Comment

Representation ID: 22

Received: 18/11/2023

Respondent: Miss Alana Moss-Deeley

- "Green spaces" are actually planted for nature and managed as such. For example, all native species, and areas of grass are left for wildflower meadows, only cut once a year after flowers have seeded
- Less mowing of green spaces
- Both general waste and recycling bins in these areas
- When local council come to lotter pick, again divide things like cans and plastic bottles to be recyed rather than just dumping it all together

Comment

Representation ID: 224

Received: 05/01/2024

Respondent: Dennis R Whittaker

Support but query paragraph 3.a. - I'm sceptical as to how that would work in practice.

Object

Representation ID: 561

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy DLP37 – Open Space and Recreation

5.9. This Policy requires proposals to recognise the values and functions of open space. In particular, the functions of specific importance in Dudley, which includes to improve the image and environmental quality of Dudley; defining and enhancing local distinctiveness; protecting and enhancing the significance of heritage assets and their setting; providing outdoor sport and physical activity facilities; and enhancing people’s mental and physical health and well-being.

5.10. It is considered that the policy as currently drafted, does not provide enough emphasis on the importance of access to open spaces, contrary to Paragraph 98 of the Framework, which states that access to a network of open spaces is important for health and well-being. It is therefore considered that the policy should specifically recognise that it is not just the provision and/or retention of open spaces that is important, but also whether these spaces provide usable and accessible areas.

5.11. In particular, it should be acknowledged that through the proposals for development on land at Corbett Hospital through application P22/1050, it was proposed that more than half of the site would have been provided as open space and green infrastructure. It is understood that the site is valued by the Council and local residents as an open space, however at the current time no public access is permitted. The development proposals would have addressed this through the extensive provision of open space proposed, which would be provided a new valuable area of open space for both new and existing residents, within the heart of the urban area and well connected to other parts of the green infrastructure network. It is considered that the policy should be modified to reflect support for opportunities to provide new, accessible, open spaces within the urban area.

Object

Representation ID: 577

Received: 21/12/2023

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy DLP37 – Open Space and Recreation
5.9.
This Policy requires proposals to recognise the values and functions of open space. In particular, the functions of specific importance in Dudley, which includes to improve the image and environmental quality of Dudley; defining and enhancing local distinctiveness; protecting and enhancing the significance of heritage assets and their setting; providing outdoor sport and physical activity facilities; and enhancing people’s mental and physical health and well-being.
5.10.
It is considered that the policy as currently drafted, does not provide enough emphasis on the importance of access to open spaces, contrary to Paragraph 98 of the Framework, which states that access to a network of open spaces is important for health and well-being. It is therefore considered that the policy should specifically recognise that it is not just the provision and/or retention of open spaces that is important, but also whether these spaces provide usable and accessible areas.
5.11.
In particular, it should be acknowledged that through the proposals for development on land at Corbett Hospital through application P22/1050, it was proposed that more than half of the site would have been provided as open space and green infrastructure. It is understood that the site is valued by the Council and local residents as an open space, however at the current time no public access is permitted. The development proposals would have addressed this through the extensive provision of open space proposed, which would be provided a new valuable area of open space for both new and existing residents, within the heart of the urban area and well connected to other parts of the green infrastructure network. It is considered that the policy should be modified to reflect support for opportunities to provide new, accessible, open spaces within the urban area.

Comment

Representation ID: 658

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of this policy.
We support the recognition of the wide value of open space listed under point 1:
f. mitigating the effects of climate change in accordance with relevant policies, through flood risk betterment, reducing potential urban heat island effects and providing opportunities for additional landscaping and tree planting;
g. preserving and enhancing diversity in the natural and built environment and preventing the fragmentation of habitat networks;
h. strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network;
i. providing outdoor sport and physical activity facilities, including footpath and cycle networks and areas for informal recreation and children’s play;
j. providing opportunities for people to grow their own food on allotments and encouraging urban horticulture; and
k. enhancing people’s mental and physical health and well-being.
Under point 3c on making more efficient use of the urban land, we advise that care should be taken to not lose biodiversity value in a drive for multifunctionality.
We welcome the inclusion of 3c iv on increasing accessible public open space and suitable recreational use of the Green Belt.
Page 5 of 9
We note that Dudley will move towards up-to-date local open space and recreation standards in terms of quantity, quality and access (3a). Reference should be made to the Accessible Natural Greenspace Standards set out in NE’s GI Framework. These state:
• Everyone has access to good quality greenspace close to home to meet Accessible Greenspace Standards, with a focus on access to greenspace within 15 minutes.
• Local authorities have at least 3 hectares per 1000 population of publicly accessible greenspace.
• Accessible greenspace meets the Green Flag Award criteria and achieve best practice in accessibility for all.
• Developers meet Local Authority requirements for accessible greenspace.
We welcome the inclusion of the reference to greenways in the justification. This could be included in the policy itself.

