Draft Black Country Plan

Comment

Representation ID: 16550

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

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

Comment

Representation ID: 16551

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Housing: (BCP pg. 87-119):
Greenhouse gas emissions contribute to global temperature rises and we already
know we must reduce them to avoid 1.5°C of warming. 42% of greenhouse gas
emissions in Dudley Borough come from housing.
Sustainable homes are vital to protect the most vulnerable people from climate
breakdown. In Dudley Borough only 31% of homes are well insulated and
13% of households are in fuel poverty. Poor insulation contributes to this
problem. The Council should develop a heating and energy efficient strategy by 2025
for the borough. Action plans must include improved regulations regarding new
builds in the private and rented sectors as well as schemes to carry out retro fit in
both council stock and private homes. Planning permission should require all homes
built in Dudley Borough to be extremely energy efficient, using the Passivhaus
standards.
• We want Dudley MBC to ensure 100% of homes are well insulated to
minimum EPC C level, eradicate fuel poverty as fast as possible.
• Retro fitting and upgrading the insulation of 9,513 homes per annum
within the Dudley area will ensure all homes are properly insulated by
2030, lifting as many people as possible out of fuel poverty.
• Only 22 existing eco heating systems have been fitted in the Borough to date.
Dudley’s official government target is 25,383 but the FoE Target for Dudley
is to fit 55100 heat pumps by 2030.
The Borough has 64 neighbourhoods with high social flood risk for surface
flooding (Nov. 2019) taking account a range of vulnerability factors.
Trees and green biodiverse community spaces clean up air pollution as well as
mitigating against both flood risk and heat islands in residential or built-up areas
with no green space or shade. All housing developments and refurbishments should
ensure that community green space and tree planting are a priority for all future
development as well as a reduction in the density of houses and roads to reduce
flood risk.
Spatial Strategy and Infra Structure: (BC Plan pg.20 – 70) and Black Country
Centres (BCP pg. 140 – 173)
Economic, housing, leisure and cultural development need to be reviewed holistically
as part of the spatial development strategy. An innovative regeneration of our town
centres should take into account people’s changing work patterns, reduced need for
office space and retail space, working from home, health, well-being, encouraging
people to shop locally, provide educational, leisure and cultural opportunities near to
people’s homes supporting both community and family life.
Friends of the Earth Stourbridge: 11.10.21:
4
Town centre buildings should be re-purposed to provide a mixed economy of use but
building on what is already there rather than demolishing good functioning
businesses. At the time of writing a row of thriving local businesses are proposed for
demolition at no. DUH008 14 Colley Gate for housing development; whilst a row of
abandoned buildings are left standing next to the proposed development. This
appears to make little sense and a waste of resources and good businesses.
We would like to see town centres including Tiers 1,2 and 3 with more pedestrian
and cycle friendly. For example, Stourbridge High Street is currently congested with
traffic and has poor air quality from the High Street and also the Ring Road. We
would like to see the High Street pedestrianised with limited traffic flow for deliveries
and greening of the streets as in other of Dudley’s towns. We would like to see the
ring road have better traffic calming measures and more accessible crossings. The
subways are dingy and dangerous after dark and should be removed.
Pedestrianisation and greening should be extended further in the other town centres
and greening of the streets with trees and planters to increase bio-diversity as well
as shade. This will improve local environments for community interaction, increased
health well-being in open social green spaces.
On residential streets we would also like to see more limits on traffic flow for
example the Street Play initiative uses existing council powers to close a street to
traffic for several hours, allowing children to play together in the street. This is a
brilliant initiative for building community and is particularly beneficial for
disadvantaged communities with no gardens and limited access to parks. Play
streets today could be accompanied by an initiative to green the street with trees
and planters, and some of the closures could even be made permanent.
As well as supporting retro-fit for people working from home the Council could
encourage the development of shared working spaces or hubs, in the town centres
of Tiers 1, 2 and 3. This would enable people to use of good quality, accessible and
well-equipped spaces close to home as well as to meeting spaces for formal and
informal interaction. Free wi-fi should be a feature. If these spaces were no more
than 10 minutes walking distance of people’s home then it may well reduce
commuter traffic and improve air quality. Libraries provide some of these facilities
but there are not enough in the borough.
Creating good quality jobs near to where people live will also ease road congestion
in the am/pm commute and improve air quality. Town centre development in Tiers
1,2 and 3 should be included in this and developments made alongside leisure,
cultural, social and retail facilities (not just food retail) included. Green space and
green corridors should also be a feature of exciting and innovative plans so that no
urban area is too far in walking distance from open green space.

