Comment

Representation ID: 886

Received: 24/10/2024

Respondent: Friends of Homer Hill Park

I support this. However, an important area of land north of Oldnall Road, Cradley, between Oldnall Colliery & allotments site, and housing in Two Gates, is not suitably shown on your maps. It includes the Flint Field and site of a Romano-British farmstead.
Few English Mesolithic sites have been identified. Here 6000 struck pieces of flint from the Middle Stone Age have been found. It is a Landscape Heritage Area and Area of High Historic Landscape Value.
The area of the farmstead is evidenced by 350 pottery shards and small finds dating from the first four centuries AD.

Comment

Representation ID: 923

Received: 20/11/2024

Respondent: Paul Young

I endorse the SLINC designation and TPO for the Clockfields green space and woodland and would like the
Local Green Space designation to be reconsidered as part of the plan.
"As my representation for Regulation 19 of the Dudley Local Plan Consultation I would like to please express
my full support for the designations below for the Clockfields green space and woodland:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of central designated public open space as Amenity space
I would also like to please request that the council reconsiders the decision for a possible Local Green Space
designation at the site as submitted during the Regulation 18 consultation and fully support any additional
protection measures and policies that could further protect the site for the benefit of the local community and
future generations such as Site of Interest for Nature Conservation (SINC).
I also request that the currently unmarked path from the end of Culverhouse Drive to the canal be designated a
formal Public Right of Way.
Regulation 19 of the Dudley Local Plan is under consultation, sadly our request under Regulation 18 for 'Local
Green Space' (equivalent to green belt protection) last year was turned down but we can still appeal that
decision. The revised LGS request was downscaled from all 4 green areas and wooded areas to just the middle
area of green space and adjacent patches at the end of Culverhouse Drive (as it needs to be one area as such).
Below is a summary and details of each of the 4 parcels of green space and woodland.
1. Mature woodland which has existed since well before the estate was built and covered by Woodland TPO
(TPO/0042/AMB) from 2011. Generally mature woodland is protected from development by Dudley Council
2. Same as above, the strip between the estate and Brettell Lane, mature woodland covered by the TPO.
3. The area of Public Open Space designated by Wrekin Homes as a condition of building the estate. The
trees are covered individually under the TPO. It is recognised as publicly accessible amenity space in the
council green space assessments. Amenity spaces and open green spaces like this aren't automatically
2
protected from development unless they have Village Green or Local Green Space designation (the latter is the
newer one).
4. Land planted as part of the Black Country Urban (Millennium) Forest which includes private open space on
the edges (Planning application P00/51751) due to land stability issues. This has both SLINC (Site of Local
Interest for Nature Conservation) status and the Woodland Tree Preservation Order to supposedly cover all
trees of any age and size. Potential upgrades would be SINC (Site of Interest for Nature Conservation) which
would offer further protection.
I've also included a map that might be of interest which is an overlay of the estate as it is now over an aerial
photo from 1963.

Comment

Representation ID: 924

Received: 21/11/2024

Respondent: Dennis R Whittaker

The only thing that I will question is the paragraph on so-called active modes of travel. Although such modes may be desirable, in most cases they are not practical - and I speak from a long lifetime of experience. Buses are unreliable and time-inefficient and no one in their right mind will waste precious time waiting, often in the cold and/or rain, for Buses that may not turn up or not connect with the next stage of the journey. Cycling is a good-weather and a leisure mode. Walking is a short distance mode. Cars are practical and efficient.

Comment

Representation ID: 971

Received: 07/11/2024

Respondent: Mr Martin Parker

I would initially like to make my representation in relation to the green space and woodland (Black
Country Urban Forest) in the Clockfields estate and fully support both TPO/0042/AMB and the Land
at Clockfields SLINC.
You may have already seen the publicity in the Birmingham Mail, Express and Star and Stourbridge
News in relation to the current planning application (P24/0312) and the great opposition to it e.g:

https://www.birminghammail.co.uk/black-country/dudley-council-officers-recommend-new30295699?

In reference to my previous request for it to be made a Local Green Space including the 2nd one
submitted for the size of the site to be revised and focussing more on the middle area I would like to
please appeal that refusal.

