Draft Black Country Plan

Object

Representation ID: 17606

Received: 11/10/2021

Respondent: Member of Parliament

It would be remiss of me to not comment on the consultation process. Whilst it is for the planning inspector to deem whether it has met regulatory requirements, it is very clear there has been no real intent to engage effectively with the local community. A plan of the scale and size of the Black Country Plan required a more detailed and interactive consultation. There is also a need to ensure that a plan for over 15 years of growth is based on reasonable discussion with the community to form those assumptions and not one based on minimum requirements. After all, the community are the subject matters of the needs and wants of the area in terms of housing and infrastructure.
The complexity of the online process is widely known, understood, and acknowledged by the Council itself.

Support

Representation ID: 17612

Received: 11/10/2021

Respondent: Member of Parliament

I also write to welcome the proposed designation of the Corbett Meadow as Local Green Space (Policy
DSA4).
In conjunction with this, I support Policy ENV1 (Nature Conservation and designation of Corbett Meadow as a Site of Local Interest for Nature Conservation); and ENVS (Historic Character and Local Distinctiveness of the Black Country and designation of Corbett Meadow (Dudley) as Area of High Historic Landscape Value)
I support the work of the Corbett Meadow Action Group (CMAG) and fully endorse their submission to this consultation.

Support

Representation ID: 17613

Received: 11/10/2021

Respondent: Member of Parliament

I also write to welcome the proposed designation of the Corbett Meadow as Local Green Space (Policy
DSA4).
In conjunction with this, I support Policy ENV1 (Nature Conservation and designation of Corbett Meadow as a Site of Local Interest for Nature Conservation); and ENV5 (Historic Character and Local Distinctiveness of the Black Country and designation of Corbett Meadow (Dudley) as Area of High Historic Landscape Value)
I support the work of the Corbett Meadow Action Group (CMAG) and fully endorse their submission to this consultation.

Object

Representation ID: 17615

Received: 11/10/2021

Respondent: Member of Parliament

I am writing to oppose proposed development on several sites in my parliamentary constituency of Stourbridge, covering two main areas:

- Land adjacent to Worcester Lane, Pedmore (Ref: DUH206, DUH207 and DUH209)
- Former grazing land at Wollaston Farm (Ref: DUH217)
I object to these proposals on four main grounds: -

1. Brownfield First
The Prime Minister has recently said that we should be "building beautiful homes on brownfield land in places that make sense". I agree completely with his statement.
I believe that the region should also adopt a brownfield first policy so these unnecessary proposals can be stopped.
I have always believed very strongly in building on brownfield sites before any green belt site can be considered. It is my belief that there is more work to be done to identify brownfield sites in the Dudley Borough. In this way, the homes earmarked for the sites could be built elsewhere, preserving precious green belt for residents.
Not only does this preserve existing green belt sites, but it also regenerates and invigorates areas that have often been left to decay or have at the very least been grossly underused. In my view, extra resources deployed to identifying and analysing brownfield sites would considerably outweigh the damage that could be done to green belt land. Evidence has also shown that building on these sites is often quicker than building on green belt sites.
The West Midlands Combined Authority (WMCA) has also secured £33m from the Brownfield Housing Fund (BHF), which allocates cash to bring old industrial sites back into use. Whilst I note this will not reduce housing targets in the Black Country Plan, it is a welcome move to expedite the use of brownfield sites that require remediation over releasing land from the Green Belt.

