the changed technological, sociological and economic landscape into a cogent framework for the future. More work needs to be done.

There is a need for additional infrastructure with an extra range of alternatives to support the requirements of integrated transport to effectively and efficiently accommodate such excessive housing growth as promoted.


Appendix 1

KEY POINTS MADE TO SOUTH STAFFS
AN EXTRACT FROM SUBMISSION

That South Staffordshire expects their distinctive character to be maintained whilst destroying others is a matter that needs to be considered fully. What holds as a valid principle for guiding Local Plans must have an equivalence when used as an objection to a proposal.

Whilst the South Staffordshire Local Plan’s movement for growth does not obliterate high proportion or significant high percentages of South Staffordshire’s total Green Belt land ( ‘Much of South Staffordshire (80%) lies within the West Midlands Green Belt (32,089 hectares)”). It does affect and obliterate important proportions or a high percentage of the very limited Green Belt available in Dudley and Wolverhampton that creates a distinctive character of Green around urban local settlements in Dudley and Wolverhampton.

A loss for Staffordshire of Green Belt sites has very minimal effects on the local Shire character because South Staffs has so much Green Belt.

The erosion of Green Belt in South Staffordshire by our boundaries, however, has a disproportional negative affect on the distinctive character and quality of life of neighbourhoods in Wolverhampton and Dudley.

At the end of the Forward,

“South Staffordshire has historically proven to be an attractive location for people to live. It has been a destination for people moving from the West Midlands major urban area and other nearby towns. Pressure for housing growth over and above the needs arising purely from within the district has continued. South Staffordshire’

Then in the Executive Summary of the Housing Strategy,

“Our preferred approach, Option G, is very much Member led. We believe Option G will meet our housing numbers, make a contribution (under our legal Duty to Cooperate) to the wider unmet housing need and also take account of the impact of development on current infrastructure and what opportunities there are for new and improved infrastructure. This approach will, however, lead to Green Belt release and this is something that has been very carefully considered in formulating the options. We know there are very difficult decisions to be made in providing new homes and protecting the Green Belt.”

A forensic examination of this statement and its implications reveals an underlying ethical, moral, professional and political intent. This is inherent and pervasive within the documents which support the Housing Strategy and Local Plan, it reveals a prevailing and unwanted sympathy.

The Preferred Option and majority of other Housing Options that allow a Housing Target build of 8,000 as presented or captured in the South Staffordshire Housing Strategy and Local Plan can only be possibly categorised in harsh terms as parasitism, imperialism and colonialism. Although harsh, a quick turn to the Oxford Dictionary of English allows a judgement and check:

a) “Parasitism ‘habitually relies on or exploits others and gives nothing in return’.”
b) “Imperialism ‘a policy of extending a country’s [local authority’s] power and influence through colonization, use of military force, or other means’ ”
b) “Colonialism ‘the policy or practice of acquiring full or partial political control over another country [local authority area], occupying it with settlers, and exploiting it economically’ ”

Globally, policies of that nature were detrimental to indigenous populations and ecosystems and disregarded the care, needs and demands of those existing populations, residential communities, people, groups and individuals. Applied in more local practices within the Local Plan, they are equally unpalatable since the strategy seeks to impose a leadership or dominance by one state - South Staffordshire Council - or social group (Elected members as this is after all a member-led strategy) over others, the Wolverhampton and Dudley communities adversely affected at the boundaries by development on the Green Belt. It relies on exploiting others and gives nothing in return.

It is also not clear why in Plan B, urban extensions are biased towards west of the Black Country. There is a key question that follows this bias and it needs to be answered: Why was it found necessary for urban extensions to be biased towards west of the Black Country in this particular plan?

There is as much, or more, Green Belt land of less than high or very high harm in the north and more land beyond the Green Belt but still in perfect reach of the whole conurbation via the A5, M6 and M54. This is much less true of Green Belt west of the Black Country, however close in proximity to the conurbation. A requirement for development to be in ‘close proximity’ to the conurbation would inevitably impinge on high harm Green Belt.

It’s more about Income and Wealth rather than Planning and Housing Considerations

South Staffordshire Council’s Local Plan highlights land for development as requirement of central Government however, the extra 4,000 above target largely is made largely on economic basis to increase their income collected by the Council.

Housing development claims on South Staffordshire Council’s infrastructure investment would be at a very low relative level with additional residents being serviced by neighbouring boroughs, whilst allowing a steady revenue stream to South Staffordshire Council through the chargeable Council tax for higher band "more expensive" properties. The costs of infrastructure would fall unfairly on the adjoining areas of Wolverhampton and Dudley who would not receive the Council Tax receipts. Imperial, parasitic and/ or colonial what words best describe this relationship?

South Staffordshire is rightly proud that it is prosperous with the proportion of those employed within the top three professional and managerial sectors being above the national average. Many if not most of these are people employed outside the area who bring the income from elsewhere into South Staffs to create a wealth base there.

Advantages and Disadvantages of the Different Options in South Staffordshire Housing Strategy

The Save the Seven Cornfields Campaign Group has fully considered the various Housing Options which are presented in summary form in the Appendices. There was much discussion of the advantages and disadvantage of these but reason, logic, planning considerations and the common purpose of community interests lead to a series of objections, endorsements and comments which are provided in much greater detail below in the following pages.

Option B includes development of Green Belt and achieves the full plan of 9,130 dwellings between 2018 and 2037, including the unnecessary full contribution of up to 4,000 dwellings to the GBHMA, but avoids allocating growth to Green Belt areas of high or very high harm. The Save the Seven Cornfields Campaign Group acknowledges this is the second best (after Option A) in terms of protecting the Green Belt.
.

Appendix 2.
Extracts from Staffordshire County Council Protected Species Advice Document
Skylark
A national BAP target species with a costed action plan and a Staffordshire BAP target species. Ground nesting in grassland or low vegetation including crops. Skylarks require open areas with an absence of features such as trees and hedgerows that act as perches for potential predators. They will not nest in confined areas. Spring planting is key where arable land is used for nesting.
Yellowhammer
UK BAP species of conservation concern and Staffordshire BAP target species. Nearly always nests on the ground, if not, always close to it hidden among grass and herbage, typically against a bank or at the base of a hedge, small tree or bush. The yellowhammer begins laying from April to early August and frequently produces two and sometimes three broods, each taking up to 28 days to fledge and therefore they have usually cleared the nest site by mid-September. skylark begins laying between late March and late April and may produce four broods, each taking between 21 and 30 days to fledge and therefore they have usually cleared the nest site by August.

