Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 87

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

support the policy to maintain a strong Green Belt to promote redevelopment and regeneration within the urban area.

Comment

Representation ID: 88

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

m concerned that there has been no clear procedure advertised that would have enabled local residents to submit suggestions for Local Green Spaces (LGS) during this process.

During an earlier consultation we were informed that the LGS application that had been submitted for the Three Fields was going to be rejected, despite the site meeting all necessary criteria and with enormous public support for the designation. The reason given was that the Three Fields is already designated as Green Belt.

The fact that a site is Green Belt is not sufficient protection in these times of enormous pressure on local authorities to build housing. And the policy Dudley is proposing on Green Belt only goes so far as to say they will not build on green belt "where possible" (Policy DLP49 Green Belt).

Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise… the community value of land” (Neighbourhood Planning, 2019, para.134).

Government guidance on LGS designation states that an LGS designation helps Local Authorities to "identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

A LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘Green Belt’.

For these reasons, I strongly believe that The Three Fields should be granted a Local Green Space designation.

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.

Support

Representation ID: 345

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

Save Stourbridge Greenbelt supports this policy to "maintain a strong Green Belt to promote redevelopment and regeneration within the urban area.”

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: 347

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

THREE FIELDS LGS DESIGNATION

Save Stourbridge Greenbelt comments that there has not been an promoted means for the public to put forward local sites as 'Local Green Spaces'. We believe that there should be a Local Green Space Designation for the “Three Fields”, Dunsley Road, Wollaston, also known as “Dunsley Fields”.

Please also see attached document in support of a Local Green Space designation for this site.

Criteria Part A. The Three Fields meets all of Part A criteria for a Local Green Space, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application. The site is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations.

Criteria Part B. The site meets two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’. It forms part of a wider green corridor and offers walkers access to the wider countryside. It is used by dog walkers, and encourages a ‘sense of community’ amongst the socially isolated. It is very popular with children, for informal recreation, games, and nature study. The site has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

Importance of a LGS designation even for sites within the Green Belt: The NPPF states that: “if land is already protected by Greenbelt Policy then consideration should be given to whether any additional local benefits would be gained by designations as local green space”. Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise… the community value of land” (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘green belt’. This site should therefore be granted a Local Green Space designation.

Tranquility: The NPPF states that planning policies should “identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason” (NPPF 2019, para 180(b)). The government guidelines on what constitutes a tranquil place is that it is “relatively undisturbed by noise from human sources that undermine the intrinsic character of the area” with a positive soundscape for e.g. of birdsong. (“Guidance: Noise”, HMG 2019, para. 8). The site is experienced as a natural space, and is described by visitors as a ‘piece of the countryside’. It is often possible to observe and listen to the sounds of farm animals in adjacent fields. It is possible to enjoy sunrise and sunsets, and because of Dark Skies, the stars at night. There are extensive views over local countryside, fields, woodland and distant hills. The dominant soundscape is that of birdsong.