2. Preventing Urban Sprawl and Building Back Beautiful
We need housing targets reduced in the region to stem the flood of high-density development, which is creating immense pressure in commuter areas and our infrastructure and creating urban sprawl.
In 2017, Birmingham City Council adopted its Development Plan which paved the way for a monolithic urban extension of 6,000 homes on green belt land, mainly in Sutton Coldfield. The plan failed to consider thousands of negative responses during the consultation. It is expected that only around 2,000 – perhaps fewer – will be delivered by the Plan's end date of 2031. Residents have been left with a plan that fails to address the real housing need of local people.
There is a real risk the same could happen should the Black Country Plan be approved in its current state. An increasing body of evidence supports the fact that increasing densification and fragmentation of green spaces, propagated by 'filling in the gaps' around urban development, feeds a plethora of negative outcomes. These include increased traffic congestion (with the resultant pollution), greater energy use and the destruction of wildlife habitats.
These points are particularly relevant to site ref DUH217 (though sites DUH206, 207 and 209 also suffer) at Wollaston Farm – a slither of green space amongst hundreds of other homes. As well as the negative consequences mentioned above, development here would further degrade the distinctiveness and character of the area. A hard to measure metric, but certainly one that is mentioned time and again by residents.
For many years, urbanism has been turbo-charged with a mandate for place-making on the edge of our cities. We must let the environment be the turbo-charge for future place-making and build homes for the future that are truly environmentally led and that reflect both the surrounding community and the land that is used.

3. The value of Green Belt land
Green belt land is precious and once lost can almost never be reclaimed.
National Planning Policy Framework (NPPF) Section 13: Protecting Green Belt Land – Paragraphs 137-151. The policy makes it very clear that “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
That Green Belt boundaries should only be altered where exceptional circumstances exist. It is not clear what the exceptional circumstances are thought to be for the inclusion of DUH206, 207,209 and 217 in the plan.
Each piece of green belt land lost to development degrades the environment and weakens the long-term health of our communities.
As well as being a rich habitat for many different species, we cannot undervalue the benefits to our mental health that green spaces provide. Throughout the pandemic, people have been telling me how useful walking in the fields and in nature have been to their mental health. If ever there is a time to protect local green space, it is now. Living near a piece of land on which you can walk freely in the fresh air is a necessity in a major residential area. Each site I have mentioned in this response falls within this category. In a Borough which has been historically highly industrialised, local people defend their green spaces vigorously for these reasons.
Whilst both the Wollaston site and the Pedmore sites share these benefits, each has its own unique risks. The Wollaston site, Ref DUH217, as I have mentioned, is a green oasis in an otherwise built-up area. To build here would be to remove access to rare green space in a heavily residential area. In Pedmore, the sites Ref DUH206, 207 and 209 enhance the character of the area. People value the green space dividing Hagley and Pedmore, and many move to the area for its benefits. Similarly, visitors to the area are attracted from nearby Birmingham and Wolverhampton to enjoy the more rural surroundings.
Importantly if the land is released, it would mean houses in the wrong place –denying people the chance of home ownership, leaving many in a long term rental trap. It leaves people without aspirational living. It would leave a region bordering on urban sprawl.

4. Infrastructure
Services are under pressure in and around Stourbridge, so much so that any increase in population could push at-risk infrastructure past a tipping point. Schools, GP surgeries, dentistry, social care, parking, and emergency services are all under pressure. Without sufficient provision to support an increased population, any housing development – whether on green belt or not – should be seriously questioned.
In addition, traffic is a major and worsening issue in Stourbridge. Congestion throughout the area causes disruption and environmental damage. Some roads in Stourbridge are amongst the worst for air pollution in the Borough. There is no doubt that further significant development, resulting in hundreds more cars on local roads, will worsen the local situation. More specifically, considering sites DUH206, 207 and 209, Worcester Lane – a busy, single track road - would struggle to support any further service roads to residential developments. The same could be said for Kingsway in Wollaston, which is also very close to a local school.

Object

Representation ID: 17616

Received: 11/10/2021

Respondent: Member of Parliament

I am writing to oppose proposed development on several sites in my parliamentary constituency of Stourbridge, covering two main areas:

- Land adjacent to Worcester Lane, Pedmore (Ref: DUH206, DUH207 and DUH209)

I object to these proposals on four main grounds: -

1. Brownfield First
The Prime Minister has recently said that we should be "building beautiful homes on brownfield land in places that make sense". I agree completely with his statement.
I believe that the region should also adopt a brownfield first policy so these unnecessary proposals can be stopped.
I have always believed very strongly in building on brownfield sites before any green belt site can be considered. It is my belief that there is more work to be done to identify brownfield sites in the Dudley Borough. In this way, the homes earmarked for the sites could be built elsewhere, preserving precious green belt for residents.
Not only does this preserve existing green belt sites, but it also regenerates and invigorates areas that have often been left to decay or have at the very least been grossly underused. In my view, extra resources deployed to identifying and analysing brownfield sites would considerably outweigh the damage that could be done to green belt land. Evidence has also shown that building on these sites is often quicker than building on green belt sites.
The West Midlands Combined Authority (WMCA) has also secured £33m from the Brownfield Housing Fund (BHF), which allocates cash to bring old industrial sites back into use. Whilst I note this will not reduce housing targets in the Black Country Plan, it is a welcome move to expedite the use of brownfield sites that require remediation over releasing land from the Green Belt.