Planning Guidance and Protected Species Planning Policy Statement 9 Biodiversity and Geological Conservation includes a set of Key Principles that should be applied to all planning decisions. These include: • Planning decisions should be based upon up-to-date information; • Planning decisions should give due weight to protected species and to biodiversity interests within the wider environment; • Planning decisions should aim to maintain biodiversity interests and to enhance, restore or add to these; • The aim of planning decisions should be to prevent harm to biodiversity interests. Where significant harm may ensue from planning consent, planning authorities should be satisfied that the development cannot be alternatively located. Should alternatives not be available, adequate mitigation must be put in place before planning permission is granted, or, if mitigation is not feasible, appropriate compensation measures must be included in development proposals. • Planning consent should be refused if harm cannot be prevented and adequate mitigation or compensation cannot be secured.

In addition to legally protected species, PPS9 (paragraph 16) advises that local authorities should ensure that species of conservation priority and their habitat are protected from the adverse effects of development. A list of these species was drawn up in response to section 74 of the Countryside and Rights of Way Act 2000 and can be found on the Defra website. This list is also referenced by sections 40 and 41 of the Natural Environment & Rural Communities Act 2006 (see s.2.5 and Appendix 1).

Guidance on the application of legislation related to planning and nature conservation is found in Government Circular: Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System (ODPM Circular 06/2005, Defra Circular 01/2005) which complements PPS9. Paragraph 98 advises that the presence of a protected species is a material consideration in considering planning proposals. Paragraph 116 advises that the presence of a European protected species should be given due weight in making planning decisions and may justify refusal of planning consent. Paragraph 99 states that the presence or otherwise of a protected species, and the extent to which it might be affected by a proposed development, must be established prior to the granting of permission, otherwise all material considerations may not have been addressed.

This means, as the Circular advises, that ecological surveys should be carried out prior to consent and should not be conditioned except in exceptional circumstances. Measures for species protection should be incorporated into planning proposals prior to consent and be implemented through conditions and/or planning agreements. While the presence of a protected species does not need to be already recorded, survey should only be required where there is a reasonable likelihood of the species being affected by the development. It should be noted that planning consent does 11 not provide derogation from the requirements of protected species legislation which must still be met, including through the acquisition of licences where relevant.
APPENDIX 3.

Butterflies recorded annually at The Seven Cornfields, Pennwood Farm, Wolverhampton
(compiled from personal records by David Jackson on behalf of the West Midlands Branch of Butterfly Conservation)

1. Essex Skipper – Fairly common along grassy strips and uncut field margins.
2. Small Skipper- ditto as with the above-mentioned species.
3. Large Skipper- Several usually encountered in uncut field edges and on Bramble patches.
4. Orange Tip – several seen each Spring, along banks and in damper patches where Garlic Mustard and Cuckooflower, its larval stage food-plants grow.
5. Large White- Not as common as it was 4-5 years ago but still frequently seen.
6. Small White – common in the planted fields.
7. Green -veined White - as with Orange Tip requires damper patches of farmland where Garlic Mustard and Cuckooflowers grow. Up to a dozen are recorded each season.
8. Brimstone- scarce.
9. Speckled Wood – common along hedgerows and by edges of shady woodland.
10. Ringlet – common along uncut hedgerow bases, in longer grass.
11. Meadow Brown- common in set aside and longer grass in uncut paddocks.
12. Gatekeeper- Several usually seen basking by gates on Bramble and Bracken.
13. Marbled White - occasional visitors stray onto the farm from a strong colony on Sedgley Beacon.
14. Red Admiral – singles frequently seen on the farm near to Common Nettles.
15. Painted Lady – on a good ‘Painted Lady Year’ several can be encountered on the farm.

1. Peacock- singles frequently seen on the farm usually near Nettle beds which its larval stage requires to breed.
2. Small Tortoiseshell – up to a dozen encountered each year on the farm usually near Nettles used by its larva to feed.
3. Comma – ditto as per the two above-mentioned species.
4. Small Copper- scarce but recorded annually near Common Sorrel its larval stage food-plant.
5. Purple Hairstreak- usually seen high up in the woodland Oaks in small discrete colonies.
6. Holly Blue- several seen each year in and around Holly bushes and Ivy covered trees.
7. Common Blue - over the past two years there has been a resurgence from six or seven individuals seen per year, now up to two dozen recorded on a good day in the uncut meadows and horse paddocks, where its larval stage main food-plants Common Birds foot Trefoil and White Clover grow.

Object

Representation ID: 23569

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

PREJUDICIAL DECISION ON GREEN BELT LOSS & ADDITIONAL HOUSING BASED ON EXAGGERATED HOUSING FORECASTS (Policy HOU 1 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group insists that the decision to meet an over-exaggerated Housing Target of 76,000 unilaterally and automatically erodes important Green Belt provision and dismisses the concerns of local residents and campaign groups. It is ultimately prejudicial to the integrity, cogency and strategic and tactical decision-making of the Black Country Housing Review to presume any acceptability of development in the Green Belt.

Object

Representation ID: 23570

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

BROWN FIELD AND DERELICT LAND SITES FIRST (Policy DEL2 in the Black Country Plan 2039)

The Save the Seven Cornfields Campaign Group considers that the changing evidence and absolute scale of Brownfield and Derelict Land sites development for housing purposes and needs has to be monitored thoroughly and plotted to understand the dynamics at play in the sub-region and neighbourhoods.

With few reservation, mostly relating to the characteristics and locality of specific sites, the Save the Seven Cornfields Campaign Group supports Housing Development on Brownfield and Derelict Land sites. The Save the Seven Cornfields Campaign Group opposes development on the Seven Cornfields Green Belt and other important Green Belt zones.