The key requirement for Local Green Space per planning policy I believe is that it is demonstrably
special to the local community. It was refused based on historical value based on the mining
history being typical of the area. I know of many other areas that were also mined heavily in the area
which are even given LNR status.

Owing to almost 300 objections from the local community and pending the outcome at committee
on Monday as well I would very much appreciate it if the level of protection afforded to the
Clockfields green spaces and woodland planted to commemorate the new Millennium be
reviewed. We were told by the council via our councillor Pat Martin in 2011 that the land would be
safe from development and never be built on. This was communicated to all estate residents at the
time and many remember this well. The TPO and SLINC status were well publicised.

I believe that as the NPPF states that historical value is just an example and not a requirement that
it shouldn't be the ultimate deciding factor in the LGS decision. There are other LGS sites and cases
where the land has been used similarly and others where say recreational value can't be
considered as there is no public access.

So I ask again for the council to please reconsider their position on the current level of protection
given to our much loved green space, open space and woodland which is very much needed in a
very urban and industrial area.

Our views are supported by many local councillors, the past and present MPs, the former Mayor of
the West Midlands, the Birmingham and Black Country Wildlife Trust and even one of the Vice
Presidents of the Wildlife Trusts.

Both Cat Eccles and Suzanne Webb fully support our campaign and oppose the development.

please find attached the revised LGS application submitted during the consultation last year
which I hope was received at that time. The initial one covered a much larger area including the
woodland alongside Brettell Lane and down to Coalbourne Brook which I realise wasn't appropriate
for a possible designation and the woodland at the East side of the site (SLINC area) may also not be
suitable although the designated public open space in the middle of the estate with the green space
surrounding the end of Culverhouse Drive as highlighted in light green in the attached with little or no
tree coverage I would like to be reconsidered please especially in light of the high level of public
support in desiring further protection for this location.

Comment

Representation ID: 972

Received: 17/11/2024

Respondent: Philip Guise

As my representation for Regulation 19 of the Dudley Local Plan Consultation I would like to please express my full support for the designations below for the Clockfields green space and woodland:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of central designated public open space as Amenity space
I would also like to please request that the council reconsiders the decision for a possible Local Green Space designation at the site as submitted during the Regulation 18 consultation and fully support any additional protection measures and policies that could further protect the site for the benefit of the local community and future generations such as Site of Interest for Nature Conservation (SINC).
I also want to request that the currently unmarked path from the end of of Culverhouse Drive to the canal be designated a formal Public Right of Way.

Comment

Representation ID: 976

Received: 18/11/2024

Respondent: Martin Holder

I fully endorse the SLINC designation and TPO for the Clockfields Green Space and woodlands and would like the Local Green Space designation to be reconsidered as part of the plan.

I would like to express my full support for the below designations:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of the central designated public open space as Amenity Space

Request the Council to reconsider the decision for a possible Local Green Space designation at the site, and any additional protection measures and policies such as Site of Interest for Nature Conservation (SLINC).

There is also a footpath, currently unmarked, from the end of Culverhouse Drive to the canal, which I would like to request to be designated a formal Public Right of Way.

Comment

Representation ID: 1015

Received: 24/11/2024

Respondent: Mr Mike Wyer

Number of people: 2

We wish to endorse the SLINC designation and TPO for the Clockfields green space and woodland
and would like the Local Green Space designation to be reconsidered as part of the plan.
As my representation for Regulation 19 of the Dudley Local Plan Consultation I would like to please
express my full support for the designations below for the Clockfields green space and woodland:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of central designated public open space as Amenity space
I would also like to please request that the council reconsiders the decision for a possible Local
Green Space designation at the site as submitted during the Regulation 18 consultation and fully
support any additional protection measures and policies that could further protect the site for the
benefit of the local community and future generations such as Site of Interest for Nature
Conservation (SINC). Also to consider the currently unmarked footpath from the end of Culverhouse
Drive to the canal to be made a Public Right of Way"

Comment

Representation ID: 1016

Received: 23/11/2024

Respondent: Ms Kerry Harris

Number of people: 2

fully endorse the SLINC designation and TPO for the Clockfields green space and woodland and
would like the Local Green Space designation to be reconsidered as part of the plan.
As my representation for Regulation 19 of the Dudley Local Plan Consultation we would like
to express our full support for the designations below for the Clockfields green space and woodland:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of central designated public open space as Amenity space
We would also like to request that the council reconsiders the decision for a possible Local Green
Space (LGS) designation at the site as submitted during the Regulation 18 consultation and fully
support any additional protection measures and policies that could further protect the site for the
benefit of the local community and future generations such as Site of Interest for Nature
Conservation (SINC).
We also request that the currently unmarked path from the end of of Culverhouse Drive to the canal
be designated a formal Public Right of Way.