Support

Representation ID: 712

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust welcomes mention of canal corridors within para 11.73 and requests that they, and Policy DLP36 Canals, is also listed as a component within para 11.71.

Support

Representation ID: 782

Received: 21/12/2023

Respondent: National Trust

Policy DLP37 Open Space and Recreation
The National Trust looks after some of the most beloved open spaces in the country and is excited by the contribution that the 8 Hills Regional Park can make towards Dudley’s ambitions set out in paragraph 11.68 which state that open space should “deliver opportunities for safe, attractive, functional, linked, and accessible green spaces for people to exercise and play sport in and enjoy. These areas also promote the enhancement of the natural environment to support greater biodiversity, maximises benefits for health and well-being, helps to mitigate and adapt to climate change…”. We would recommend that the opportunity for residents to connect to nature should be included in this paragraph.
It is anticipated that the 8 Hills Regional Park within and on the edge of Dudley will provide open space that may be the nearest open space to existing and new residents of the Borough, and we concur with the approach set out in paragraph 11.71 which sets out that “it is important that open space and sports facilities, and places that people visit every day such as shops and schools, are located and designed so that people are encouraged to walk or cycle to them from their homes“. We have purposefully identified land to the south of the A456 and east of Wollescote for inclusion within the 8 Hills Regional Park boundary on the basis that improving access to greenspace in these locations would yield best access for existing communities that might not have adequate access to open space currently.
Whilst the 8 Hills Regional Park would not seek to create new open space, its intention is to improve access to existing spaces, as part of a wider partnership with member organisations, which could include Local Authorities such as Dudley Borough Council. This increased and improved access across open space that would link into a Regional Park would comply with the justification for the policy set out in paragraph 11.73, particularly in terms of the creation of “Greenways”, especially when considering the focus of our efforts to provide attractive and safe off-road links for active travel along wildlife corridors. We are in agreement that the restoration of towpaths, bridges, public rights of way and the creation of cycle and pedestrian links to enhance the greenway network should be high priority and this is what we will be seeking to achieve throughout the regional park, including the area in southeast Dudley. We are supportive of the approach that such enhancement will be sought through planning conditions and obligations.
We are supportive of the wording of policy DLP37 and consider that the 8 Hills Regional Park can go some way towards prioritising the existing green network for recreation and biodiversity and taking opportunities to strengthen and expand the network; significantly expanding community use of open space and recreation facilities; and providing opportunities to increase accessible public open space and suitable recreational use of the Green Belt. We are particularly supportive of the inclusion of the objective to make more efficient use of land by increasing access to open space and recreation facilities for all, including people with disabilities and other target groups with limited access at present, and expect that much of the work that we do in developing the 8 Hills proposals will be focused on this element.

Support

Representation ID: 804

Received: 30/01/2024

Respondent: Historic England

DLP 37. We support the heritage references within this policy.

Object

Representation ID: 836

Received: 19/12/2023

Respondent: Sport England

Support reference to Active Design but this should be referenced as guidance, not policy and should be included in the justification for other relevant policies within the Plan.

Part 1 of the policy should be amended to refer to the provision of informal facilities to distinguish from formal provision covered by Policy DLP38.

Concerned that the wording of parts 2 and 3a of the policy are not consistent with Policy DLP38, the NPPF para 99 and Sport England's Playing Fields Policy. DLP37 should be amended to make it clearer it does not relate to playing fields and built sports facilities.

Support references in part c of the policy.

Comment

Representation ID: 874

Received: 09/04/2024

Respondent: Severn Trent

Agent: Severn Trent

Green Open Spaces Policy
Development of flood resilience schemes within local green spaces will be supported provided the schemes do not adversely impact the primary function of the green space.
Supporting Text:
We understand the need for protecting Green Spaces, however open spaces can provide suitable locations for schemes such as flood alleviation schemes to be delivered without adversely impacting on the primary function of the open space. If the correct scheme is chosen, the flood alleviation schemes can result in additional benefits to the local green space through biodiversity and amenity benefits.