There is ample Brownfield and Derelict Land sites within the Black Country sub-region to service its needs for several years into the next decade and further. Incentives can assist developers to make the right decision.

When Derelict Land grant, sometime ago, was available to Local Authorities for tackling Dereliction, many sites where annually transformed into productive use including housing across the sub-region.

Taxation relief is another method to ensure a faster rate of transformation of Derelict and Brownfield sites. Governments should be lobbied to provide such assistance.

The failure to develop Brownfield sites has much to do with margins of profitability and economies of scale. This a private sector consideration and not necessarily an economic concept applicable to the public who instinctively know what is known as a Public Good in Economic Theory.

It is easier and more profitable to develop on most Green Belt and Green field sites than on Derelict and Brown Field sites. It is not, however, always easier and more profitable to develop on most Green Belt and Green Field sites when the infrastructure costs of over-intensification of use of services are taken into consideration.

In addition, Housing Developers and Speculators favour the acquisition and land banking of Greenfield sites to control the price of land already held by them and can be classed in their accounts as an investment. In the same manner, the most famous Diamond monopoly merchant buys and then withholds diamonds to ensure a higher price than would be naturally be the case if these diamonds where released on the open market. Artificial scarcity is created for Housing land (and diamonds).

Notwithstanding these facts, there is no logical reason for a Local Authority to release Greenfield sites or extinguish Green Belt status when there are many Brown Field and Derelict Land sites to develop first.

Allowing easy access to Green Belt development means the unsightly Brownfield and Derelict Land sites will remain for longer than necessary were the natural market mechanisms not distorted by Land Banking. They will not be transformed into useful use when they could have been.

Anybody with an eye to sustainable Land Use policy and environmental conservation in its largest sense would ensure the future Housing Demand was met by a policy of Brownfields first.

On 17th March 2017, West Midlands Combined Authority (WMCA) Board received a Report entitled Land Fund: Black Country Strategic Brownfield Land Programme. The Report noted:

“The Brown Field Strategic Brownfield Land Programme has identified a robust and deliverable pipeline of £342m of schemes, leveraging total investment of over £1.4b within three Priority Propositions of Delivering Black Country Garden City, Establishing High Value Manufacturing (HVM) Capital City and Strategic Population Centres.”

With investment from the WMCA Board, the Report made it clear that remediation would deliver 1600 houses. What higher levels of reclamation could be achieved over the Local Plan period with a more targeted approach? Enough to not need development of the Green Belt (or the additional 4,000 pledged by South Staffordshire Council).

Given the rising vacancy trends in retail, office and industrial property and the diminishing demand, the annual growth of the supply rate of unwanted commercial and Derelict Land and Brownfield sites will increase and the net result will be a year-on-year incremental growth and, therefore, a much higher total availability of such sites -unless of course there is a consequential turnover of reclamation for productive use like Housing. (This then suggests that less of the South Staffordshire Housing requirement -either normal (4,000) or exaggerated target (8,000) - will have to come from Green sites or the Green Belt.)

TRIPLE LOCK - PREVENTION OF PLANNING BLIGHT (policy Del 2 in the Black Country Plan 2039)

If the prospect of additional houses as planned and formally agreed in the Black Country Plan 2039 moves to that reality then measures must be in place to prevent the problems, recently witnessed, when retailers acquired land or development rights in cities to prevent expansion of their competitors. In Wolverhampton City Centre this created long standing problems.

If developers or builders were to start but not complete work on all the Green Belt sites then the worst of all worlds would have arrived; lost Green Belt but not completed sites with a few houses but no amenities.

Planning Blight is where the reduction of economic activity or property values in a particular area result from expected or possible development.

The Save the Seven Cornfields Campaign Group proposes that there should be a Triple Lock applied to Green Belts. There should be proper monitoring of housing development in Black Country (& South Staffordshire) and Green Belts at risk and other important Green Sites should not be released at once but a phasing should be operable.

The release of individual sites should then only occur when it is obvious that the available non-Green Belt sites in the Black Country (& South Staffordshire) and the Brownfield and Derelict Land sites in the districts within the Black Country have been developed, that the Black Country Housing figures have not been met year-on-year and the lowest graded Green Belt sites with the fewest constraints get released first.

This Triple Lock should be written within the Black Country 2039 Plan’s Objective and Planning and Development Briefs and it must form the basis of future agreements with developers and builders.

Object

Representation ID: 23571

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

It is quite strange that the Black Country Local Plan has not given proper Spatial Land Use Planning Consideration for Employment or Economic Development. It is unfortunate and untimely that the Black Country Employment Area Review Or BEAR will not be available until August.

It has premised growth through Housing but not materially considered alternative perspectives.

For instance, it would not be out of the question to adopt a thriving no growth strategy which is about making Black Country capable of standing alone in a sustainable local economic development model. Such a strategy being more akin to current vectors of change and not positioned on continuous sustained consumption.

It might also have been a strategic decision to promote micro-enterprises and venture capital investment which fostered business that were not dependent on travel to and from the major business hubs. After all the networked world has demonstrated the potential for different kinds of business and, during Covid shut down, the attractiveness of working from home.

This refreshed option builds upon the strength of adding a more current and real employment perspective which seeks to broaden the economic base. This needs to be interdependent, agile, far-sighted, current and inclusive rather than orthodox, rigid, myopic and exclusive.

The fallacy of linear projection of employment applies in the current Local Plan and its preparation, this is where agencies such as the Council act as institutions of continuity as they show themselves loathe to innovate, preferring incremental change of a known order rather than violent transformations in line with emerging trends.

The Black Country plan demonstrates the popularity and longevity of the dominant paradigm regarding unchecked growth which may not prove sustainable.

Local Planning was meant to take on sociological, technological and economical change

The whole point of a Local Plan for the Black Country is to provide an integrated and comprehensive series of policies which draws together the inter-related aspects of a complex world. For instance, to consider Homelessness (which is not given proper consideration) is to treat a problem of inequality which is multifaceted and not just a matter of buildings and availability. Local Plans are meant to go beyond simple Land Use Planning considerations.

