Object

Representation ID: 1339

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Borough's goal to connect and extend the Green Infrastructure network is supported, but the policy's requirement for a minimum 15m width is seen as arbitrary and lacking justification. The roles and functions of the Green Network, such as serving both as a wildlife corridor and recreational space, are questioned for potential conflict, especially in urban areas where some functions may be more suited to rural settings. The Council should balance enhancing the green network with other development needs, including housing and employment land. It is argued that sites like Corbetts Hospital could contribute to the green network while also supporting housing development with sensitive design and recreational space.

Object

Representation ID: 1394

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Borough's goal to connect and extend the Green Infrastructure network is supported, but the policy's requirement for a minimum 15m width is seen as arbitrary and lacking justification. The roles and functions of the Green Network, such as serving both as a wildlife corridor and recreational space, are questioned for potential conflict, especially in urban areas where some functions may be more suited to rural settings. The Council should balance enhancing the green network with other development needs, including housing and employment land. It is argued that sites like Corbetts Hospital could contribute to the green network while also supporting housing development with sensitive design and recreational space.

Support

Representation ID: 1409

Received: 21/11/2024

Respondent: National Trust

DLP51 Dudley Borough’s Green Infrastructure Network
We are supportive of the wording of policy DLP51, and are especially supportive of the reference to the Regional Park in paragraph 13.18.


As set out earlier in this letter, we wanted to provide the following rationale and further justification for the inclusion of the Regional Park within this policy. It is our view that the designation of the regional park and inclusion within the associated Green Infrastructure policy by Dudley MBC would reinforce proposed policies within the Local Plan, including DLP55
Historic Character and Local Distinctiveness of Dudley and DLP60 Areas of High Historic Landscape Value on the grounds that the purpose of the regional park would be to improve access to open space for the public, and enable nature recovery and enhancement. Furthermore, the regional park designation presents the opportunity to enhance Green Belt policy in the context of the emerging, revised NPPF and require any development that is proposed in the vicinity of or within the regional park to deliver meaningful, high quality green infrastructure to connect with the existing network.


With regards to specific features in Dudley that could be highlighted as significant within the regional park, I have identified that there is number of existing heritage designations in the area that could be further preserved and enhanced by their position within the regional park.


Wychbury Hill is geographically and historically one of the Clent Hills, being part of the wider hill range so a clear link to the established geography being presented as part of the regional park. It is also a significant geosite within the Black Country, which has its own draw of visitors. Wychbury Hill would be most westerly point in the regional park and would make sense as a visitor gateway to the regional park – various sources of funding could be explored to establish this.


Notable features at Wychbury Hill include Wychbury Hill obelisk – grade II* listed structure, previously at risk and rebuilt and restored in 2011 – visible from peaks in Malvern and Shropshire – links to Lickey Monument (also an obelisk). Wychbury Hill also contains Wychbury Ring, an iron age hill fort. Small bronze rings, including an Iron Age terret, were
found in the fort in 1884, and Roman coins and masonry have been found nearby, suggesting a possible site of a later Roman Villa.


It is noted that there are scheduled ancient monuments in the area – St Mary’s Abbey and associated earthworks, Halesowen Abbey. The designation of the regional park could highlight and bring attention to these important heritage assets and the identified Area of High Historic Landscape Value - contains the site of Manor Colliery, Lapal Canal and Tunnel.


It is understood that areas of Ancient Woodland are found in the area of the proposed regional park to be covered by Dudley, and given the National Trust’s recent success to develop a bid for a woodland creation opportunity, these areas could be preserved and enhanced by other woodland creation, as well as funding opportunities for other woodland enhancement and creation elsewhere in the regional park.


There are a number of Sites of Importance for Nature Conservation (SINC) in the area identified which again could be enhanced by their inclusion within a designated regional park, providing the opportunity to improve preservation of these special places and improve educational opportunities for visitors to the area, through the provision of signage which is likely to be delivered throughout the regional park.


As set out in our previous consultation response, we would recommend that the Regional Park is designated on the Policies Map. We do note however that the proposed Green Infrastructure Network specifically includes the Dudley portion of the West Midlands Green Belt, and this is indicated on the Policies Map. We do however consider that further reference to the Regional Park would further strengthen the opportunities that can be identified to support the Green Infrastructure network in Dudley and more widely across the West Midlands through the Regional Park.

Comment

Representation ID: 1420

Received: 29/11/2024

Respondent: Network Rail

Agent: CBRE Limited

Policy DLP51 – Dudley Borough's Green Infrastructure Network (pp303 to 304)

This Policy identifies the rail network as forming part of the Green Infrastructure Network (Policy criterion 1 (j)), and Part 3 of the Policy (criteria a to c) requires development to comply with the aims and roles of the Green Network and for development to complement and enhance this Network.

Some of the rail network within the Borough is covered by ecological designations, including Sites of Importance for Nature Conservation (“SINC”) and Sites of Local Importance for Nature Conservation (“SLINC”) which are subject to the provisions of Policy DLP31 (Nature Conservation) (pp. 212 to 214). Policy DLP31 protects these designations but does allow for exceptions to this protection where the strategic benefits of a development clearly outweigh the importance of a local nature conservation site and mitigation is provided, applying a hierarchy of minimisation, mitigation, and compensation.

Network Rail has prepared a national Biodiversity Action Plan (December 2020). This aims to strike a balance between safety, performance, and environmental outcomes. The importance of the railway for biodiversity, including in connecting habitats, is fully recognised, and supported by Network Rail. There is however a need to ensure the best balance between biodiversity objectives and the ability to maintain and improve the railway to keep it running safely and smoothly. It is not always safe or practical to avoid all impacts on existing biodiversity features as part of this balance, and in situations where certain on-site impacts are unavoidable, Network Rail will seek to create appropriate habitats elsewhere, (in the local area where possible), to mitigate for and offset any impacts, also having regard to national legislative requirements.

To ensure consistency with relevant strategic policies for the area and in broad accordance with the approach of Policy DLP31, which will also apply to relevant future Network Rail proposals, it is recommended that Part 3 of Policy DLP51 is expanded to acknowledge that there may be exceptional circumstances, such as safety and operational considerations concerned with the functioning of the railway, where proposals will be permitted which conflict with one or more of criteria a to c in Part 3 of the Policy.

Comment

Representation ID: 1499

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate previous comments to Regulation 18.

Welcomes inclusion of reference to canals. Request partner engagement with the Council in any forthcoming Green Infrastructure strategies. Provide advice on developer contributions to Green Infrastructure. Canals and associated facilities can contribute to Green Infrastructure. Plan should recognise Green Infrastructure improvements can come via a policy framework for securing these via the design and layout of a site and developer contributions. Ongoing maintenance is important and should be addressed in policy and considered at early stage of design.

Comment

Representation ID: 1559

Received: 29/11/2024

Respondent: Historic England

We would anticipate to see a reference to the historic environment within this policy, as a component of green infrastructure.