2. Preventing Urban Sprawl and Building Back Beautiful
We need housing targets reduced in the region to stem the flood of high-density development, which is creating immense pressure in commuter areas and our infrastructure and creating urban sprawl.
In 2017, Birmingham City Council adopted its Development Plan which paved the way for a monolithic urban extension of 6,000 homes on green belt land, mainly in Sutton Coldfield. The plan failed to consider thousands of negative responses during the consultation. It is expected that only around 2,000 – perhaps fewer – will be delivered by the Plan's end date of 2031. Residents have been left with a plan that fails to address the real housing need of local people.
There is a real risk the same could happen should the Black Country Plan be approved in its current state. An increasing body of evidence supports the fact that increasing densification and fragmentation of green spaces, propagated by 'filling in the gaps' around urban development, feeds a plethora of negative outcomes. These include increased traffic congestion (with the resultant pollution), greater energy use and the destruction of wildlife habitats.
These points are particularly relevant to site ref DUH217 (though sites DUH206, 207 and 209 also suffer) at Wollaston Farm – a slither of green space amongst hundreds of other homes. As well as the negative consequences mentioned above, development here would further degrade the distinctiveness and character of the area. A hard to measure metric, but certainly one that is mentioned time and again by residents.
For many years, urbanism has been turbo-charged with a mandate for place-making on the edge of our cities. We must let the environment be the turbo-charge for future place-making and build homes for the future that are truly environmentally led and that reflect both the surrounding community and the land that is used.

3. The value of Green Belt land
Green belt land is precious and once lost can almost never be reclaimed.
National Planning Policy Framework (NPPF) Section 13: Protecting Green Belt Land – Paragraphs 137-151. The policy makes it very clear that “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
That Green Belt boundaries should only be altered where exceptional circumstances exist. It is not clear what the exceptional circumstances are thought to be for the inclusion of DUH206, 207,209 and 217 in the plan.
Each piece of green belt land lost to development degrades the environment and weakens the long-term health of our communities.
As well as being a rich habitat for many different species, we cannot undervalue the benefits to our mental health that green spaces provide. Throughout the pandemic, people have been telling me how useful walking in the fields and in nature have been to their mental health. If ever there is a time to protect local green space, it is now. Living near a piece of land on which you can walk freely in the fresh air is a necessity in a major residential area. Each site I have mentioned in this response falls within this category. In a Borough which has been historically highly industrialised, local people defend their green spaces vigorously for these reasons.
Whilst both the Wollaston site and the Pedmore sites share these benefits, each has its own unique risks. The Wollaston site, Ref DUH217, as I have mentioned, is a green oasis in an otherwise built-up area. To build here would be to remove access to rare green space in a heavily residential area. In Pedmore, the sites Ref DUH206, 207 and 209 enhance the character of the area. People value the green space dividing Hagley and Pedmore, and many move to the area for its benefits. Similarly, visitors to the area are attracted from nearby Birmingham and Wolverhampton to enjoy the more rural surroundings.
Importantly if the land is released, it would mean houses in the wrong place –denying people the chance of home ownership, leaving many in a long term rental trap. It leaves people without aspirational living. It would leave a region bordering on urban sprawl.

