Black Country Core Strategy Issue and Option Report

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

Dear Sir,

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

Dear Sir,

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.

Dear Sir,

REF BLACK COUNTRY CORE STRATEGY



The Friends of Sheepwash Local Nature Reserve would like to respond to this consultation set out below.The friends group is one of the longest established in Sandwell going back to 1997.
Sheepwash Local Nature Reserve,the only designated local nature reserve in Tipton has recorded around 190 bird species as well as having SSSI status sites and areas of locally rare important wildlife habitat such as wet meadow areas and wetland/reed habitat.Our primary objectives as per our constitution are the protection of the nature reserve and its surrounding wildlife corridors and also trying to combat the anti- social behaviour/vandalism that has plagued the site for many years. The Black Country Core strategy raises issues which are highly relevant to these two objectives and it also must be said that it directly threatens the future of this site.


THE CONSULTATION PROCESS AND THE FLAWED STRATEGY

Firstly we would like to state that we do not believe this consultation has been conducted in a very appropriate manner. The core strategy itself is far too broad and the oppressive 100 page document, and 13o+ questions is unlikely to have been communicated in such a way that the majority of people will even have read or understood what it is about.The shortened online
version is little more than a loaded confirmation bias tick box exercise whereby the BCCS can write

off a "democratic" consultation exercise to get what the constructors want- which is to build more houses on open space.

Quite simply we distrust the entire basis on whichit is constructed,and its authors appear to be minded towards the ever unsustainable expansion of urban environments by usurping any land available no matter how contaminated it is or how it will adversely affect those who are already finding it difficult to live with the overpopulated density that planners believe is acceptable.
A reasonable question which we would like to ask the BCCS is,if people reject your plans for housing more unsustainable housing in their areas,given you are refusing to even ask "IF" they want more housing instead of "where" it should be,are you just goingtoignore all the objections despite having no democratic basis to justify pressing ahead with it? To what extent are people already living in densely overpopulated areas like the Black Country compared with the rest of the UK even offered a choice in the BCCS vision?
Our open spaces are beingsystematically destroyed by the avarice of the "offshore" tax avoidance construction lobby and the political/business class who faithfully serve them and who themselves choose to remain and live in splendid ruralisolation,yet dictate that we should have to live with more overspill from Cities like Birmingham to line their pockets still further- most notably by supplementingthe private landlord and so called "affordable housing" industry.
Put simply, "the need" for housing in the Black Country is one which is founded on an odious lie about rising population.The population "rise" is down to manipulated Lego land building by
politicians,simply to raise the council tax bands to accrue more money in order to cover their perennial mismanagement .It can also be used to plead "poverty" to national Government, and unfortunately the unwanted West Midlands Combined Authority-(again with no valid mandate),is a means of achieving this.
Taking Sandwell as an example, one can see that from official figures on its creation in 1974 that this area according to the official guide from that year:
"With an estimated popu lation of 324,000 and a total area of 21,150 acres, the borough is urban in character and highly industrialised and includes the districts of Oldbury, Rowley Regis, Smethwick, Tipton, Wednesbury and West Bromwich."


A freedom of information request however revealed in 2014 that this figure had actually fallen to

316, 700.
https://www.whatdotheyknow . com/request/306 299/response/777 408/ attach/html /3/FOl %20Re sponse%201%20727066864 . doc.html


Having looked into the official statistics for the other black country boroughs,they also show this statistic of population falls with the 1980/90's, yet only increasing with the disastrous managed Eastern European free movement in 2004- itself a politically managed and motivated cheap labour exercise. With Brexit hopefully now alleviating this influx, to what extent has the BCCS taken this into account,and why shouldit want to create what could become unoccupied new house ghost towns that no one lives in?

Every mention of this theme of "need" running throughout the document and "the strategy" is challengeab le, yet the authors of this paper do not appear to want it to be. Below are the latest figures from the estimations of The office of national statistics.


Choose an area Walsall
278,715 people in 2016 All ages

Choose an area Sandwell
322,712 people i n 2016 All ages

136.919 males 141,796 females

49.1% i-----

159,904 males
162,808 females

49.6% -----i.





