SSGB response to BCP

Below is our Group Response to the Draft Black Country Plan, which was submitted to the Reg 18 public consultation in October 2021.

We also submitted a more detailed comment on the Local Green Space application for the Three Fields, which can be read here.


Site reference numbers: DUH206, Worcester Lane North, Stourbridge; DUH207, Worcester Lane Central, Stourbridge
DUH209, Worcester Lane South, Stourbridge.

We object to the allocation of the three Worcester Lane sites for the following reasons:

Area of High Historic Landscape Value (AHHLV): These sites lie in an AHHLV. Strategic Priority 12 is to “protect, sustain and enhance the quality of the built and historic environment.” See also Policy ENV5, p. 230. All three are green field sites with grade 3a agricultural land situated in a strongly rural landscape and contain public Rights of Way. Given the emphasis in Policy CPS3 on “heritage, recreation, agricultural and nature conservation value”, these sites should not be allocated.

Proximity to Site of Local Importance for Nature Conservation (SLINC): There is an adjacent SLINC, as well as mature trees and hedgerows, and I/we believe that no mitigation would be sufficient to be considered sustainable.

Green Belt harm: We disagree with the Green RAG rating of low/moderate for Green Belt harm for these three sites. There would be no clearly “defensible boundary” to this development (Policy GB1, and para 3.16). Development would also encroach on the open countryside between Hagley and Pedmore, going against at least three of the five purposes of the green belt (para 138 of the NPPF): (a) checking unrestricted sprawl, (b) preventing neighbouring towns merging into one another, and (c) safeguarding the countryside from encroachment.


Site reference number: DUH217, Grazing Land Wollaston Farm, Stourbridge.

We object to the allocation of Grazing Land, Wollaston Farm, for these reasons:

Public open space: The site is located within Community Forum 7, where there is a below-average quantity of open space. It was well-used in the past, before the public were excluded from the site. I/we believe the site should be re-opened to provide a much-needed green space in this area which could additionally be developed as a wildflower meadow.

Landscape sensitivity: This is a green belt, green field site, which although having no agricultural rating and defined as ‘urban’, falls within area S17 having high landscape sensitivity and a “sense of scenic rural character” (Dudley Landscape Sensitivity Assessment). It is my/our opinion that Red ratings for landscape sensitivity should be considered to constitute “significant planning constraints which cannot be mitigated”, despite the high levels of housing land which the BCP is seeking to meet.

Tranquillity: 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 are 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). This site should be assessed for tranquillity and protected under Policy GB1 (4) on protecting tranquil areas.


Site reference number: Site ID 10511, The Three Fields, Norton, DY8 3LS (site ID number as it appears in the Site Assessment Report, section A-6: Sites Assessed for Local Green Space, from p. 534).

We object to the Three Fields, Norton not being designated a Local Green Space for these reasons:

This is a comment on an unallocated site, which was assessed for a LGS Designation in the Site Assessment Report.

Local Green Space: This site meets all of Part A criteria, and sufficient of Part B criteria (Beauty, and Recreation) to meet national criteria for a Local Green Space. The Site Assessment summary for this site quotes the NPPF; “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”, and suggests that since the site is green belt, “there would not be any additional local benefits” in designating the site a LGS (p. 537 of Appendix A).
However, 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). 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’.

Designations: The site has mature hedgerows which should be surveyed. Other hedgerows in the locality recently received SLINC protection (Racecourse Lane SLINC, Norton).

Tranquillity: This site should be protected under Policy GB1 (4) on protecting tranquil areas as it fulfils the criteria listed above.