Comment

Representation ID: 16552

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Housing: (BCP pg. 87-119):
Greenhouse gas emissions contribute to global temperature rises and we already
know we must reduce them to avoid 1.5°C of warming. 42% of greenhouse gas
emissions in Dudley Borough come from housing.
Sustainable homes are vital to protect the most vulnerable people from climate
breakdown. In Dudley Borough only 31% of homes are well insulated and
13% of households are in fuel poverty. Poor insulation contributes to this
problem. The Council should develop a heating and energy efficient strategy by 2025
for the borough. Action plans must include improved regulations regarding new
builds in the private and rented sectors as well as schemes to carry out retro fit in
both council stock and private homes. Planning permission should require all homes
built in Dudley Borough to be extremely energy efficient, using the Passivhaus
standards.
• We want Dudley MBC to ensure 100% of homes are well insulated to
minimum EPC C level, eradicate fuel poverty as fast as possible.
• Retro fitting and upgrading the insulation of 9,513 homes per annum
within the Dudley area will ensure all homes are properly insulated by
2030, lifting as many people as possible out of fuel poverty.
• Only 22 existing eco heating systems have been fitted in the Borough to date.
Dudley’s official government target is 25,383 but the FoE Target for Dudley
is to fit 55100 heat pumps by 2030.
The Borough has 64 neighbourhoods with high social flood risk for surface
flooding (Nov. 2019) taking account a range of vulnerability factors.
Trees and green biodiverse community spaces clean up air pollution as well as
mitigating against both flood risk and heat islands in residential or built-up areas
with no green space or shade. All housing developments and refurbishments should
ensure that community green space and tree planting are a priority for all future
development as well as a reduction in the density of houses and roads to reduce
flood risk.
Spatial Strategy and Infra Structure: (BC Plan pg.20 – 70) and Black Country
Centres (BCP pg. 140 – 173)
Economic, housing, leisure and cultural development need to be reviewed holistically
as part of the spatial development strategy. An innovative regeneration of our town
centres should take into account people’s changing work patterns, reduced need for
office space and retail space, working from home, health, well-being, encouraging
people to shop locally, provide educational, leisure and cultural opportunities near to
people’s homes supporting both community and family life.
Friends of the Earth Stourbridge: 11.10.21:
4
Town centre buildings should be re-purposed to provide a mixed economy of use but
building on what is already there rather than demolishing good functioning
businesses. At the time of writing a row of thriving local businesses are proposed for
demolition at no. DUH008 14 Colley Gate for housing development; whilst a row of
abandoned buildings are left standing next to the proposed development. This
appears to make little sense and a waste of resources and good businesses.
We would like to see town centres including Tiers 1,2 and 3 with more pedestrian
and cycle friendly. For example, Stourbridge High Street is currently congested with
traffic and has poor air quality from the High Street and also the Ring Road. We
would like to see the High Street pedestrianised with limited traffic flow for deliveries
and greening of the streets as in other of Dudley’s towns. We would like to see the
ring road have better traffic calming measures and more accessible crossings. The
subways are dingy and dangerous after dark and should be removed.
Pedestrianisation and greening should be extended further in the other town centres
and greening of the streets with trees and planters to increase bio-diversity as well
as shade. This will improve local environments for community interaction, increased
health well-being in open social green spaces.
On residential streets we would also like to see more limits on traffic flow for
example the Street Play initiative uses existing council powers to close a street to
traffic for several hours, allowing children to play together in the street. This is a
brilliant initiative for building community and is particularly beneficial for
disadvantaged communities with no gardens and limited access to parks. Play
streets today could be accompanied by an initiative to green the street with trees
and planters, and some of the closures could even be made permanent.
As well as supporting retro-fit for people working from home the Council could
encourage the development of shared working spaces or hubs, in the town centres
of Tiers 1, 2 and 3. This would enable people to use of good quality, accessible and
well-equipped spaces close to home as well as to meeting spaces for formal and
informal interaction. Free wi-fi should be a feature. If these spaces were no more
than 10 minutes walking distance of people’s home then it may well reduce
commuter traffic and improve air quality. Libraries provide some of these facilities
but there are not enough in the borough.
Creating good quality jobs near to where people live will also ease road congestion
in the am/pm commute and improve air quality. Town centre development in Tiers
1,2 and 3 should be included in this and developments made alongside leisure,
cultural, social and retail facilities (not just food retail) included. Green space and
green corridors should also be a feature of exciting and innovative plans so that no
urban area is too far in walking distance from open green space.