Choose an area Dudley
317,634 peop le i n 2016

Choose an area Wolverhampton
256,621 people i n 2016

All ages
155.945 males
161.689 females




49.1%
50.9%-----

All ages
127.25 males 129,596 females



49.5%
50






As seen by these statistics,Sandwell's population is the largest, yet as a borough it has 86 square kilometres {33 sq mi) according to the 2011census. Wolverhampton by comparison has 26.8 square miles.





"QJ' "' c


oil

"' E c
'ijj "' ::i

"O "O 2

'" QJ

.!: 0
ti; u

Statistical Unit of

i"ii'i i"ii'i

t: "'

'U "cO > -u"

Unit Measure c c ;::

';":: ::i "'

C;::i "'

Old Code

UJ UJ 0 Ill iii

ONSCode K04000001 E92000001 El2000005 EOS000030 EOS000027 EOS000028 EOS000031 n/a
Usually Resident Population 2011 Persons Nvmber 56075912 53012456 5601847 269323 312925 308063 249470 1139781
c Usually Resident Population 2001 Persons Nvmber 52041916 49138831 5267308 253499 305155 282904 236582 107814(
.!? Popn Change 2001-2011 Persons Proportion 0.071938 0.07307 0.059719 0.058755 0.02483 0.081668 0.051662 0.054081
;;;

-s Males Persons Nvmber 27573376 26069148 2763187 132319 153819 151592
Q.

123441 561171

0 Females
Q.

Persons Number 28502536 26943308 2838660 137004 159106 156471 126029 57861(

Area Heerores Number 15101354 13027843 1299832 10395.49 9795.66 8556.73 6943.95 35691.8:
Density Persons per ha Nvmber 3.713304 4.069166 4.309671 25.90768 31.94527 36.00242 35.92624 31.9339




One can see that this population density in Sandwell is grossly disproportionate to England and Wales- as are the other Black country boroughs,yet how is it that we are expected to take more, or that there should even be "a call for sites"? Just what madness is the BCCS trying to create?
THERE IS QUITE SIMPLY NO ROOM LEFT! At what point are planners going to accept this because currently it does not appear that they have set any maximum levels, except coming back every

few years and wanting more and more land for unsustainable housing supply when the "demand" has been artificially created.


Sheepwash and increasing population density

We have witnessed how increasing population density around the site has contributed to an increase in anti-social behaviour as well as the disjointed disintegration of community by influx of non- English speakers. Essentially foreign ghettos have been created where large social housing developments for rent have destroyed the character of towns.With a fall of police,no school
places,full doctors surgeries,over- subscribed school places,where is the "sustainability"?

The nature reserveitself is directly threatened as a concept by an increase in human population around its centre. In particular reference to this was the ludicrous decision to centre a regeneration corridor for housing RC9,to which we continue to fundamentally object.


THE secs QUESTIONS
We do not wish to answer all of the SCCS questions but the ones that are most relevant to protectingsheepwash from further threat of housing.



No we do not.

"There have been a number of changes to national policy and a housing shortfall has been identified in Birmingham which neighbouring authorities have a duty to consider accommodati ng."
For reasons stated above concerning population density,it is a disgrace that the BCCS tries to sneak this through without a full review. Why should neighbouring authorities have "a duty" to accommodate Birmingham's overspill? By "stretching" the existing special strategy you mean more land grabbing for housing so why hide behind such concealed scheming?
We are sick and tired of having to be "developed" in the urban area.

"Given the levels of growth to be planned for, care is needed to safeguard environmental and historic assets and to ensure enough services,such as open space,shops,schools and healthcare, are provided."


This statement in relation to Sandwell,and specifically corridor RC9 cannot be delivered.

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No
If not,what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide deta i l s .






