Making your comments

Please also see How to Submit your Comments
More help available here: Further Assistance


Before you submit comments:

(1) Make a note of the Site Reference number:

. you will need the individual Site Reference number for each site you wish to comment on
. Site Reference numbers appear on the Draft Policies Map (marked in orange) and also in Table 14 under development allocations in the Draft Plan

Site Reference numbers for main Stourbridge Greenbelt sites:
Allocated sites (to object to the inclusion of):
. Wollaston Farm (DUH217)
. Worcester Lane (DUH206, DUH207, DUH209)


To submit your comments:

(2) Go either to the Portal or the Comment Form:

For the Online Consultation Portal follow this direct link to ‘development allocations‘), and for the Comment Forms (please see here)

Follow step-by-step guide to Submitting in our How to submit comments page

For further assistance, please see Help and Assistance


To view comments that have already been submitted:
You can view comments that have already been submitted (with a delay for processing) on the Online Consultation portal
. click on the magnifying glass icon next to the site, chapter or policy.
Note: This can be done without logging in.
(this feature had not gone live at the time of writing)


Tips:
. you must include the Site Reference number for the site you are commenting on (or the document title and policy number if you are commenting on a policy).
. if commenting on a policy, note that the comments form says:
“It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.”
. relate your comment to planning issues
. support your comment with evidence as far as possible (this can be your own observations)
Note: All comments will be made public, alongside your name


Important: Don’t feel you need to make a lengthy and jargon-filled submission. It is far more important to actually make a comment, however brief, and that you use your own words, judgement and experience of the local area and how you believe development would affect you as a resident, your neighbourhood and local services, and the local environment.


Key points for Responses on Site Allocations:

Note: Please also see the section ‘What comments should I make’ in this document from the Wildlife Trust, which also contains a good summary of how sites were selected for allocation.

Impact on local services:
. schools (refer to particular schools, the capacity, distance from the site, estimate of the number of extra school places that would be required – can that be met?)
. doctors, dentists (difficulty in getting on lists, waiting times, difficulty with appointments), hospitals
. other community facilities such as leisure centres, community centres, other services you rely on
. distance from shops
. increased traffic if local services are not close by and you cannot walk or cycle

Traffic and transport:
. increase in vehicles on local roads (use a calculation number of 1.5 cars per house – how would this many extra cars affect area? where possible, talk about actual drive times, where bottlenecks and problem areas are)
. peak time traffic, how many cars per hour (estimate, or use figures if you have them)
. idling traffic, pollution and air quality, how this affects health
. noise pollution
. access for emergency vehicles
. parking issues
. commuting times to places people are likely to work (or distance to local stations)
. lack of opportunity for road widening or other improvements (or level of detail in the plan to take account of these factors: necessary infrastructure, how will they be funded or delivered?)

Loss of amenity:
. loss of open or countryside views, open nature of the landscape, beautiful and peaceful locations
. effect on the local character of the area
. loss of green space
. loss of Rights of Way, permissive paths, places to walk and enjoy the open area
. loss of recreational space, and areas for ‘natural play’ (describe how you use the space)
. distance you would have to travel to get to a similar site, how you would have to use your car to get there
. importance you and your family feel the site has to your physical and mental wellbeing
. reasons why you moved here, why you enjoy the area, and how you would be affected by development

Impact on the natural environment:
. loss of agricultural land (refer to the quality on your site)
. impact on local Geosites, SSSIs, SLINCS, SINCS, & priority habitats
. trees which you believe should have TPOs, hedgerows which you feel should be protected (give detail where possible)
. loss of habitat for wildlife, protected and endangered species (what kinds of wildlife are present on the site?)
. issues relating to flooding or surface water (instances and extent of flooding/surface water. Impact that has on homes or traffic)

Impact on the historical setting and archaeology:
. importance of the site or local area for its history
. potential loss historical or archaeological remains
. likely presence of further archaeological sites (lack of archaeological surveys of the Greenbelt)
. setting of local monuments (e.g. Hagley monument, Wychbury hillfort)

Sustainability of the development of the site:
. how can it be sustainable to build on a green field site? (i.e. one which has never been built on)
. comment on the ‘mitigations’ they suggest for removing trees, hedgerows, or building next to SINCs, SLINCS, etc. on this particular site

Green belt issues:
. refer to the five purposes of the greenbelt (Para 138 of the NPPF) and the extent to which your site contributes to that.

Housing need:
. for the homes proposed on this site – do they address the needs of local people, or commuters?
. would they help to get young local people on the property ladder?
. are the proposed houses likely to be ‘affordable’?
. would this development be in the right place, and at the right time?