4. Infrastructure
Services are under pressure in and around Stourbridge, so much so that any increase in population could push at-risk infrastructure past a tipping point. Schools, GP surgeries, dentistry, social care, parking, and emergency services are all under pressure. Without sufficient provision to support an increased population, any housing development – whether on green belt or not – should be seriously questioned.
In addition, traffic is a major and worsening issue in Stourbridge. Congestion throughout the area causes disruption and environmental damage. Some roads in Stourbridge are amongst the worst for air pollution in the Borough. There is no doubt that further significant development, resulting in hundreds more cars on local roads, will worsen the local situation. More specifically, considering sites DUH206, 207 and 209, Worcester Lane – a busy, single track road - would struggle to support any further service roads to residential developments. The same could be said for Kingsway in Wollaston, which is also very close to a local school.

Object

Representation ID: 17682

Received: 11/10/2021

Respondent: Member of Parliament

[WOH273]

I want to object to the inclusion of the Mosely Road open space, also known as the Grapes Pool Field, in the draft plan at Table 43 Site WHO 273.

The Mosely Road open space is a much loved green field area, used for leisure and providing an important amenity for local people. There is widespread and strong opposition from residents locally at its inclusion as a proposed development site. Residents make the point - and I agree - that new housing should be focussed on the many brownfield sites in the Wolverhampton and wider Black Country area. Local people should not be forced to choose between the new housing the area needs and the green spaces we love. There are many former factory and other industrial sites in the Black Country and these should be used for houing development, not the small amount of precious green space we have. My objections are supported by all three councillors for the Bilston North ward where this land sits and by the vast majority of local residents. we would like to see this space removed from the draft plan.

Object

Representation ID: 23208

Received: 11/10/2021

Respondent: Member of Parliament

Number of people: 2381

As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.

At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.

Object

Representation ID: 23209

Received: 11/10/2021

Respondent: Member of Parliament

Number of people: 2381

As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.