No. Each individual site should be looked at for constraints. Land contamination issues for specific sites in the 2011 core strategy were not looked at seriously. In particular the recently published Sandwell council Dudley Port supplementary planning document dealing with housing allocation sites in the RC9 corridor show that none of the proposed sites have been developed and still have considerable contamination issues associated with them. Five years on, and some of the sites have remained in exactly the same condition- ie non-deliverable. For how long should these sites
remain as paper target figure exercises before being realised that they are never going to be
deliverable? In particular the former Duport's tip site in Tividale was supposedly "reclaimed" but was not in terms of housing suitability in the 1990's under the auspices of the black country development corporation,but retains considerable development constraints. No local residents that we have spoken to want the area developed for housing at all,yet it remains on the plan against all local opposition- why?
We would also like to add that a large petition was handed into Sandwell council against this housing allocation site in the consultation for the DPSPD.We want to see this site removed from the allocation process as not deliverable and also not wanted.
We also note at this stage from the Health and Wellbeing Technical Paper



"Local communities through local and neighbourhood plans should be able to identify special protection for green areas of particular importance to them. By designating land as Local Green Space, local communities will be able to rule out new development other than in very special circumstances. Identifying land as Local Green Space should therefore be consistent with the local planning of sustainable development and complement investment in sufficient homes,jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period (para.76.)"





No we do not. We could not care less about "national guidance" as these theories do not live in our area, and neither do planning inspectors from Bristol.You frame these questions in such a way as to supply what you are going to do then ask people to challenge it based on "national guidance". Whereis there any evidence of compiling a strategy based on what local people want, instead of what national guidance demands? The housing allocations are not appropriate because they are unsustainable.
Our futures under increasing density appear in your context to be linked to the housing business market, supplying money to greedy developers. The strategy should not be based on HMA's and certainly not accommodati ng Birmingham overspill.Is this core strategy called "the Birmingham core strategy''?
With question four we simply ask,if more employment land is also sort in this exercise after you basically did not correctly apply it in 2011,why do you not just accommodate this into the existing brownfield sites instead of trying to clean up contaminated sites of past industrial use for housing and then grabbing land for employment from the greenbelt. The BCCS appears to want to increase

the population to unsustainable levels and then try to fit in employment as an afterthought.You cannot do this, the area is full and there are few jobs already.



Who are The Greater Birmingham and Black Country Housing Market Area (HMA) authorities and to whom are they accountable or answerable? Who elected them? We do not support building on green belt land to accommodate former Industrial land house buildingto line the pockets of the house building industry.Existing vacant Industrial land should be used to house new industry and support existing population job growth.
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No
If not,what other key issues should be taken into account?

Officers compiling this plan and particularly councillors approving it need to look at the social breakdown of communities and the threat to mental health that population density and also lack of jobs is creating.The more you increase the population the less chance of a job. All of strategy appears to be centred around "the economy'' and not about local peoples' needs or aspirations. There is a string sense that decisions are being promoted by people who do not live in the black country, by choice,and a blank cheque is being given to promote these schemes all based on theoretical numbers. There are few practical or realistic measures in this review just more theory, more acronyms,more figures.
You should look first at existing school places, existing doctors surgeries etc BEFORE adding more people and then as an afterthought deciding that more of these are then needed.




uestion 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/ No
not, what alternatives would you suggest and how might these changes impact on individual re Strateft'LllOlicies?


As previously stated, area RC9is not deliverable. It has not been deliverable for over 30 years before the 2011BCCS. It is proposed to build new houses on contaminated land putting existing residents at risk who do not want their quality of life ruined for the purposes of meeting targets. Their view should be a valid vision.
More open space/wildl fe areas are needed in the brownfield area.These are being lost and so called "mitigation" isn't being met where wildlife is concerned.






If you support the release of further employment land for housing, what should the characteristics of these employment areas be?

Question llb - Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No
Please submit specific sites through the 'call for sites' form.

We totally reject all your proposals. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appea r here to be suggesting putting small existing businesses out of business on the say so of any
individ ual who wants to build houses there instead. This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing. What democratic mandate does the BCCS have for doing this? It is deplorable.





Question 14 - Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No
[If yes, please provide details.
No we do not support either. When you talk of "rounding off" the green belt this means grabbi ng land and putting a spin on it. Look at the black country borough density we have given evidence on and compare this with the green belt in areas like Warwickshire/Worcestershire/Shropshire and Staffordshire. These areas should give up their green belt land first. The green belt area , or

what you can even call such in the Black country cannot be given over to satisfying Birmingham's "poverty" pitch.To question 15 we would refer to this "export" as you termit. The black country is full.











