Comment

Representation ID: 82

Received: 18/12/2023

Respondent: Dr Christine Farmer

Policy DLP34, Paragraphs 1 and 2 do not appear to give sufficient weight to the ‘Historic Importance’ of hedgerows as defined in the Hedgerow Regulations, 1997.

Policy DLP, Paragraph 3. I am concerned that this policy would permit hedgerow removal and replacement in exchange for achieving “a high quality site layout”. The policy doesn’t state whether the replacement hedge would be required to follow the same course as the original. If the line of the hedgerow is not preserved, valuable historic information may be lost; and the process would undoubtedly degrade the hedge’s ecological value (the ‘Wildlife and Landscape Importance’ defined in the Hedgerow Regulations, 1997).

In the green belt around Stourbridge alone, 21 hedgerows are of undoubted ‘Historic Importance’ under the Hedgerow Regulations, 1997. At at least 57 more are potentially of high ‘Wildlife and Landscape Importance’ (Research by K. James). Some of these hedgerows have recently been designated as SLINCs; and I believe that surveys of the remaining hedgerows would be beneficial.
Hedgerows on The Three Fields, also known as “Dunsley Fields”, Dunsley Road, Wollaston.

The hedgerow which forms the western boundary of The Three Fields between Dunsley Road and Westwood Avenue in Stourbridge is of particular concern. This marks an ancient parish, manor and county boundary which, since the late Anglo-Saxon period, has also delineated the NW edge of Clent and Halfshire Hundreds as well as a variety of civil and ecclesiastical administrative areas. The southern (straight) portion probably dates, at least, to the late 18th century, although some of the trees here appear to be considerably older. The northern (curved) portion seems to be a continuation of a pre-Conquest boundary to the north, defined by a linear earthwork referenced in a tenth-century charter. In 1300, the boundary of Kinver forest ran either along this hedge-line or very close to it.
References from research by Kevin James:

K. James, Stourbridge’s Western Boundary: A cornerstone of the historical landscape (2017),

http://www.stourbridgewesternboundary.kjdocs.co.uk/Stourbridge%20Western%20Boundary.pdf

K. James, ‘The Norman forest of Kinver: An analysis of the forest’s extent and place-names recorded in the Great perambulation of 1300’, Transactions of the Staffordshire Archaeological and Historical Society, LIV (2023), 1–31.

Comment

Representation ID: 89

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

Paragraphs 1 and 2 of Policy DLP 34 do not appear to give sufficient weight to the ‘historic importance’ of hedgerows as defined in the Hedgerow Regulations, 1997.

Paragraph 3 of Policy DLP 34 seems to suggest that it would be permitted for hedgerows to be removed and replaced with no guarantee that any historical course of a hedgerow would be maintained.

21 hedgerows in Stourbridge Green Belt are of ‘Historic Importance’ under the regulations, and at least 57 more are potentially of high ‘Wildlife and Landscape Importance’ (research by Kevin James).

The hedgerows of the “Three Fields”, Dunsley Road, Wollaston, should be surveyed.

The hedgerows of this site are of importance to wildlife, and may be eligible for protection as a SLINC (Site of Local Importance for Nature Conservation).

The hedgerows are probably “important” hedgerows as defined in the “Hedgerow Regulations” 1997, due to their Historic importance, and their value for wildlife.

Comment

Representation ID: 151

Received: 03/01/2024

Respondent: Mr David Anscombe

It is widely recognised that hedgerows form a vital habitat for wildlife and a corridor for many species to safely transit through both urban and rural areas.
Many are also of historic importance.
It is therefore vital that these should be preserved and, where possible, be surveyed and recorded to assist this.
I suggest that paragraphs 1 to 3 of Policy DLP34 fail to recognise this and give adequate weight to the need to preserve a resource that, once destroyed, can never be replaced.

Comment

Representation ID: 165

Received: 22/12/2023

Respondent: Ms Rosalind Partridge

Paragraphs 1 and 2 of DLP34 do not give sufficient weight to the importance of hedgerows as defined in Hedgrow Regulations 1997.

Para. 3 of DLP34 appears to suggest it would be permitted to remove and replace hedgerows with no guarantee that any historical course of a hedgerow would be maintained.

Removing these hedgerows would cause irreparable damage to wildlife and nature. They provide highways for wildlife and should be extended to ensure wildlife corridors are maintained. They are an invaluable resource for wildlife as well as providing much needed carbon capture. Work such as coppicing for maintenance should only be done in the autumn/ They are likely to be elidgible for protection as a SLINC: a site of local importance for nature conservation.

21 hedgerows in Stourbridge Green Belt are of Historical importance under the regulations and at least 57 more are potentially of high wildlife and Landscape Importance ( research by Kevin James). The hedgerows of the Three Fields on Dunsley Road should be surveyed.