Comment

Representation ID: 1034

Received: 28/11/2024

Respondent: Sandwell Council

Additional wording should be included at the end of paragraph 3.34 as follows:
Over the plan period, the Council will continue to regularly monitor the land supply position and keep under review any opportunities for additional supply within the borough. Mechanisms for such monitoring and review will include an annual Strategic Housing Land Availability Assessment (wherein density and other capacity assumptions can be reconsidered, and a Call for Sites undertaken); the Brownfield Register; forthcoming Design Codes, Masterplans, or any equivalent for specific areas or sites; the Housing Delivery Test Action Plan (where applicable); and the Authority Monitoring Report.

Comment

Representation ID: 1046

Received: 28/11/2024

Respondent: Mr Roy Burgess

Supporting the brownfield first approach to the plan.

Support

Representation ID: 1047

Received: 28/11/2024

Respondent: TfWM and WMCA

Overall, we support this plan with many of the proposals referenced, fully assisting with the West Midlands Combined Authority (WMCA) goals and aspirations as well as those within the agreed Core Strategy of the new West Midlands statutory Local Transport Plan (WMLTP5). We especially welcome the positive ambition for improving transport within Dudley, which outlines new opportunities within the coming years, and its bold intent for improving the transport system.

Comment

Representation ID: 1050

Received: 28/11/2024

Respondent: TfWM and WMCA

Part one – Dudley Local Plan Regulation 19 – General Comments

o The local plan makes no reference to residential streets being designed and restricted to 20mph.

Object

Representation ID: 1064

Received: 28/11/2024

Respondent: Bloor Homes

Agent: Harris Lamb

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

In light of the Council's need and the shortfall that the Council is faced with, Bloor do not consider that the Council has met its duty to cooperate. We urge the Council to enter constructive and productive discussions with the other HMA authorities, including Bromsgrove, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.
It is our view that the focus for addressing the shortfall in Dudley should be those authorities closest to them. Bromsgrove and South Staffordshire are the closest authorities with a meaningful ability to address the shortfall and with land available adjacent to the conurbation. The Bromsgrove plan review is still at an early stage and there is still plenty of scope to hold meaningful discussions to provide land to meet the needs arising in Sandwell.
We trust you take our comments into consideration, and we look forward to being notified of further stages of consultation on the Local Plan. If you have any questions or need to discuss, please do not hesitate to contact me.

Comment

Representation ID: 1073

Received: 29/11/2024

Respondent: Mr Mike Wyer

As my representation to regulation 19 of the Local Plan, I would like Local Green Space
and or SINC designation to be further considered by the council for the greater protection
of the Clockfields green space and woodland.

Object

Representation ID: 1089

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council will be well aware that the Government have recently concluded consultation on revisions to the Framework. The draft Framework includes transitional provisions that would apply should the Plan be submitted for examination prior to or within 1 month of publication. We understand that the Framework is due to be published before Christmas. As such, it is debatable whether the plan will be examined under the current Framework or the new Framework. As well as the transitional arrangements the draft Framework includes significant changes to Green Belt policies as well as the application of the standard method. Should the Council have to calculate its housing requirement using the updated standard method this would result in a significantly different figure to the one currently being promoted. Clearly, without second guessing what the final version of the Framework says and when it is published, should it be relevant to the preparation of the plan we would welcome the opportunity to work with the Council to resolve any issues that it may unearth and particularly if further land for housing is required as a result.

Barberry are promoting land for residential development at Swindon Road, Wall Heath, Kingswinford (referred locally as the Triangle site) and have previously submitted details of the site to the preparation of the Black Country Plan and previously representations to the Black Country Plan Preferred Options consultation that concluded in October 2021.