El,E2,E3 NO STRONGLY OPPOSED. E4 yes. It has long been established that people can commute FROM areas such as Kinver or Malvern into the black country, yet never in the opposite direction. Why?
Q20 The Vaughn trading estate in Tipton is one such site, and we are keen to see The Autobase industrial estate on the border of Sheepwash retained for industrial use. NB WE OPPOSE ANY THREAT OF THIS SITE EVER BECOMING CONSIDERED FOR HOUSING.
















We do not support creating more housing capacity, as already stated in our area because it has reached an unsustainable level already. We have had many dealings with West Midlands police and also Sandwell council's anti-social behaviour teams. Pressure from new developments in the Tividale area and Great Bridge has resulted in more anti-social behaviour issues- particularly riding of off road bikes and illegal fishing on the nature reserve. This leads to the value of the site as "a nature reserve" and also a SSSI site being devalued.
We are aware of school places in the area being challenged, and in the Temple Way area (part of RC9 corridor), there are no shops,poor parking and a lack of any community centre.Another 250 houses in this area on the site of the former Duport's Tip will do nothing but over tip this unsustainable situation even further.
We are afraid that there is a major disconnect in reality from people who do not live in our area, and who are producing the BCCS and our personal and practical every day experiences. There is
little engagement other than this oppressive generalised strategy for allowing people to express their opinions.There is a lack of planning involving local people, and the impression that they do not have any control or say in how their areas will develop or remain.







"Poor ground conditions, a legacy of the Black Country's mining and industrial past,affect much of the area. As ground conditions are a major constraint on delivery,land remediation is a priority for delivery intervention.Itis recognised that in dealing with individual development proposals, exceptional circumstances may occasionally arise which result in genuine financial viability concerns,for example where remediation costs are above what could reasonably have been

foreseen. The Black Country has a good track record of working with developers to address viability issues and del ver sites."
Corridor RC9 is the epitome of this.The Black country development corporation failed. The Duport's tip site has onits doorstep the contaminated rattlechain lagoon,a chemical waste dump and threat with a still current waste management licence.It is unthinkable to build more housing
in such a location- hereis a direct quote from social media about someone who was conned, and we use that word because it is true when they bought a house built on the former sewage works next to this lagoon,which by stupidity of a Bristol planning inspector gained approval.
1 Ibought a house on the banks of this chemical dump. It took me 18 months to sell it (at a massive loss which I'm still paying for now).So glad I'm away from this now.Many nights sleep lost wonying about the health
of my kids growing up with this in our back garden.We had meetings with the Environmental Health and Rhodia and were even interviewed by the press. Nothing ever came ofit. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
like Reply Message O 2 2 I 1
NOW THAT'S GREAT STRATEGIC THEORETICAL PLANNING FOR YOU ISN'T IT. It is also a reminder
that planners need to live in the real world and realise that people have to live in these areas for many,many years and building in such locations can have significant health consequences.
Question 31 - Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No
If no, what alternative sources of funding or delivery mechanisms should be investigated?

No,you are not living in the real world.Many sites like the ones mentioned already are not deliverable,have not been deliverable in the last five years,have not had anything done to them
in the last five years and are not economically viable.Why then are such sites retained when the prospect of them ever becoming a reality (which local people do not want anyway)?

Question 32 - Do you think that the proposed approach to incorporate health and wellbeing issues in the Core Strategy review is appropriate? Yes/No
If no, please provide details




Question 33 - Is there more that the Core Strategy can do to address health and wellbeing issues in the Black Country? Yes/No
If yes, is a new policy needed to address such issues for example?




Question 34a - Do you agree that the health and wellbeing impacts of large development proposals should be considered at the Preferred Spatial Option stage of the Core Strategy review through a Health Impact Assessment approach? Yes/No

Question 34b - What design features do you think are key to ensuring new development encourages healthy living, which could be assessed through the HIA process?