Likewise, providing the right dwellings at the right time is not about providing, for instance, building 4 bedroom luxury homes at points unconnected to future growth points, technological assets and demands created by changing sociological characteristics.

Much of the Black Country Local Plan appears a ‘gold rush’ to release the national treasure of the Green Belt and important greenfield sites without a comprehensive consideration of inter-related aspects that determine quality of life, real life chances and opportunities for all.

Planning, simply is about making decisions and taking actions, now or in the very near future, to make sure total future benefits are maximised and / or the overall direct and indirect costs are reduced.

When applied to Land Use, it seeks to consider the allocation, benefits and costs of Town Planning Classes of Use to meet interdependent activities required by individuals, groups, communities and populations within a Local Authority Area or, as in this case, four Local Authorities.

Many of options and considerations within the Black Country Local Plan do not attempt to draw together the interconnected aspects of service provision with the broadest possible set of features arising from the 4 Council’s corporate organisational policies. To do this would be to ensure the best of all futures and quality of life for its stakeholders.

The Plan simply considers Land for Housing but does not consider how to ensure its service or those of the sub-region and neighbouring areas can be better focused with Land Use Planning to enrich the area. For example, Widening Participation and Life Long Learning can be perspectives that bring education, training and learning relationships with economic development and local planning for the benefit of an area.

Local Planning should extend corporate planning, amenities and wrap round services around major new residential build. Briefly, but relevant here is an understanding of Local Plans which depends to some extent on its genesis. It arose out of the knowledge that Land Use Planning was linked to sociological, economic and technological change. There was a clear link between Economic Development and Planning. These grew out of a disaffected population pressure to ensure that the public ought to participate in the process - as there was disenchantment with planning generally. Development control had been a success when it avoided development in the wrong places and when better results were achieved than would otherwise be the case. There was in many cases a lack of correspondence between the Development Control and Development Planning.

Object

Representation ID: 23572

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.
The Black Country Plan 2039 policy on Climate Change is inadequate and falls within other objections about lack of innovation and total reliance on sustained growth of existing models of production, wealth generation and income generation. Alternatives don’t have to be absolutely alternative than present ones but, in many instances, just require a bit more creativity and imagination from policy makers and employers.

Applying the right discretion to the Black Country Local Plan and Local Planning process can ensure that the pioneering and guiding principles are adhered to and this ought to be the genesis of an Option that takes proper account of:

1.Exercise Free at the point of participation.
Quality of Life especially in relation to Health Improvement and declining provision of Health Care and Treatment. In essence, wise decisions and actions should result in more people exercising and undertaking mental exercises to reduce mental ill health. Exercises such as walking in Green Spaces provides such overall health benefits which are free at the point of participation. More so than in richer areas where residents have the residual income to purchase subscriptions, poor folk have difficulty with ensuring capacity to buy and rely on free at point of participation facilities.

2.Life choice changes following Covid 19The pandemic and consequential lock downs has informed many of the different life choices available. None of these are considered in the assumptions generated in Housing Demand forecasts. Spending more time and working at home has highlighted the dis-benefits of daily commutes. It has also raised the question of a life well lived which need not be premised on full time work and constant consumptions.

3.The Care of the Planet and Protection of Green Belt paradigm In less than a decade the realisation that the Planet needs to be protected from polluting industries and unthinking exploitation, this is coupled with a need to safe important clusters of flora and fauna. Natures Carbon Sinks must be sustained. Fundamentally, investors and developers should not be able to make income or wealth destroying the planet or a locality. (Policy CC1)

4.Dramatic Weather Patterns and Flooding Few could dispute in Britain, Europe and the World dramatic changes in weather patterns have resulted in Floods which the consequential economic, social and physical damages and costs. It is beyond stupid to develop on sites where the risks of Flooding on the site and adjacent areas is probable or already demonstrated. The Seven Cornfields site, for instance, has suffered from changes in the water layers and there has been frequent flooding of the Penn Golf Club site. This problem will in every likelihood of greater flooding and damage on the Golf course if the Seven Cornfields site is developed. Policy CC1

5.Fungal diversification
Increasingly, scientists are realising that the microscopic action of fungi are important in maintaining a viable ecosystem. These takes a long period to develop and cannot easily be built up once lost. Many Green Belt and important green field sites are hosts to a very diverse biosphere of fungal networks that are important to above ground plant life. Policy CC1

6.Pollution
Air pollution increases with development and traffic. Some but not all air borne pollutants are reduced where large green tracks exists. Put another way, a fully developed and built area with
stagnant air leads to respiratory problems. Policy CC1

7.Business Growth does not always require extra buildings
(In reality, it is people and their activities - not buildings and physical infrastructure - which release and realise creativity and productive potential that then creates income and wealth. Relationships between individuals, groups and communities create income and wealth. Traditional economics and that contained in the Local Plan considered an old formulae which is entrepreneur plus land, labour and capital creates wealth. A brief consideration of some of the largest businesses to date with phenomenal growth, these demonstrate Land is not so critical. Consider Facebook, Bit Coin, Uber, Amazon and Google. Policy CC1

Object

Representation ID: 23573

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.

The Seven Cornfields site comes in the highest of five categories of Green Belt in the South Staffordshire Green Belt survey – loss would be of ‘very high harm’ to the Green Belt - and in the higher of two categories of Green Belt in the Greater Birmingham Housing Market Area (GBHMA) survey – ‘principle contribution’ - but much of the wedge further out towards Wombourne is categorised in the GBHMA survey in the lower ‘supporting contribution’ and the overall area west of Wolverhampton is one of the areas where it thought that ‘proportionate dispersal’ (small developments) might be appropriate. It is, however, much worse north of the Black Country, where two more proportional dispersal search areas, a ‘development area with an employment focus’, two ‘urban extensions’ and two possible ‘new settlements’ are postulated!
The Seven Cornfields are a microcosm, at present there are patches of woodland surrounded by arable fields, there are, however, wildlife corridors, hedgerows and footpaths where wildlife can move round at night passing unseen down these trails, so the woodland patches are not isolated one from the other. The wedge as a whole allows this connectivity to extend to the open countryside, thus physically linking large areas of Wolverhampton (and Dudley) with rural South Staffordshire.