Commenting on Policies:

Key Points for Commenting on Policies in the Draft Local Plan:

The easiest and most straightforward way to view and comment is via the
Online Consultation Portal which contains sections on all of the policies being put forward in the Draft Plan.

Alternatively you can submit comments via the Comment Form (see this page).

Policy issues which you may wish to comment on:

Housing need:
. unoccupied housing across the borough – what is being done to address this?
. do the homes proposed in this plan address the needs of local people
. do they help to get young local people on the property ladder?
. are the proposed houses likely to be ‘affordable’?
. would this development be in the right place, and at the right time?

Has consideration been given to likely changes in the way we will be working, shopping, and living in the post-Covid environment?
. greater numbers will be working from home in future
. resulting in diminished need for office space, or retail space
. likelihood that more brownfield will become available due to these issues?

Green belt issues:
. has enough work been done to bring brownfield land forward for development?
. suggest that brownfield land should be developed before any planning permission is given for greenbelt sites
. Green belt land is protected. What justification is there then for its release?
. have ‘exceptional circumstances’ been proven for the release of the greenbelt?
. is it justifiable to release greenbelt which has a ‘moderate’ or above level of harm?
. what justification is there to use the government’s standard calculation of numbers for housing need when it has been stated that these are just a starting point and local authorities can adjust according to the constraints of the green belt?

Ecological and climate emergency:
. is enough weight being given to this in the preparation of the Plan?
. sustainability of their transport plan – road transport a major contributor to the climate emergency
. necessity for green spaces to be accessible on foot or bicycle
. is enough weight given to nature over economic and social benefits of development?
. is enough protection being given to hedgerows and trees?

Sustainability:
. how can it be sustainable to build on green field sites? (sites which have never been built on)
. once it has gone, it has gone and can never be converted back.
. loss of natural habitat for wildlife
. negative effects on transport and energy use
. consumption of land for present-day perceived need resulting in the loss of these things, is not sustainable.
. comment on the ‘mitigations’ they suggest for removing trees, hedgerows, or building next to SINCs, SLINCS
. is it justified to assume one aspect can be ‘offset’ against another?
. does this plan ensure we are living within sustainable limits?
. NPPF definition of sustainable development which is: “development which meets the needs of the present without compromising the ability of future generations to meet their own needs”

Other comments about the consultation:

. what efforts have been made to contact difficult to reach groups?
. have local community groups, churches, governors of local schools, tenants and residents associations, been made aware of the plans? Was enough notification given to local communities?
. why were local communities not informed that they could have applied for Local Green Space designations to protect their sites?
. why is it so difficult to understand the process, and access the material.
. do you think enough has been done to inform and help local residents to respond to this process?

Link to Dudley’s Statement of Community Involvement


Additional information to help with your submissions:

Further documents page contains links to:
. the Evidence Base (reports used in preparation of the Draft Black Country Plan)
. Dudley Planning Policy documents on transport, environment, etc.
. Historical reports on a number of the affected sites (compiled for SSGB)
. the National Planning Policy Framework (NPPF)


Further Suggestions:

You may additionally like to consider how and why particular sites were selected. To do this, refer to the following documents:

Site Assessment Report
. this covers the site selection, assessment criteria and process
. an explanation of the red-amber-green system (RAG))
. a section on Green Belt selection (2.9 – 2.15, and Diagram 2)
. a section on Local Green Space Selection (2.16 – 2.22)

Appendix A – Dudley
This is the large document which contains all of the sites that were assessed, and includes:
. tables and site references for all sites
. list of sites not assessed, and why (Section A-2)
. maps of allocated and unallocated/rejected, by ward (Section A-3)
. sites assessed for housing and/or employment and selected (Section A-4)
. sites assessed for housing and/or employment and not selected (Section A-5)
. sites assessed for Local Green Space (Section A-6)
. individual tables for each site, rated under the RAG system (see above)

Page number reference for Selected sites in Stourbridge:
. Pedmore and Stourbridge East (Worcester Lane sites), from p. 96.
. Wollaston and Stourbridge Town (Wollaston Farm site), from p. 115.


For those that would like to examine the Evidence base which is referred to in the Draft Plan, please see Further documents page which links to reports used as evidence in preparation of the Plan (but that you are not invited to comment on), plus further background information you may find useful in composing your submission.


Disclaimer, please note: The information on these pages has been compiled by concerned local residents to the best of our ability. We do not have expert planning knowledge. We strongly advise you contact Dudley planning to confirm any information, and for any further help you may require.


To suggest edits or additions to this page please email us


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