Comment

Representation ID: 16553

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Economy: (BC Plan pg. 120-139)
We would like to see the following Green Jobs targets included in Dudley’s
economic development plans:
• 1770 green apprenticeships could be created in Dudley by 2023 so young
people can get the skills to work in the green economy.
• 2599 green jobs could be created in Dudley by 2030, according to the Local
Government Association.
• Potential jobs by industry: 127 in low-carbon services. 902 in low-carbon
heating. 826 in energy efficiency. 169 in alternative fuels. 393 in lowemissions vehicles. 182 in low-carbon electricity.

Comment

Representation ID: 16554

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Energy / Power: In Dudley Borough 27% of greenhouse gas emissions are
industrial and commercial. Dudley has 23Gwh of renewable energy.
We would like to see Dudley MBC reduce greenhouse gas emissions by 13% per
year to achieve a zero target by 2030. We suggest some of the following measures
would support this.
• Support the development of renewable energy and energy storage. Aim to
install on every Dudley building with E, W, S roofs, PV solar, with battery
storage, to become mini power stations.
• Switch street lighting to well designed and well directed LED lights for
minimum power consumption.
• Invest in the energy performance of buildings and reduce energy used by
Dudley MBC in its own estate through better insulation, glazing and use of
renewable sources by 2030.
• DMBC to procure only truly renewable electricity by only using suppliers who
purchase both the renewable electricity and its accompanying Renewable
Energy Guarantees of Origin (REGO) certificate directly from its generators.
• Dudley MBC should enable and support the growth and use of green energy,
Our FoE target for Dudley is 212 Gwh by 2030.
• Dudley MBC should divest from all fossil fuels and instead invest in renewable
energy projects, ensure energy is not wasted and prevent the development of
new fossil fuel extraction.

