Draft Black Country Plan

Comment

Representation ID: 23239

Received: 11/10/2021

Respondent: Member of Parliament

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.

Comment

Representation ID: 23240

Received: 11/10/2021

Respondent: Member of Parliament

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.

Comment

Representation ID: 23241

Received: 11/10/2021

Respondent: Member of Parliament

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.

Object

Representation ID: 23242

Received: 11/10/2021

Respondent: Member of Parliament

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.

Object

Representation ID: 23243

Received: 11/10/2021

Respondent: Member of Parliament

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.
A Brownfield First policy approach, coupled with regeneration of our High Streets and Urban Districts, infilling and improved density can produce all the homes we need, without encroaching on the Green Belt.
Across the globe as we emerge from the pandemic global thinking is dictating that we Build Back Better. At the heart of that is to Build Back Better and Greener - something at this stage the Black Country Plan fails to achieve.

Object

Representation ID: 45977

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:


- 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.