This is fundamental,but you don't appear to realise that putting pressure on people,reducing
their areas of open space,nature reserves and access to nature are a direct threat to their existing health and wellbeing.

* YOU MUST LOOK AT THE IMPACT OF HOUSING DENSITY AND HOW THIS PROMOTES MENTAL ILL HEALTH AND ANTI-SOCIAL BEHAVIOUR
* YOU MUST LOOK AT HOW CREATING FOREIGN GHETTOS,(OF LARGELY NON FIRST LANGUAGE ENGLISH SPEAKING IMMIGRANTS), IS DESTROYING A SENSE OF EXISTING COMMUNITY
* YOU MUST LOOK AT HOW HOUSING YOUNG AND OLD TOGETHER, AND MIDDLE CLASS WITH LOWER CLASS ECONOMIC UNDERCLASSES IS DESTROYING COMMUNITY.
* SOCIAL PRIVATE RENT HOUSING BOLTED ONTO NEW DEVELOPMENTS IS DESTROYING COMMUNITY.
* THE TIME OF SOCIAL AND MULTICULTURAL EXPERIMENTS,WHICH HAVE NEVER WORKED ANYWHERE IN THE URBAN REALM MUST CEASE.
More housing=fewer opportunities, jobs, school places, doctor's appointments,queues in shops. It also promotes car fumes, social inequality, power cuts etc
Worse stillis the health and wellbeing aspect of building sites on contaminated land. There are few studies at present which show the long term impact of 50 years of living on such a site. The new build on brownfieldland first approach is a potential cancer keg which will hit the NHS if it still exists. Illconceived developments such as The Stonegate housing estate in Walsall is a good example of such a mistake in that people who live in this area are unsure as well as the local authority as to how this direct health threat will be dealt with. The core strategy does not address this issue and neither does the unfit for purpose NPPF. Indeed the NPPF is a Nostradamus like nonsense with directly conflicting statements like the quatrains of the great "prophet" ,which can be used by anyone who wants to cherry pick to suit their particular argument.It is also written by civil servants who do not live in areas like the black country, and will never do so by choice- for the purposes of their own "health and wellbeing".
Question 35 - Do you support the proposed approach to housing land supply? Yes/No If no, please explain why.


No for the reasons stated above.







We are totally opposed to so called "garden city" principles as these are a spin on land grabbing and building on areas of nature conservation and open space and reducing it. We submitted an objection to Sandwell councilregarding the Dudley Port supplementary planning document citing that though the document spoke of "Dudley port" the area affected by the largely economically non- viable housing areas (RC9) is located in Tividale. A petition signed by over 400 local residents

and users of Sheepwash nature reserve was also submitted at the same time.If this is white washed it makes a mockery of this whole exercise, asit is not what local people want, but people who believe they are somehow better than those people and who do not live in their area who are making life changing decisions for their areas."The garden city" is a direct threat to nature.



We do not believe the NPPF cares about this issue, but policy envl does address the concerns we have about development around sheepwash and how corridor RC9 is in conflict with this.
Question 102a - Do you support the proposed changes relating to open space, sport and recreation? Yes/No
If no, please explain
Question 102b - Do you think that Policy ENV6, taken together with national and local policies, provides sufficient protection from development for open space? Yes/No
If no, please explain
Question 102c - Do you think that any other criteria need to be added to Policy ENV6, or any other changes shou ld be made. Yes/No
If yes,please provide details.

You have not set out what these "proposed changes" are to policy ENV6 !This needs immediate clarification. We do not believe the caveat of the current policy ENV6 "making creative use of land exchanges and disposing of surplus assets to generate resources for investment" protects open space but just leaves it open to being targeted.We also do not believe that this policy should be used to undervalue nature conservation sites like sheepwash- eg by inserting a play area into the site which is not wanted. This policy has potential to undermine any existing nature reserve sites, and so we would like clarification on what the changes are.