Comment

Representation ID: 16555

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Transport: (BC Plan pg. 174 – 200)
In Dudley 31% of greenhouse gas emissions are from transport. 41% of
the population use public transport, walking or cycling for daily travel.
There are currently only 34 electric vehicle charging points in the borough.
We want Dudley MBC to support the reduction of air pollution to meet World Health
Organisation levels, match European best practice in the use of buses cycling and
walking and ensure all vehicles are zero emission. Dudley MBC should commit more
Friends of the Earth Stourbridge: 11.10.21:
6
investment in the walking and cycling infrastructure to join up routes and provide
extra cycle lanes.
We want to see a 50% increase in people using public transport, walking
and cycling in the Borough. Cycle parks should be strategically placed at bus and
railway stations.
Traffic calming measures should be introduced in all residential areas to slow traffic,
increase public safety and reduce emissions. For example, there are major problems
with traffic at all major arterial road leading to and from Dudley Town centre, on
Stourbridge Ring Road, through Amblecote, Wordsley an Kingswinford, Russells
Hall, Merry Hill, Quarry Bank Brierley Hill, Colley Gate and more. At Oldswinford
Cross, Stourbridge and similar sites there are no proper pedestrian
crossings. Halesowen Road, Netherton is identified among the top 10 most polluted
areas in the West Midlands and currently breaches air quality standards. Dudley
Borough has a major traffic congestion problem which must be addressed
immediately to ensure we can tackle the Climate Emergency and to ensure the
improved health and wellbeing of those who live and work in the Borough.
It is essential that Dudley Council work with West Midlands Transport Authority to
invest in a sustainable public transport network. Routes need to be accessible and
joined up. It has to be easy for people to leave their cars at home. Local bus
services should be fare free and go where people need them at the right times and
there is an incentive to not drive.
This is not just about commuting but also about social justice, health and well-being
too. For example, re-introducing Sunday services from rail and main bus depots to
places like Kinver or Clent so people can access nature and green space when they
have family time together.
We need to encourage parents and children to walk more to and from schools.
Currently many residential areas have poor air quality near schools as parents or
taxis drive children to school and leave engines idling in the street. This cause of this
behaviour is often that they don’t their children are safe to walk or cycle.
Reinstatement of existing rails routes for passengers and freight should be
considered rather than spending money on new metro track which does not even
join up the public transport network to Stourbridge and mainline rail junctions. Key
centres and national rail links need to be included in the transport network for
example the Brierley Hill to Stourbridge Junction rail link. Transport depots with
toilet /washing and refreshment facilities for freight drivers should be located at
suitable supply hubs in the borough and have electric charging points from
renewables installed.
Fleet vehicles such as those used by Dudley MBC should be sustainable and run on
renewable energy by 2030.
The FoE target for the installation of EV charging points in the Borough by
2030 is 1549.