Object

Representation ID: 23223

Received: 11/10/2021

Respondent: Member of Parliament

As one of the thirteen Members of Parliament in the Black Country area I welcome the opportunity to comment on the proposed new Draft Plan that includes my Aldridge-­Brownhills constituency.
In recognizing that there is a requirement on the part of all local planning authorities to undertake a Local Plan that identifies where development will take place over a 20-year framework, the Plan in its current form is significantly flawed particularly in the Borough of Walsall and in large parts of the eastern flank of the Borough which includes the entire Aldridge-Brownhills constituency.
Throughout this submission I wish to outline how in repeated instances the land proposed in the Plan, which for a large part is for development on designated Green Belt, fundamentally goes against public opinion and planning guidance. Whilst accepting that there are to be further iterations of this document it is important that these concerns are expressed at this stage of the process, and addressed.
I note that under the heading 'What does this mean for Walsall?" the following figures are quoted: ­
• Additional Land needed to build additional homes: 13,344
To be provided as follows:­
• Urban areas and Brownfield sites: 7,928
• Green Belt sites: 5,418
However, throughout the proposed Plan there is no information available to explain the rationale for how these figures have been derived. Furthermore, if these figures are extrapolated over a 20 year period they are likely to be over exaggerated, and certainly not reflective of need.
The Office for National Statistics states:­ "The UK population growth rate from mid-2018 to mid-2019 was at 0.5% slower than any year since mid-2004".
In addition it states:­ "migration has continued to be the main driver of UK population growth since the 1990s".
On the basis that there is falling migration and a falling UK population growth rate, the forecast number of homes used for the purpose of the Black Country Plan is over exaggerated and must be revised downwards before moving forward. Furthermore it takes no account of the impact on business or housing needs as we emerge from the Coronavirus pandemic.
Yet for the purpose of the Black Country Plan there is an inbuilt assumption that these figures are accurate, thus locking communities across my Aldridge-Brownhills constituency into a plan that is fundamentally unfair and which at its heart devastates several of our most valuable Green Belt sites and our natural environment, at a time when the focus should be on building back better, greener and more sustainably. A key way to achieve this is to develop on brownfield sites first, of which we have many across the West Midlands, and focus as a priority on our town and urban/district centres.
Constituents from across Aldridge-Brownhills would be forgiven for not sharing the sentiments set out in the Black Country Plan where in Paragraph 4.6 it states:­
"The BCP adopts a brownfield-first approach to maximise delivery of development within the urban area".
As a community we are on the urban fringe of the West Midlands 'Metro' conurbation and I am still seeking to understand in the Borough of Walsall the extent to which that policy has been put into practice.
Furthermore in the same paragraph the authors of the Plan undermine their opening statement by declaring:­ "however, poor ground conditions are a legacy of the Black Country's mining and industrial past are a significant constraint, in both physical and financial terms". This assertion must be challenged.
In recent years, we have seen the steps taken and significant investment to successfully assist with the remediation of brownfield sites for housing. The United Kingdom is on the verge of playing global host to the UN Climate Change Conference (COP 26), yet it is unclear what full and proper assessment has been undertaken of all available brownfield sites in my constituency ahead of proposing large swathes of development on existing Green Belt sites.
It is extremely disappointing that the Black Country Plan fails to live up to its brownfield first policy aspiration, nor even recognises the value and multiple benefits that such a policy and protections would create.
By failing to live up to that policy the Green Belt will undoubtedly be sacrificed first, our communities and environment damaged and the opportunity to regenerate urban and brownfield sites lost for a generation, if not forever.
Turning again to the figures on which this Plan is based and even on the basis of the flawed starting point of 13,344 units required over 20 years, this equates to 667 units per year.
Adopting an urban and brownfield sites first policy would provide 12 years of homes without having to touch any of the Green Belt sites.
If the trajectory of population growth continues to fall and migration flows reduce, the preservation of our Green Belt would endure for longer, if not indefinitely, whilst housing need can be met on brownfield sites, and our towns and district centres are regenerated and reinvigorated to be able to meet the challenge of the post Covid-19 era and provide the needed homes.
Without such a commitment to uphold the development of brownfield sites first, developers will simply continue to choose Green Belt sites over brownfield sites seeing them as the easier and cheaper model for development.
The stated aims of the Green Belt and the protections that it is given are well documented. There should be no de-designation of existing Green Belt.
As identified in the National Planning Policy Framework, the Green Belt serves 5 key purposes. Key amongst those objectives is to check the unrestricted sprawl of large built up areas.
On all of the key sites identified on Green Belt land in my Aldridge-Brownhills constituency, these principles are being set to one side to meet questionable targets and quotas that for the reasons I have identified above have not been justified in the Plan.
The Plan states, "the density of housing development in the existing urban areas will be increased to ensure that the land is used efficiently". There is widespread support to ensure the better utilisation of existing development land especially were it allows an increase in density and infilling for new homes, however there are no details or examples contained within the Plan as to how this can be fully achieved.