The ecosystem has developed over centuries but has been able to adapt to minor intrusions of humankind.

If houses are built on all of the Seven Cornfields, hedgerows cleared and the Penn Brook banks manicured and landscaped for the residents of the new estate then these vulnerable corridors will disappear. The wildlife of the woodlands will vanish. Anthropogenic species like foxes will persist but bats, xxxxxx and butterflies and perhaps the birds of prey will be lost for this and future generations.

The road system around the Seven Cornfields site is congested and insufficient for any additional traffic. Access points to the site will become pinch points. At peak times all the housing estate’s feeder roads onto main highways are already gridlocked.

The roads from Penn, Ettingshall Park, Northway and Goldthorn estates towards Wolverhampton and Birmingham are congested and at capacity. Wolverhampton and Dudley residents will bear the brunt of the traffic increase.

The development of houses will place a huge strain on the infrastructure of the Goldthorn Park, Northway, Ettingshall Park and Penn estates which are adjoining areas to the Green Belt under threat.

THE STAFFORDSHIRE BIODIVERSITY ACTION PLAN

The Staffordshire Biodiversity Action Plan (SBAP) to which South Staffordshire Council are joint partners with other organisations, has been in place since 1998 in order to co-ordinate conservation efforts to deliver the UK Biodiversity Action Plan.

Several pairs of Skylark breed on the rough grassland at Penwood Farm (The Seven Cornfields) and this species has its own Action Plan in the SBAP.
......
4.Dramatic Weather Patterns and Flooding Few could dispute in Britain, Europe and the World dramatic changes in weather patterns have resulted in Floods which the consequential economic, social and physical damages and costs. It is beyond stupid to develop on sites where the risks of Flooding on the site and adjacent areas is probable or already demonstrated. The Seven Cornfields site, for instance, has suffered from changes in the water layers and there has been frequent flooding of the Penn Golf Club site. This problem will in every likelihood of greater flooding and damage on the Golf course if the Seven Cornfields site is developed. Policy CC1
....
14. Carbon Sink
The Seven Cornfields provide a carbon sink for Wolverhampton. The importance of this asset to address air pollution and store atoms like carbon cannot be overestimated. It is fundamental to survival on this planet and locally that carbon is captured and stored.
....
The Save the Seven Cornfields Campaign Group do not consider the loss of the Seven Cornfields and other Green Belt sites this is a price worth paying for additional houses. Especially when the forecasting model is questionable and based on assumptions from a economic and social world that was so different prior to Covid 19 than after its emergence.


Here a list of planning reasons behind the objections to development on the Seven Cornfields:
Affordable Housing Mix

The mix of much needed affordable social housing provided is unclear and cannot be guaranteed.

Insufficient local infrastructure

Transport and Traffic Congestion - too much extra housing around the borders of Wolverhampton and Dudley will lead to further pollution and congestion on busy roads.

The road system around Seven Cornfields site is congested and insufficient for any additional traffic. At peak times all the estates feeder roads onto main roads are already gridlocked.

The roads from Penn, Ettingshall Park, Northway and Goldthorn estates towards Wolverhampton and Birmingham are congested and at capacity. Wolverhampton and Dudley residents will bear the brunt of the traffic increase.

The development of thousands of houses will place a huge strain on the infrastructure of the Goldthorn Park, Northway, Ettingshall Park and Penn estates which are adjoining areas to the Green Belt.

No Accident and Emergency facilities exist in the South Staffordshire. Additional pressure will be placed on Russells Hall Hospital in Dudley or New Cross Wolverhampton Hospitals. Both hospitals are at capacity.

Primary and Secondary Schooling provision will be exhausted.

The development of the Wolverhampton part of the Seven Cornfields will make it easy of a developer or developers to build on the South Staffs part of the site. And Vice Versa. There are infrastructure issues which revolve around Policing, Fire Service coverage and Ambulance callouts. Is South Staffordshire likely to increase funding of policing and Fire Coverage at Wombourne? Ambulances would have to respond from New Cross and Russells Hall Hospitals.

Health and Well Being will be affected badly because of the further strain on GP surgeries, hospitals and dental services

There will be a loss of spare service capacity, for example, waste disposal

Environmental issues

The proposed developments are over-bearing, out-of-scale and out of character in terms of appearance compared with existing development in the vicinity

Increasing hazards and dangers on the roads will follow excess road traffic, there will be a decline in road safety, an increase in accident hot spots, increased noise, floods, fire risks from local warming

Negative Environmental Impact across the area with a loss of wildlife, biodiversity, air quality, open spaces,

Scale of developments would affect the water table and massively increase the extent and duration of flooding, for instance at Penn Golf Course

Unacceptably high density / over-development of the Penn Wood or Seven Cornfields site.

Adverse effects on residential amenity of adjoining estates and neighbours, by reason of -among other factors - noise*, disturbance*, overlooking, loss of privacy, overshadowing, etc. [ note noise or disturbance arising from the actual execution of the works, which will have to be taken into account, in relation to conditions that may be imposed on the planning permission, dealing with hours and methods of working, etc. during the development around sites where vulnerable people are present - Sedgley Blind Institute]

Quality of life of existing residents will suffer.

Loss of Green Belt will result in urban sprawl, the merging of towns and housing estates

Linked directly to the increase in traffic and the loss of green belt land is the deterioration of environmental factors such as air quality.

Penn, Goldthorn, Blakenhall, Ettingshall Park and Northway estates suffer from stationary traffic during commuting hours, as a result the level of air pollution from vehicle fumes is excessive. An additional 1000s of vehicles would increase the likelihood of respiratory illness like Asthma.

Increased associated vehicle noise levels is inevitable together with accident rates associated with the increase in vehicle numbers.

Public transport would need to be reviewed and would in all likelihood require increased investment

Loss of recreation, play and open spaces especially important for people with mental health problems

Access to the rail infrastructure is distant and prohibitive but Option A has the right level of infrastructure in play.

Visual impact of the development making area unattractive to inward investment.

Effect of the development on the character of the neighbourhood will be detrimental.