Comment

Representation ID: 16556

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Environmental Transformation and Climate Change: (BC Plan pg. 201-295)
Dudley will be required soon to produce a Local Nature Recovery Strategy as part of
a requirement to meet biodiversity targets. Our Local Plan should aim to reduce
greenhouse gases, restore nature and increase resilience to extreme weather
events.
Dudley MBC should manage the land they own and have control over in a way that
helps nature and increases biodiversity such as managing roadside verges for
wildflowers, planting trees, developing meadows, preserving and increasing
designated nature reserves. The Council has a substantial role in deciding how land
is used in an area, particularly when it comes to the Local Plan. In this way Dudley
can make a significant contribution to nature restoration. The government's
Environment Bill places extra emphasis on the role of the local council in nature's
recovery.
The Local Plan needs to protect all wildlife in the area and ensure its abundance
across all rural, suburban and urban landscapes. This means ensuring that places
like nature reserves are not lost or damaged by development, but also aiming to
increase space for nature outside of designated nature reserves and biodiversity
hotspots. Creating networks of nature corridors for wildlife to move through can help
with this, as can protecting green open spaces and the green belt from
development. More and better access to nature and green spaces also has public
health benefits.
Dudley MBC needs to identify how nature can help mitigate against extreme
weather. For example, flood plains, wetlands and increased tree cover can act as
natural flood defences. Creating green open spaces and planting trees lowers
temperatures and so in built up areas can be effective in mitigating heat islands.
Dudley MBC can also integrate nature restoration into activities like grass cutting and
hedge trimming. Cutting grasses at the right time of year and in the right ways can
help wildflowers and associated wildlife thrive, while bad and untimely grass and
hedge management can set back ideal conditions for nature for years for example
the wildflower meadows currently in preparation at the 3 Fields, near the Roman
Road site in Stourbridge.
Only 7% of Dudley area, including greenbelt, has tree cover but Friends of the Earth
UK have identified an additional 62 hectares of land (1 hectare = a football pitch) in
the Borough which may be suitable for new woodlands. Some of these areas are
extensions of existing woods and green space such as Iverley, near Racecourse
Lane, opposite Norton Covert, Wychbury Hill, Gibbett Lane, Botts Farm, The Clump,
Mount Pleasant and Ridgehill Wood. More information can be found here.
https://takeclimateaction.uk/woodland-opportunity-mapping-england
We urge Dudley MBC to protect all greenbelt land carefully and to fully assess the
biodiversity impact of new development on brownfield sites as well as greenbelt.
Friends of the Earth Stourbridge: 11.10.21:
8
We want Dudley to double tree cover on council-owned land, update local planning
strategies to significantly increase tree cover across the Local Authority area, and
ensure existing trees are properly protected in order to store carbon, support nature,
aid flood protection and deliver mental health benefits.
Dudley MBC should transition to organic weed management on council-owned land,
streets and verges by eliminating the use of herbicides such as glyphosate for weed
management. This will help to increase biodiversity and draw down carbon pollution.
It can provide a significant boost for pollinators and other wildlife to manage parks,
and other green spaces as well as grass verges with nature in mind. Development of
new meadows alongside other designated nature reserves would increase potential
for bio-diversity.
We would like to see Dudley’s Green Care produce a pollinator action plan as part of
their management strategy. They can also influence other land owners including
schools and colleges to manage their grounds for nature. By eliminating the use of
herbicides and pesticides in their parks, playgrounds, verges and green spaces to
protect residents’ health as well as help plant and wildlife.
Dudley MBC has limited green space and it must protect existing local green spaces,
the green belt and locally designated nature sites, and ensure public access to local
authority owned green spaces, including golf courses. Dudley needs new good
quality green spaces in areas which fall short of recommended minimum levels (2
hectares of green space within 5 minutes’ walk), particularly in areas where people
have less access to private gardens.
Dudley Borough has more than 6 neighbourhoods which are identified as deprived of
green space which is essential for physical and mental health. They are:
o Cradley West and the Hayes
o Cradley East
o Stourbridge Town and the Old Quarter
o Brierley Hill
o Kates Hill
o Upper Gornal and Ruiton
o Wordsley and Buckpool
o Dudley Town
o Russells Hall
This is again a matter of social justice. A Friends of the Earth study found that
persons of Black, Asian or minority ethnic (BAME) people are more than twice as
likely as a white person to live in areas in England that are most deprived of green
space. The research also found a correlation between income and green space
rating, although it is not as strong as for ethnicit

Comment

Representation ID: 16557

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Waste: (BC Plan pg. 296 – 331)
Producing and distributing things we buy consumes fossil fuels and contributes to
increased greenhouse gas emissions. What we discard generates more greenhouse
gas emissions by its being transported away and then processed for example by
incineration. It follows therefore that we must reduce our consumption to reduce
harmful emissions by re-using, repairing and repurposing what we already have.
Dudley reuses, recycles and composts only 38% of its household waste.
Some waste disposal is contracted out in the borough and some waste still
goes to landfill.
Our aim is for Dudley Borough to be a zero-waste area by 2030 where all
waste reused or recycled as part of a circular economy approach. The
official government target for Dudley is 68%. Friends of the Earth’s target
is 100%
The Council should Implement food waste recycling by 2023. This will be a national
requirement. Use food waste according to the food waste hierarchy of prevent,
reuse, recycle and ensure non-recyclable biodegradeable waste is used to make
biogas. A local composting scheme would also be effective and useful for green
management.
Our target for Dudley is to cease sending domestic and industrial waste to landfill
either in the UK or abroad by the Council and or it’s contractors by 2025.
We would like to see Dudley MBC promote reduction of waste at source by installing
water taps in public places to reduce single use plastics. The Council should increase
capacity to recycle a wider range of plastics and other materials. Work with
businesses and services to reduce waste at source and take greater responsibility for
recycling. Promote plastic free status for all community and town centres including
single use vending machines in council facilities such as leisure centres.
The Council needs to work more closely with the local community and conservation
groups to achieve ‘clear water’ by removing dumped waste and single use plastics
from watercourses in the borough.