The Council are no longer considering the release of their Green Belt land as an option to meet its housing need, favouring exporting the problem to other yet undefined locations in the Housing Market Area (“HMA”). The current National Planning Policy Framework (‘The Framework’) states there is no requirement to review Green Belt boundaries when plans are being prepared, but it continues to allow authorities to choose to subject to demonstrating exceptional circumstances. However, it does place more of an onus on Councils to instigate this process and the weight of responsibility that comes with this should not be underestimated.

Barberry, therefore, object to the proposed strategy on the basis that the Council has not explored all the options available to meet the housing need and that it has land available in its administrative boundary to meet its identified housing need, including sites that it has previously supported as draft residential allocations in the Black Country Core Strategy review. We consider there are exceptional circumstances that warrant the Green Belt being reviewed and land released from it to help meet housing needs, which include the substantial social and economic impacts for thousands of local people and businesses.

Paragraph 60 goes on to conclude that in addition to any local housing need figure, any needs that cannot be met within neighbouring authorities should also be taken into account in establishing the amount of housing to be planned for. There is significant pressure across the HMA from constrained authorities who cannot meet their development needs within their administrative boundaries, with tens of thousands of homes and hundreds of hectares of employment land needing to be found. The number of authorities able to assist with this overspill in the HMA are limited and the evidence suggests they cannot be relied upon when the numbers they have proposed in their emerging plans to assist with addressing the overspill do not even scratch the surface. Consequently, where authorities have the land available, we consider they should be using this unless there is an overwhelming persuasive reason as to why that land should not be developed, with the argument that ‘it is Green Belt land’ not standing up to scrutiny, when it is inevitable that most of the overspill would need to be on land currently designated as Green Belt if the development needs identified are going to be met.

Further to the above, we consider that not only should Dudley be meeting its own housing need, but that it should also be assisting with meeting the overspill from other authorities, such as Birmingham, Sandwell and Wolverhampton, with whom it has a strong functional relationship and that it can provide the land in the locations to help meet the overspill from these authorities close to where the need is arising. We acknowledge that these residents might not fall in your administrative boundary, but when so many people stand to suffer from the lack of land to meet the development needs identified we would implore the Council to not allow administrative lines to stand in the way of helping these people. Accordingly, Barberry have strong reservations about whether the Council’s intended strategy is sound. The tests of soundness remain in the updated Framework as set out in paragraph 35. As it stands, Barberry consider that the Plan is not positively prepared in that does not meet the area’s objectively assessed needs and is not informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. In light of the failure to identify where and how the Council’s unmet needs are to be met we do not consider that the Council has met the duty to cooperate.

Support

Representation ID: 1090

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Table 4.1 sets out the Council's strategic objectives and priorities. We note Objective 1 is the conservation and enhancement of a natural and built environment including the strategic priority of addressing the climate and ecological emergency. We also welcome Strategic Priority 4 of fostering economic growth and investment and Strategic Priority 6 of creating thriving neighbourhoods by providing new and affordable homes in range of sizes, types and tenures to meet the Borough’s housing needs. Similarly, we welcome Strategic Priority 7 that seeks to deliver the resources, infrastructure and services to support growth. Barberry generally support the Objectives and Strategy Priorities of the Plan.
.

Comment

Representation ID: 1092

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

The Vision for Dudley sets out a number of areas that the Council wish to see achieved through the delivery of the Local Plan. These include making Dudley an attractive and desirable place to live, work and visit, having strong, inclusive resilient and thriving communities which enhance health and social wellbeing and providing a wide range of housing that will meet people's needs through their various life stages and is affordable to live in. We are generally supportive of the Vision in that it is aspirational and seeks to deliver the development needs of its residents over the Plan Period. We particularly welcome the intention to deliver a wide range of housing that will meet people's needs. Barberry supports the vision set out in the Plan.

Comment

Representation ID: 1097

Received: 29/11/2024

Respondent: Mrs Susie O'Dowd

I would like to submit my representation to Regulation 19 of the local plan to ask that the Clockfields
green space and woodland be given further protection by reconsidering Local Green Space or SINC
designation please

Comment

Representation ID: 1098

Received: 29/11/2024

Respondent: Mr Andrew O'Dowd

I would like to submit my representation to Regulation 19 of the local plan to ask that the Clockfields
green space and woodland be given further protection by reconsidering Local Green Space or SINC
designation please.