Loss of existing views from neighbouring properties and estates would adversely affect the residential amenity of neighbouring owners

The development would adversely affect highway safety or the convenience of road users.
.
Green belt destruction.

Development of green belt land will negatively contribute to climate change issues in every case.

Loss of enjoyment, discovery and exploration,

Loss of family, exercise and health benefits of fields for walkers, dog-walkers, naturalists

Areas proposed for development clearly on established green belt are close to ancient woodlands, large parts of the established eco systems would be destroyed together with the associated wildlife

Mental Health problems are on the rise and everyone needs quiet places to relax and meditate on established and well used public open space accessible without the use of vehicles. Local residents have a place to relax using a network of very well established footpaths and highways through historic agricultural land.

Loss of habitat and wildlife from the area would be irreversible.

The new roads for homes and associated driveways would contribute to flooding and effect the natural balance of the area.

Massive loss of Green Belt, footpaths and open aspect of the neighbourhood (‘green belt grabbing’ on an unnecessary and industrial scale )


10. THE SEVEN CORNFIELDS CAMPAIGN GROUP
OPPOSES HOUSING DEVELOPMENT ON THE GREEN BELT AND THE SEVEN CORNFIELDS AND OBJECTS TO ANY LOSS OF GREEN BELT SITES IN OR AROUND WOLVERHAMPTON OR DUDLEY


There should be a basic opposition to dismantling any part of the Green Belt - it is a simple concept which has served Britain well in comparison with other countries in protecting our countryside. Indeed, it might be said that rural - and urban in leafy suburbs - tourism has been a success because of Green Belt status sustained in large visitor centres.

The purposes of the Green Belt include the protection against encroachment from and between adjoining major urban areas. They prevent regions, counties, sub-regions like the Black Country and districts swallowing their green boundaries and then as if by accident become an urban sprawl. They act as a barrier to the coalescence of rural and urban settlements in order to retain the attractive distinctive character of each rural or urban setting of settlements. The original land use planning developed with titles like the Town and Country Act - this showed the importance of the distinction.

Housing development on key Green Belt sites adjacent to housing estates cannot be allowed because infrastructure is necessary and must be sufficient to serve the demands generated.

Additional infrastructure and upgrading will have to take place prior to development of housing. Roads will have to extended possibly widened and traffic management systems upgraded to control flows productively and effectively. Their critical educational issue will be the provision of a secondary school. This will need to be built and the schools made operational prior to the housing development completion.

This in turn will mean that those living on estates adjacent to the site will suffer from:
Loss of clean air
Serious local flooding due to lost natural water drainage
Shortage of local school places as competition increases will be dramatic
Class sizes will in turn increase poor education attainment
Hospital patient face longer waiting lists
Waiting time for doctor appointments will increase
The extent of traffic jams and grid lock on local feeder roads will increase
There will be less recreational space for walks or play
There will be a loss of local wildlife and plants

The Black Country Plan 2039 needs to take account of the Green Belt Review published by LUCs, which seek to assess parcels of land within the Green Belt against the five tests set out in Paragraph 134 of the National Planning Policy Framework (NPPF):
1. to check the unrestricted sprawl of large built-up areas.
2. to prevent neighbouring towns merging into one another.
3. to assist in safeguarding the countryside from encroachment.
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.


11. THE SEVEN CORNFIELDS CAMPAIGN GROUP
OPPOSES HOUSING DEVELOPMENT ON PENNWOOD FARM AND THE SEVEN CORNFIELDS SITE


The Seven Cornfields site comes in the highest of five categories of Green Belt in the South Staffordshire Green Belt survey – loss would be of ‘very high harm’ to the Green Belt - and in the higher of two categories of Green Belt in the Greater Birmingham Housing Market Area (GBHMA) survey – ‘principle contribution’ - but much of the wedge further out towards Wombourne is categorised in the GBHMA survey in the lower ‘supporting contribution’ and the overall area west of Wolverhampton is one of the areas where it thought that ‘proportionate dispersal’ (small developments) might be appropriate. It is however much worse north of the Black Country, where two more proportional dispersal search areas, a ‘development area with an employment focus’, two ‘urban extensions’ and two possible ‘new settlements’ are postulated!

The Seven Cornfields are a microcosm, at present there are patches of woodland surrounded by arable fields, there are, however, wildlife corridors, hedgerows and footpaths where wildlife can move round at night passing unseen down these trails, so the woodland patches are not isolated one from the other. The ecosystem has developed over centuries but has adapted to minor intrusions of humankind. If houses are built on all of the Seven Cornfields, hedgerows cleared and the Penn Brook banks manicured and landscaped for the residents of the new estate then these vulnerable corridors will disappear. The wildlife of the woodlands will vanish. Anthropogenic species like foxes will persist but bats, xxxxxs and butterflies and perhaps the birds of prey will be lost for this and future generations.

Pennwood Farm is an important wildlife corridor and represents one of the more ecologically rich and varied mosaics of habitats in the wider farming community, where the wildflowers on adjoining farms have been destroyed by spraying, and these farms have been virtually sterilised by over-intensification and are much less rich in invertebrates and the birds that breed and feed on them.

The farm has important hedgerows for breeding Yellowhammers and the rough grassland supports several pairs of Skylark. Both species are Red Listed by the Royal Society for the Protection of Birds as species of National Conservation Concern.
The Horse paddocks and associated bridleways and rough ground support good populations of nectar sources which in turn support 22 species of butterflies, making it a 'hot spot' in South Staffordshire.
Ancient woodland and hedgerows around the farm are important breeding areas for a variety of birds and 72 species have been recorded on the farm in recent years.

The Staffordshire Biodiversity Action Plan

The Staffordshire Biodiversity Action Plan (SBAP) to which South Staffordshire Council are joint partners with other organisations, has been in place since 1998 in order to co-ordinate conservation efforts to deliver the UK Biodiversity Action Plan.

Several pairs of Skylark breed on the rough grassland at Penwood Farm (The Seven Cornfields) and this species has its own Action Plan in the SBAP.

See Appendix 2. Extracts from Staffordshire County Council Protected Species Advice Document
which includes planning advice and guidance on biodiversity conservation.