Whilst such an approach is to be welcomed, to fully understand whether this approach has been adopted by the Plan more information is required, particularly to understand if these are reflected in the proposed numbers.
Strategic Priorities 3 and 4 contained within the Plan carry widespread public support: ­
"to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents".
"to improve and diversify the Black Country housing offer".
However, the proposed Plan identifies a large number of sites within the Aldridge-Brownhills constituency that will certainly not meet the identified strategic priorities as set out. The average spend by a first time buyer across England stands at £205,246. Average house prices in Aldridge, Pelsall and Streetly all stand above the average first time buyer rate and the West Midlands average.
Indeed, in the case of two of the proposed sites (Aldridge Road/Queslett Road East and Stonnall Road) average prices based on the West Midlands average are between 51% and 110% higher.
Several of the current proposed sites will not manage to meet the stated objectives in these strategic priorities, they could in fact further fuel levels of unaffordability as this proposed plan will not provide the necessary housing mix.
In seeking to achieve a balanced plan, I applaud the aim of seeking to enhance the vitality of our town centres. Key Government support projects prior to and since the Covid-19 pandemic seek to recognise the changing face of our High Streets and Village Centres.
Yet the Black Country Plan fails to take full advantage of any changing High Street within my own constituency. All of the development is predominately focussed on existing Green Belt sites and on the outskirts of Village Centres well away from our High Streets.
Transport Infrastructure and the enhancement of sustainable and active travel are to be applauded and should be central to any development plan, but it is unclear from within the proposed plan how this will be underpinned by the current document.
A number of the proposed sites across Aldridge-Brown hills currently suffer from severe daily congestion, including Aldridge Road/Queslett Road East, Wolverhampton Road, Pelsall Road/Clayhanger junction and Stonnall Road.
Large parts of the road network cannot cope with the existing number of properties/vehicles, in the case of the proposed Aldridge Road/Queslett Road site the imposition of 960 properties most of which would turn right towards Birmingham would lead to even further increased gridlock in both directions given at the same time more than 1,900 school children are currently seeking to access the existing road network.
Whilst constituents would welcome steps towards more sustainable levels of transportation, it is highly questionable as to whether we can justify attempting to take these vital necessary steps when there is a lack of detailed transport modelling to accompany the proposed plan.
Further, Paragraph 4.9 supports the fact that this has not happened and only remains 'on-going'. Improved sustainable travel will not account for the loss of the natural environment with large swathes of Green Belt being lost for a future generation.
No proper thinking has underpinned education needs and the impact that the proposed sites in Aldridge-Brownhills would place on the already pressured school network. With large numbers of schools across the constituency already at capacity and the pressure of the additional number of homes being proposed, I am concerned as the Member of Parliament that schools would not be able to accommodate such an influx of new development.
Equally, across my Aldridge-Brownhills constituency, we have witnessed in recent years an increase in the amount of flooding that has taken place in areas where the Black Country Plan has proposed a large number of these new properties. Areas such as Wolverhampton Road and Aldridge Road/Queslett Road East sites have had repeated instances of flooding in recent years including the flooding of homes.
To remove even more natural soakaway in several of these areas would have a detrimental effect on existing residents. This should not be overlooked at the initial stages of site allocation/preference in this Plan as it should include work on the existing drains and sewers too.
The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.
Whilst acknowledging that the current consultation has worked within the framework of the statutory guidelines set down, I do not believe that it has worked within the spirit.
A more rigorous communication plan should have been in place to raise the spectre of the importance of this consultation particularly in areas which could potentially be most affected by any future plan to implement.
In my own constituency Councillors alongside volunteers have been left to play their civic role in seeking to encourage large-scale participation, but we all believe that this should have been backed up with greater central co-ordination.
There is widespread understanding amongst residents from my Aldridge-Brownhills constituency that we need to plan new homes for future generations, the only question we would ask is do we have to facilitate these whilst destroying some of our most precious Green Belt and Open Spaces?
The latest iteration of this Plan is unacceptable to me as the Member of Parliament for Aldridge-Brownhills and to large numbers of my constituents who have contributed to this consultation.
In responding to your consultation, I am insisting, on behalf of the constituency of Aldridge­ Brownhills, that the Black Country Plan lives up to its own aspiration to promote a development policy of Brownfield First.
As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.
Green Belt sites can only be developed once, and we owe it to all the future generations of this country in an era of environmental vigilance to protect designated Green Belt sites and adopt a policy of Brownfield First development. On behalf of my constituents from Aldridge­ Brownhills I urge the next iteration of this strategy to do exactly that.