Comment

Representation ID: 1099

Received: 29/11/2024

Respondent: Ms Julie Tranter

Please can I make a representation to Regulation 19 of the local plan to request the Local Green
Space designation for the Clockfields open space be reconsidered for greater protection and or an
upgrade to SINC designation on the current Land at Clockfields SLINC

Comment

Representation ID: 1100

Received: 29/11/2024

Respondent: Mr Mark and Karen Grigg

Number of people: 2

Please can I make a representation to Regulation 19 of the local plan to request the Local Green
Space designation for the Clockfields open space be reconsidered for greater protection and or an
upgrade to SINC designation on the current land at Clockfields SLINC

Comment

Representation ID: 1101

Received: 29/11/2024

Respondent: Mr David Rothin

As my representation for Regulation 19 of the Dudley Local Plan Consultation we would like to
express our full support for the designations below for the Clockfields green space and woodland:
1) Land at Clockfields SLINC
2) Tree Preservation Order TPO/0042/AMB
3) Recognition of central designated public open space as Amenity space
We would also like to request that the council reconsiders the decision for a possible Local Green
Space (LGS) designation at the site as submitted during the Regulation 18 consultation and fully
support any additional protection measures and policies that could further protect the site for the
benefit of the local community and future generations such as Site of Interest for Nature
Conservation (SINC).
We also request that the currently unmarked path from the end of of Culverhouse Drive to the
canal be designated a formal Public Right of Way.

Comment

Representation ID: 1102

Received: 29/11/2024

Respondent: Mr Adam Harris

I wish to make a representation to Regulation 19 of the local plan to request the Local Green Space
designation for the Clockfields open space to be reconsidered for greater protection and or an
upgrade to SINC designation on the current Land at Clockfields SLINC.

Comment

Representation ID: 1103

Received: 29/11/2024

Respondent: Mr Brian Moore

Please can I make a representation to Regulation 19 of the local plan to request the Local Green
Space designation for the Clockfields open space be reconsidered for greater protection and or an
upgrade to SINC designation on the current Land at Clockfields SLINC

Comment

Representation ID: 1104

Received: 29/11/2024

Respondent: Mrs Charlotte Walker

I wish to make a representation to Regulation 19 of the local plan to request the Local Green
Space designation for the Clockfields open space to be reconsidered for greater protection and or
an upgrade to SINC designation on the current Land at Clockfields SLINC

Comment

Representation ID: 1105

Received: 29/11/2024

Respondent: James Bird

wish to make a representation to
Regulation 19 of the local plan to request the Local Green Space designation for the Clockfields
open space to be reconsidered for greater protection and or an upgrade to SINC designation on
the current Land at Clockfields SLINC.

Comment

Representation ID: 1106

Received: 29/11/2024

Respondent: Matthew Walker

I wish to make a representation to Regulation 19 of the local plan to request the Local Green Space
designation for the Clockfields open space to be reconsidered for greater protection and or an
upgrade to SINC designation on the current Land at Clockfields SLINC.

Comment

Representation ID: 1107

Received: 29/11/2024

Respondent: Ms Flora Bianco

I wish to make a representation to Regulation 19 of the local plan to request the Local Green
Space designation for the Clockfields open space to be reconsidered for greater protection and or
an upgrade to SINC designation on the current Land at Clockfields SLINC

Comment

Representation ID: 1108

Received: 29/11/2024

Respondent: Mr Roger Orchard

I wish to make a representation to Regulation 19 of the local plan to request the Local Green Space
designation for the Clockfields open space to be reconsidered for greater protection and or an
upgrade to SINC designation on the current Land at Clockfields SLINC.

Object

Representation ID: 1110

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Missed opportunities to specify the type of resilience, equitable access to nature, etc. Resilient natural environment and the benefits for people and climate resilience. In several places in the document “resilient” is mentioned, without a specification of the resilience to which this refers. Equitable access to green spaces and nature will help Dudley Council toward its ambitions of both the Dudley Health and Wellbeing Strategy 2023-2028 and the Dudley Climate Action Plan, as well as the Local Nature Recovery Strategy. Establishing a Nature Recovery Network will help to address biodiversity loss, climate change, and wellbeing.