Detail of Butterflies population on the Seven Cornfields can be found in Appendix 3. Butterflies recorded annually at the Seven Cornfields, Pennwood Farm.

Flooding

Currently, Penn Golf Course suffers from frequent flooding and there are concerns that the water table will be affected to bring other areas into zones of high risk of flooding if development of housing proceeds on the Green Belt without an assessment of the likelihood of flooding in a particular area so that development needs and mitigation measures should be carefully considered.

There is an important water course on the Seven Cornfields known as Penn Brook, this was originally called Lloyd brook, it flows westwards across the common from its source on Colton Hills. When the brook leaves the common it becomes the River Wom (after which Wombourne is named).

Penn Brook is one of the key tributaries of Smestow Brook. It falls 90 metres (300 feet) in 8 kilometres (5 miles). The Penn Brook rises in the natural amphitheatre created by the heights of Goldthorn Park, the Northway and Colton Hills.

Development of the sloping site of the Seven Cornfields is likely to cause additional flooding problems especially as annual rainfall appears to be increasing.

Significant transport investment is needed to support options.

The thinking on growth is wanting and depends too heavily on extinguishing Green Belt status.

Economic Development perspectives are weak within the policies and the proper benefits of a Local Plan are lost as no attempt has been made to link the changed technological, sociological and economic landscape into a cogent framework for the future. More work needs to be done.

There is a need for additional infrastructure with an extra range of alternatives to support the requirements of integrated transport to effectively and efficiently accommodate such excessive housing growth as promoted.


Appendix 1

KEY POINTS MADE TO SOUTH STAFFS
AN EXTRACT FROM SUBMISSION

That South Staffordshire expects their distinctive character to be maintained whilst destroying others is a matter that needs to be considered fully. What holds as a valid principle for guiding Local Plans must have an equivalence when used as an objection to a proposal.

Whilst the South Staffordshire Local Plan’s movement for growth does not obliterate high proportion or significant high percentages of South Staffordshire’s total Green Belt land ( ‘Much of South Staffordshire (80%) lies within the West Midlands Green Belt (32,089 hectares)”). It does affect and obliterate important proportions or a high percentage of the very limited Green Belt available in Dudley and Wolverhampton that creates a distinctive character of Green around urban local settlements in Dudley and Wolverhampton.

A loss for Staffordshire of Green Belt sites has very minimal effects on the local Shire character because South Staffs has so much Green Belt.

The erosion of Green Belt in South Staffordshire by our boundaries, however, has a disproportional negative affect on the distinctive character and quality of life of neighbourhoods in Wolverhampton and Dudley.

At the end of the Forward,

“South Staffordshire has historically proven to be an attractive location for people to live. It has been a destination for people moving from the West Midlands major urban area and other nearby towns. Pressure for housing growth over and above the needs arising purely from within the district has continued. South Staffordshire’

Then in the Executive Summary of the Housing Strategy,

“Our preferred approach, Option G, is very much Member led. We believe Option G will meet our housing numbers, make a contribution (under our legal Duty to Cooperate) to the wider unmet housing need and also take account of the impact of development on current infrastructure and what opportunities there are for new and improved infrastructure. This approach will, however, lead to Green Belt release and this is something that has been very carefully considered in formulating the options. We know there are very difficult decisions to be made in providing new homes and protecting the Green Belt.”

A forensic examination of this statement and its implications reveals an underlying ethical, moral, professional and political intent. This is inherent and pervasive within the documents which support the Housing Strategy and Local Plan, it reveals a prevailing and unwanted sympathy.

The Preferred Option and majority of other Housing Options that allow a Housing Target build of 8,000 as presented or captured in the South Staffordshire Housing Strategy and Local Plan can only be possibly categorised in harsh terms as parasitism, imperialism and colonialism. Although harsh, a quick turn to the Oxford Dictionary of English allows a judgement and check:

a) “Parasitism ‘habitually relies on or exploits others and gives nothing in return’.”
b) “Imperialism ‘a policy of extending a country’s [local authority’s] power and influence through colonization, use of military force, or other means’ ”
b) “Colonialism ‘the policy or practice of acquiring full or partial political control over another country [local authority area], occupying it with settlers, and exploiting it economically’ ”

Globally, policies of that nature were detrimental to indigenous populations and ecosystems and disregarded the care, needs and demands of those existing populations, residential communities, people, groups and individuals. Applied in more local practices within the Local Plan, they are equally unpalatable since the strategy seeks to impose a leadership or dominance by one state - South Staffordshire Council - or social group (Elected members as this is after all a member-led strategy) over others, the Wolverhampton and Dudley communities adversely affected at the boundaries by development on the Green Belt. It relies on exploiting others and gives nothing in return.

It is also not clear why in Plan B, urban extensions are biased towards west of the Black Country. There is a key question that follows this bias and it needs to be answered: Why was it found necessary for urban extensions to be biased towards west of the Black Country in this particular plan?

There is as much, or more, Green Belt land of less than high or very high harm in the north and more land beyond the Green Belt but still in perfect reach of the whole conurbation via the A5, M6 and M54. This is much less true of Green Belt west of the Black Country, however close in proximity to the conurbation. A requirement for development to be in ‘close proximity’ to the conurbation would inevitably impinge on high harm Green Belt.

It’s more about Income and Wealth rather than Planning and Housing Considerations

South Staffordshire Council’s Local Plan highlights land for development as requirement of central Government however, the extra 4,000 above target largely is made largely on economic basis to increase their income collected by the Council.

Housing development claims on South Staffordshire Council’s infrastructure investment would be at a very low relative level with additional residents being serviced by neighbouring boroughs, whilst allowing a steady revenue stream to South Staffordshire Council through the chargeable Council tax for higher band "more expensive" properties. The costs of infrastructure would fall unfairly on the adjoining areas of Wolverhampton and Dudley who would not receive the Council Tax receipts. Imperial, parasitic and/ or colonial what words best describe this relationship?

South Staffordshire is rightly proud that it is prosperous with the proportion of those employed within the top three professional and managerial sectors being above the national average. Many if not most of these are people employed outside the area who bring the income from elsewhere into South Staffs to create a wealth base there.