We believe that nature reserve sites should have special mention in this policy so that they are not targeted for land swap use- i.e a football pitch is built on for housing,so a new football pitch is created on part of the nature reserve. The net loss is to the nature "reserve" but this policy does not adequately clarify if there is a hierarchy of sites. We are of course of the opinion that nature reserves should come before sports provision.
Question 115a - Do you have evidence of any realistic possibility of tracking in the Black Country? Yes/No
If yes, please provide details.
Question 115b - Do you think there are particular issues for the Black Country that would justify approaches different from those in national policy? Yes/No
If yes, please provide details.

We do not support tracking under any circumstances. The legacy of past industrial use and soil contamination make this concept a non- starter in terms of water/river contamination.





No we do not. These plans will always be opposed locally in terms of corridor RC9 and the development next to rattlechain lagoon and the former Duport's tip.There is very weak detail

provided in local plans like the Dudley port supplementary planning document about this area. Take for example the swot analysis, which Sandwell council did not even publish with the document,but was obtained through an FOi request.




We have added these to illustrate the point of locating additional housing next to a hazardous waste site. We can see here that the detailis poor from the DPSPD about land remediation costs and the "inappropriate development''.

Why would you possibly want to limit information for potential house buyers/investors? As far as we are concerned this sets the BCCS for what it is- a con job manufactured by the political class and their business chums and taking local people for every penny and leaving them with nothing except fractured communities built on contaminated land.In achieving this cruel vision it will no doubt supplement the income of people who register companies for tax avoidance purposes in places like the channel islands and who will profit from such land sales.
As stated previously we totally reject all your proposals in table 2. We do not support building houses on employment land. We do not support building houses in regeneration corridor nine as it is unsustainable to live there with little employment land there already for those who are out of work living there. You appear here to be suggesting putting small existing businesses out of business on the say so of any individual who wants to build houses there instead.This whole process is open to wide scale fraud with multiple agents of the house building industry submitting "call for sites" in areas where they can make a killing.What democratic mandate does the BCCS have for doingthis? It is deplorable.
We reject "garden city" principles for the academia con job that they are.

The first and only test for those producing this plan, supporting it and passingit is thus- would you live in regeneration corridor nine next to a toxic waste lagoon containing many tonnes of white phosphorus that poisoned birds that landed onit?
The leader of Sandwell council does not even live in Sandwell,the black country, or the West Midlands, but Derbyshire.
How many of the black country local enterprise partnership live in the black country? The same question for Andy Street?
Ibought a house on the banks of this chemical dump. IItook me 18 months to sell it (at a massive loss which I'm still paying for now).So
glad I'm away from this now. Many nights sleep lost worrying about the health of my kids growing up with this in our back garden. We had meetings with the Environmental Health and Rhodia and were even interviewed by the press.
Nothing ever came of it. Strangest of all, none of this showed up on any searches when we purchased the property from Barratts and the hazardous waste signs disappeared from the gates while the properties were being sold.
Like Reply Message 0 2 2. Jul) at 22 52
This is the reality, not the flowery padded out garbage in this document which is just theoretical academic metropolitan elites telling the plebs how they should all live.The document is underhand and has been devised and serves underhand corrupt people and business interests.





Yes- Retaining employment land for employment use and not promoting existing land for housing, and then grabbing areas of green belt/open space to compensate.
A strategy where the views of local people are engaged in the decision making process and not chaired by political front groups who do not involve the local community. One such example in our

area is the so called ''Tipton Development group" - chaired (who knows by what mandate}, by a former disgraced labour councillor.
No one appears to know anythingabout this group orits "plan" .There is no public record of who they are.
Quite unbelievably, there is no mention of Brexit in the entire core strategy document and how this will impact the whole "vision" of needing more housingor if it will even be needed at all.As this will hopefully reduce migration from Eastern Europe,(and there is current evidence of many returning there}, the population projections are likely to be entirely inaccurate,and so what does the BCCS intend to do if there is a population decrease yet still plough on with building homes that will be empty?
Business is also of course another issue, and surely we need to retain land in existing areas rather than trying to build more elsewhere. Money to remediate areas of contamination may not appear from the EU, so what are your contingencies at that point up to 2036?
Virtually all of the policies in this document may be flawed or superseded by new legislation beyond 2019 and our thankful EU exit.
We would wish to be consulted on all aspects of this core strategy in the future, so please keep us informed.