Object

Representation ID: 23224

Received: 11/10/2021

Respondent: Member of Parliament

As one of the thirteen Members of Parliament in the Black Country area I welcome the opportunity to comment on the proposed new Draft Plan that includes my Aldridge­Brownhills constituency.
In recognizing that there is a requirement on the part of all local planning authorities to undertake a Local Plan that identifies where development will take place over a 20-year framework, the Plan in its current form is significantly flawed particularly in the Borough of Walsall and in large parts of the eastern flank of the Borough which includes the entire Aldridge-Brownhills constituency.
Throughout this submission I wish to outline how in repeated instances the land proposed in the Plan, which for a large part is for development on designated Green Belt, fundamentally goes against public opinion and planning guidance. Whilst accepting that there are to be further iterations of this document it is important that these concerns are expressed at this stage of the process, and addressed.
I note that under the heading 'What does this mean for Walsall?" the following figures are quoted: ­
• Additional Land needed to build additional homes: 13,344
To be provided as follows:­
• Urban areas and Brownfield sites: 7,928
• Green Belt sites: 5,418
However, throughout the proposed Plan there is no information available to explain the rationale for how these figures have been derived. Furthermore, if these figures are extrapolated over a 20 year period they are likely to be over exaggerated, and certainly not reflective of need.
The Office for National Statistics states:­ "The UK population growth rate from mid-2018 to mid-2019 was at 0.5% slower than any year since mid-2004".
In addition it states:­ "migration has continued to be the main driver of UK population growth since the 1990s".
On the basis that there is falling migration and a falling UK population growth rate, the forecast number of homes used for the purpose of the Black Country Plan is over exaggerated and must be revised downwards before moving forward. Furthermore it takes no account of the impact on business or housing needs as we emerge from the Coronavirus pandemic.
Yet for the purpose of the Black Country Plan there is an inbuilt assumption that these figures are accurate, thus locking communities across my Aldridge-Brownhills constituency into a plan that is fundamentally unfair and which at its heart devastates several of our most valuable Green Belt sites and our natural environment, at a time when the focus should be on building back better, greener and more sustainably. A key way to achieve this is to develop on brownfield sites first, of which we have many across the West Midlands, and focus as a priority on our town and urban/district centres.
Constituents from across Aldridge-Brownhills would be forgiven for not sharing the sentiments set out in the Black Country Plan where in Paragraph 4.6 it states:­
"The BCP adopts a brownfield-first approach to maximise delivery of development within the urban area".
As a community we are on the urban fringe of the West Midlands 'Metro' conurbation and I am still seeking to understand in the Borough of Walsall the extent to which that policy has been put into practice.
Furthermore in the same paragraph the authors of the Plan undermine their opening statement by declaring:­ "however, poor ground conditions are a legacy of the Black Country's mining and industrial past are a significant constraint, in both physical and financial terms". This assertion must be challenged.
In recent years, we have seen the steps taken and significant investment to successfully assist with the remediation of brownfield sites for housing. The United Kingdom is on the verge of playing global host to the UN Climate Change Conference (COP 26), yet it is unclear what full and proper assessment has been undertaken of all available brownfield sites in my constituency ahead of proposing large swathes of development on existing Green Belt sites.
It is extremely disappointing that the Black Country Plan fails to live up to its brownfield first policy aspiration, nor even recognises the value and multiple benefits that such a policy and protections would create.
By failing to live up to that policy the Green Belt will undoubtedly be sacrificed first, our communities and environment damaged and the opportunity to regenerate urban and brownfield sites lost for a generation, if not forever.
Turning again to the figures on which this Plan is based and even on the basis of the flawed starting point of 13,344 units required over 20 years, this equates to 667 units per year.
Adopting an urban and brownfield sites first policy would provide 12 years of homes without having to touch any of the Green Belt sites.
If the trajectory of population growth continues to fall and migration flows reduce, the preservation of our Green Belt would endure for longer, if not indefinitely, whilst housing need can be met on brownfield sites, and our towns and district centres are regenerated and reinvigorated to be able to meet the challenge of the post Covid-19 era and provide the needed homes.
Without such a commitment to uphold the development of brownfield sites first, developers will simply continue to choose Green Belt sites over brownfield sites seeing them as the easier and cheaper model for development.
The stated aims of the Green Belt and the protections that it is given are well documented. There should be no de-designation of existing Green Belt.
As identified in the National Planning Policy Framework, the Green Belt serves 5 key purposes. Key amongst those objectives is to check the unrestricted sprawl of large built up areas.
On all of the key sites identified on Green Belt land in my Aldridge-Brownhills constituency, these principles are being set to one side to meet questionable targets and quotas that for the reasons I have identified above have not been justified in the Plan.
The Plan states, "the density of housing development in the existing urban areas will be increased to ensure that the land is used efficiently". There is widespread support to ensure the better utilisation of existing development land especially were it allows an increase in density and infilling for new homes, however there are no details or examples contained within the Plan as to how this can be fully achieved.
