Black Country Core Strategy Issue and Option Report

For over thirty years now, I have been actively involved with local Conservation and Environmental Issues, through my role as a founding member of The Halesowen Abbey Trust. Over that period, Dudley Council in conjunction with other Black Country Boroughs, has initiated and strengthend its environmental policies, regarding Green Belts and Open Land. In addition, a Countryside Management Plan was put in place, to support those Policies and to put in action, improvements to the Public Rights of Way,raising Public Awareness of our Green Assets and Wildlife, planting thousands of trees, production of Walk Leaflets, and involvement with Local Schools. The project has , and continues to be a huge success.

This year with the announcement of"The Black Country Core Strategy", all the previous thirty years support to uphold Green Belt Polocies, is now in danger of being totally disregarded.
The suggested proposals to build 22,000 homes and develope 300 Hectares of Industrial land in The Green Belt is contary to the Councils much respected established Policies, and is completly unacceptable.

Evidence submitted by the Council to support the Strategy can be challenged as follows;

"Meeting Housing Needs"

The housing requirements as quoted in the background evidence to the Strategy are stated as "trajections and projections" only, and assume that the population of The Black Country will rise at an alarming rate between 2016 and 2036. This assumed increase above the normal predicted growth pattern should not be accepted as a reason to prematurely release Green Belt.
Given the normal population growth pattern (which could decrease as well as increase) all future developments, and improvements to our infrastucture can be proven to be fully accommodated within the urban area. In addition to urban (or Brownfield) sites already identified , many other urban sites have not been identified across the four Black Country Boroughs .

"Supporting The Economy"

In the Core Strategy,s supporting evidence, it is stated the "The demand for Industrial Land has been declining over the years". This is a trend over the past several decades where traditional heavy industry has closed down , giving way to smaller and more specialised manufacturing concerns.
The figures for the Employment Land Assessments up to 2036 are quoted as"Only
indicative and are bound to change as land is developed or coming forward".
Elsewhere in the evidence it is suggested that by releasing Green Belt Land this will attract larger manufacturers and distribution centres. This statement is pure conjecture and contary to the evidence that requirements now are for smaller higher employment and specialised sites which all can be located within the urban area.

" Releasing Green Belt"

The Evidence in the proposed Core Strategy, to release Green Belt Land is not conclusive, and is largely based on assumptions and predictions.
There are sufficient sites within the Black Country Urban Area to accomodate all future development requirements and therefore there is no requirement to to consider releasing Green Belt Land.
This requirement and procedure needs to be removed immediatly from the Strategy .