Advantages and Disadvantages of the Different Options in South Staffordshire Housing Strategy

The Save the Seven Cornfields Campaign Group has fully considered the various Housing Options which are presented in summary form in the Appendices. There was much discussion of the advantages and disadvantage of these but reason, logic, planning considerations and the common purpose of community interests lead to a series of objections, endorsements and comments which are provided in much greater detail below in the following pages.

Option B includes development of Green Belt and achieves the full plan of 9,130 dwellings between 2018 and 2037, including the unnecessary full contribution of up to 4,000 dwellings to the GBHMA, but avoids allocating growth to Green Belt areas of high or very high harm. The Save the Seven Cornfields Campaign Group acknowledges this is the second best (after Option A) in terms of protecting the Green Belt.
.

Appendix 2.
Extracts from Staffordshire County Council Protected Species Advice Document
Skylark
A national BAP target species with a costed action plan and a Staffordshire BAP target species. Ground nesting in grassland or low vegetation including crops. Skylarks require open areas with an absence of features such as trees and hedgerows that act as perches for potential predators. They will not nest in confined areas. Spring planting is key where arable land is used for nesting.
Yellowhammer
UK BAP species of conservation concern and Staffordshire BAP target species. Nearly always nests on the ground, if not, always close to it hidden among grass and herbage, typically against a bank or at the base of a hedge, small tree or bush. The yellowhammer begins laying from April to early August and frequently produces two and sometimes three broods, each taking up to 28 days to fledge and therefore they have usually cleared the nest site by mid-September. skylark begins laying between late March and late April and may produce four broods, each taking between 21 and 30 days to fledge and therefore they have usually cleared the nest site by August.

Planning Guidance and Protected Species Planning Policy Statement 9 Biodiversity and Geological Conservation includes a set of Key Principles that should be applied to all planning decisions. These include: • Planning decisions should be based upon up-to-date information; • Planning decisions should give due weight to protected species and to biodiversity interests within the wider environment; • Planning decisions should aim to maintain biodiversity interests and to enhance, restore or add to these; • The aim of planning decisions should be to prevent harm to biodiversity interests. Where significant harm may ensue from planning consent, planning authorities should be satisfied that the development cannot be alternatively located. Should alternatives not be available, adequate mitigation must be put in place before planning permission is granted, or, if mitigation is not feasible, appropriate compensation measures must be included in development proposals. • Planning consent should be refused if harm cannot be prevented and adequate mitigation or compensation cannot be secured.

In addition to legally protected species, PPS9 (paragraph 16) advises that local authorities should ensure that species of conservation priority and their habitat are protected from the adverse effects of development. A list of these species was drawn up in response to section 74 of the Countryside and Rights of Way Act 2000 and can be found on the Defra website. This list is also referenced by sections 40 and 41 of the Natural Environment & Rural Communities Act 2006 (see s.2.5 and Appendix 1).

Guidance on the application of legislation related to planning and nature conservation is found in Government Circular: Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System (ODPM Circular 06/2005, Defra Circular 01/2005) which complements PPS9. Paragraph 98 advises that the presence of a protected species is a material consideration in considering planning proposals. Paragraph 116 advises that the presence of a European protected species should be given due weight in making planning decisions and may justify refusal of planning consent. Paragraph 99 states that the presence or otherwise of a protected species, and the extent to which it might be affected by a proposed development, must be established prior to the granting of permission, otherwise all material considerations may not have been addressed.

This means, as the Circular advises, that ecological surveys should be carried out prior to consent and should not be conditioned except in exceptional circumstances. Measures for species protection should be incorporated into planning proposals prior to consent and be implemented through conditions and/or planning agreements. While the presence of a protected species does not need to be already recorded, survey should only be required where there is a reasonable likelihood of the species being affected by the development. It should be noted that planning consent does 11 not provide derogation from the requirements of protected species legislation which must still be met, including through the acquisition of licences where relevant.
APPENDIX 3.

Butterflies recorded annually at The Seven Cornfields, Pennwood Farm, Wolverhampton
(compiled from personal records by David Jackson on behalf of the West Midlands Branch of Butterfly Conservation)

1. Essex Skipper – Fairly common along grassy strips and uncut field margins.
2. Small Skipper- ditto as with the above-mentioned species.
3. Large Skipper- Several usually encountered in uncut field edges and on Bramble patches.
4. Orange Tip – several seen each Spring, along banks and in damper patches where Garlic Mustard and Cuckooflower, its larval stage food-plants grow.
5. Large White- Not as common as it was 4-5 years ago but still frequently seen.
6. Small White – common in the planted fields.
7. Green -veined White - as with Orange Tip requires damper patches of farmland where Garlic Mustard and Cuckooflowers grow. Up to a dozen are recorded each season.
8. Brimstone- scarce.
9. Speckled Wood – common along hedgerows and by edges of shady woodland.
10. Ringlet – common along uncut hedgerow bases, in longer grass.
11. Meadow Brown- common in set aside and longer grass in uncut paddocks.
12. Gatekeeper- Several usually seen basking by gates on Bramble and Bracken.
13. Marbled White - occasional visitors stray onto the farm from a strong colony on Sedgley Beacon.
14. Red Admiral – singles frequently seen on the farm near to Common Nettles.
15. Painted Lady – on a good ‘Painted Lady Year’ several can be encountered on the farm.

1. Peacock- singles frequently seen on the farm usually near Nettle beds which its larval stage requires to breed.
2. Small Tortoiseshell – up to a dozen encountered each year on the farm usually near Nettles used by its larva to feed.
3. Comma – ditto as per the two above-mentioned species.
4. Small Copper- scarce but recorded annually near Common Sorrel its larval stage food-plant.
5. Purple Hairstreak- usually seen high up in the woodland Oaks in small discrete colonies.
6. Holly Blue- several seen each year in and around Holly bushes and Ivy covered trees.
7. Common Blue - over the past two years there has been a resurgence from six or seven individuals seen per year, now up to two dozen recorded on a good day in the uncut meadows and horse paddocks, where its larval stage main food-plants Common Birds foot Trefoil and White Clover grow.