Comment

Representation ID: 168

Received: 21/12/2023

Respondent: Dr Kevin James

Paragraphs 1 and 2 do not appear to give sufficient weight to the 'Historic Importance' of hedgerows as defined in the Hedgerow Regulations, 1997. The historic nature of some hedgerows contributes significantly to their value for two reasons: a) The patterns of hedges in the landscape provide important information for understanding historic land use, and b) the complex ecology existing within a hedgerow can take a very long time to mature, meaning that our more ancient examples are difficult to replace and, thus, should be more highly valued. I am concerned that DLP34, paragraph 3 would permit hedgerow removal and replacement in exchange for achieving "a high quality site layout". The policy doesn't state whether the replacement hedge would be required to follow the same course as the original. If the line of the hedgerow is not preserved, valuable historic information may be lost (point (a) above). And, in any case, the process would undoubtedly degrade the hedge's ecological value (the 'Wildlife and Landscape Importance' defined in the Hedgerow Regulations, 1997) (point (b)).

Reference has been made to the protection and need for surveys of the hedgerows around Stourbridge and particular reference to the Hedgerows around Three Fields including details of the historic importance of these hedgerows.

Comment

Representation ID: 182

Received: 19/12/2023

Respondent: Miss Yvonne Hands

Paragraph 1and2 of DLP34 do not appear to give sufficient weight to the 'Historic importance ' of hedgerows as defined in the hedgerows regulations 1997.
Paragraph 3 of DLP34 'suggests' that removal of hedgerows and replaced with no guarantee that any historical course of a hedgerow would be maintained may be permitted.
Stourbridge greenbelt has 21 hedgerows of Historic importance and at least 57 of potentially high ' wildlife and landscape importance.
The 'Three fields ' Dunsley road hedgerows give food and a home for a great variety of beautiful birds and many small animals and insects

Comment

Representation ID: 201

Received: 19/12/2023

Respondent: Mr Eric Hand

Part of the policy do not appear to have sufficent weight

Comment

Representation ID: 346

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

Policy DLP34, Paragraphs 1 and 2 do not appear to give sufficient weight to the ‘Historic Importance’ of hedgerows as defined in the Hedgerow Regulations, 1997.

Policy DLP, Paragraph 3. I am concerned that this policy would permit hedgerow removal and replacement in exchange for achieving “a high quality site layout”. The policy doesn’t state whether the replacement hedge would be required to follow the same course as the original. If the line of the hedgerow is not preserved, valuable historic information may be lost; and the process would undoubtedly degrade the hedge’s ecological value (the ‘Wildlife and Landscape Importance’ defined in the Hedgerow Regulations, 1997).

In the green belt around Stourbridge alone, 21 hedgerows are of undoubted ‘Historic Importance’ under the Hedgerow Regulations, 1997. At at least 57 more are potentially of high ‘Wildlife and Landscape Importance’ (Research by K. James). Some of these hedgerows have recently been designated as SLINCs; and I believe that surveys of the remaining hedgerows would be beneficial.
Hedgerows on The Three Fields, also known as “Dunsley Fields”, Dunsley Road, Wollaston.

The hedgerow which forms the western boundary of The Three Fields between Dunsley Road and Westwood Avenue in Stourbridge is of particular concern. This marks an ancient parish, manor and county boundary which, since the late Anglo-Saxon period, has also delineated the NW edge of Clent and Halfshire Hundreds as well as a variety of civil and ecclesiastical administrative areas. The southern (straight) portion probably dates, at least, to the late 18th century, although some of the trees here appear to be considerably older. The northern (curved) portion seems to be a continuation of a pre-Conquest boundary to the north, defined by a linear earthwork referenced in a tenth-century charter. In 1300, the boundary of Kinver forest ran either along this hedge-line or very close to it.

References from research by Kevin James:

K. James, Stourbridge’s Western Boundary: A cornerstone of the historical landscape (2017),

http://www.stourbridgewesternboundary.kjdocs.co.uk/Stourbridge%20Western%20Boundary.pdf

K. James, ‘The Norman forest of Kinver: An analysis of the forest’s extent and place-names recorded in the Great perambulation of 1300’, Transactions of the Staffordshire Archaeological and Historical Society, LIV (2023), 1–31.

Comment

Representation ID: 405

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF would question if criteria one is necessary in Local Plan policy as repeats other national legislation and protection. HBF are also keen to understand how this policy interacts with other policies on BNG and nature conservation, and viability. HBF suggest further flexibility is needed in the policy, for example hedgerow removal may be an essential to gain access to
a site, but BNG policies which require 10% net gain from the pre-development baseline so any loss would already have to be compensated. HBF suggest the Council should give more thought to how the suite of environmental policies are intended to work together so that developers are completely clear what is expected of them, and to ensure that the policies do not serve to
make development undeliverable. The interrelationships between the BNG policy and other environmental policies needs to be fully considered and explained.

Support

Representation ID: 655

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes this policy

Comment

Representation ID: 802

Received: 30/01/2024

Respondent: Historic England

DLP34. It would also be worth adding in a section in this policy about hedgerows as a heritage feature and when it will be necessary to safeguard these from development.