Whilst such an approach is to be welcomed, to fully understand whether this approach has been adopted by the Plan more information is required, particularly to understand if these are reflected in the proposed numbers.
Strategic Priorities 3 and 4 contained within the Plan carry widespread public support: ­
"to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents".
"to improve and diversify the Black Country housing offer".
However, the proposed Plan identifies a large number of sites within the Aldridge-Brownhills constituency that will certainly not meet the identified strategic priorities as set out. The average spend by a first time buyer across England stands at £205,246. Average house prices in Aldridge, Pelsall and Streetly all stand above the average first time buyer rate and the West Midlands average.
Indeed, in the case of two of the proposed sites (Aldridge Road/Queslett Road East and Stonnall Road) average prices based on the West Midlands average are between 51% and 110% higher.
Several of the current proposed sites will not manage to meet the stated objectives in these strategic priorities, they could in fact further fuel levels of unaffordability as this proposed plan will not provide the necessary housing mix.
In seeking to achieve a balanced plan, I applaud the aim of seeking to enhance the vitality of our town centres. Key Government support projects prior to and since the Covid-19 pandemic seek to recognise the changing face of our High Streets and Village Centres.
Yet the Black Country Plan fails to take full advantage of any changing High Street within my own constituency. All of the development is predominately focussed on existing Green Belt sites and on the outskirts of Village Centres well away from our High Streets.
Transport Infrastructure and the enhancement of sustainable and active travel are to be applauded and should be central to any development plan, but it is unclear from within the proposed plan how this will be underpinned by the current document.
A number of the proposed sites across Aldridge-Brown hills currently suffer from severe daily congestion, including Aldridge Road/Queslett Road East, Wolverhampton Road, Pelsall Road/Clayhanger junction and Stonnall Road.
Large parts of the road network cannot cope with the existing number of properties/vehicles, in the case of the proposed Aldridge Road/Queslett Road site the imposition of 960 properties most of which would turn right towards Birmingham would lead to even further increased gridlock in both directions given at the same time more than 1,900 school children are currently seeking to access the existing road network.
Whilst constituents would welcome steps towards more sustainable levels of transportation, it is highly questionable as to whether we can justify attempting to take these vital necessary steps when there is a lack of detailed transport modelling to accompany the proposed plan.
Further, Paragraph 4.9 supports the fact that this has not happened and only remains 'on-going'. Improved sustainable travel will not account for the loss of the natural environment with large swathes of Green Belt being lost for a future generation.
No proper thinking has underpinned education needs and the impact that the proposed sites in Aldridge-Brownhills would place on the already pressured school network. With large numbers of schools across the constituency already at capacity and the pressure of the additional number of homes being proposed, I am concerned as the Member of Parliament that schools would not be able to accommodate such an influx of new development.
Equally, across my Aldridge-Brownhills constituency, we have witnessed in recent years an increase in the amount of flooding that has taken place in areas where the Black Country Plan has proposed a large number of these new properties. Areas such as Wolverhampton Road and Aldridge Road/Queslett Road East sites have had repeated instances of flooding in recent years including the flooding of homes.
To remove even more natural soakaway in several of these areas would have a detrimental effect on existing residents. This should not be overlooked at the initial stages of site allocation/preference in this Plan as it should include work on the existing drains and sewers too.
The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.
Whilst acknowledging that the current consultation has worked within the framework of the statutory guidelines set down, I do not believe that it has worked within the spirit.
A more rigorous communication plan should have been in place to raise the spectre of the importance of this consultation particularly in areas which could potentially be most affected by any future plan to implement.
In my own constituency Councillors alongside volunteers have been left to play their civic role in seeking to encourage large-scale participation, but we all believe that this should have been backed up with greater central co-ordination.
There is widespread understanding amongst residents from my Aldridge-Brownhills constituency that we need to plan new homes for future generations, the only question we would ask is do we have to facilitate these whilst destroying some of our most precious Green Belt and Open Spaces?
The latest iteration of this Plan is unacceptable to me as the Member of Parliament for Aldridge-Brownhills and to large numbers of my constituents who have contributed to this consultation.
In responding to your consultation, I am insisting, on behalf of the constituency of Aldridge­ Brownhills, that the Black Country Plan lives up to its own aspiration to promote a development policy of Brownfield First.
As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.
Green Belt sites can only be developed once, and we owe it to all the future generations of this country in an era of environmental vigilance to protect designated Green Belt sites and adopt a policy of Brownfield First development. On behalf of my constituents from Aldridge­ Brownhills I urge the next iteration of this strategy to do exactly that.