The Three Fields

PLEASE NOTE: WE ARE AWAITING INFORMATION FROM DUDLEY PLANNING ABOUT HOW TO COMMENT ON AN UNALLOCATED SITE. PLEASE DO NOT COMMENT ON THE THREE FIELDS UNTIL WE HAVE CONFIRMATION OF THE PROCESS.

In the meantime, you can read our Application for the designation of a Local Green Space, and see also the Historical Report compiled by Kevin James


The Draft Black Country Plan 2039 (Regulation 18) Consultation is now live
You can comment/submit representations until the deadline of 5pm on 11th October 2021


The Three Fields was NOT Allocated for development in the Draft Local Plan. However, there is still a long way to go before the Plan is adopted in two years time, and there is pressure on Dudley to find additional sites to meet its development needs during the lifetime of the plan. For this reason we recommend that you use the Public Consultation to demonstrate the importance to local people of this site by:

(1) Supporting the continued protection of the Three Fields
(2) Objecting to its not having been designated as a Local Green Space (LGS)

PLEASE DO NOT COMMENT YET ON THE THREE FIELDS – WE ARE TRYING TO CONFIRM WITH DUDLEY PLANNING WHETHER AND HOW WE CAN COMMENT ON REJECTED LGS APPLICATIONS.


Both these submissions can be made via the BCP Comments Form (but NOT via the Online Planning Portal, as the Three Fields is an Unallocated/Rejected site)

Please note:
If you are submitting a Supportive comment (1) for the continued protection of the site
AND an Objection (2) to Dudley’s rejection of the LGS application
Then you will need to submit Two separate comment forms.
The SITE ALLOCATION NUMBERS are also different for these two cases (see below)


How to comment (this is the same for case (1) or case (2)):
Go to the BCP How to CommentPage
click on the PDF entitled ‘BCP Comments Form‘, and:
. either download the writable form, complete it on computer, and email it to the address given
or print out the form, complete it by hand, and post it to the address given

(for further guidance on submitting via the Comments Form, please see Section 2 of our How to Submit Comments page).

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 any development of this site would affect you as a resident, your neighbourhood and local services, and the local environment.


(1) To support the continued protection of the Three Fields:

IMPORTANT: For this, use Site Reference SA-0076-DUD, as it appears in the main section of Appendix A: Dudley

We suggest:

. that you use the BCP Comment Form (from here: How to Comment)
. quoting the Site reference SA-0076-DUD
. site address: Three Fields/Dunsley Fields, Dunsley Road, Norton DY8 3LS
. select the option to ‘SUPPORT‘ (note: the form defaults to ‘neutral’ comment)
. refer to the document and section you are commenting on, which is
Appendix A:Dudley (Three Fields assessment report appears from p. 383)
— note that the Red indicates a barrier to development, Green indicates no barrier to development – see the explanation of the R-A-G system in Section 4 of the the Site Assessment Report

You may like to refer to these resources to help formulate your comments:
. our Key points for Responses on Site Allocations on this page
. BCP documents and policies on our Further documents page

Biodiversity:
. the Site assessment (from p. 383 here) states that there currently are No designations for the Three Fields. However it is also noted that the hedgerow is well-developed and that an Ecological survey is required. We suggest you support this survey.
. the hedgerows are likely to be important. Others locally were recently designated as SLINCs see this document and this location map.

Remember: the conclusion of the Site assessment was that the site is “NOT suitable for residential or industrial purposes” and the site was NOT allocated. Therefore you would be SUPPORTING this conclusion.


(2) To object to the rejection of the Local Green Space (LGS) designation for the Three Fields

IMPORTANT: For this, use Site ID 10511 as it appears in Section A-6: Sites Assessed for Local Green Space, within Appendix A: Dudley.

Background and case: Dudley Planning considered our application (submitted Aug 2020) for the Three Fields to be designated a Local Green Space. While a LGS designation would give no more protection than it currently enjoys as a Green Belt site, it would additionally demonstrate the importance of the site to the local community and identify its particular local significance (beyond it’s simply being ‘Greenbelt’)

The LGS application was assessed by Dudley planning, and their assessment is presented in a table from p. 535 of section A-6: Sites Assessed for Local Green Space in Appendix A:Dudley
. three Fields Site ID number here appears as: 10511
. site Address: Three Fields/Dunsley Fields, Dunsley Road, Norton DY8 3LS

The assessment results – the site meets all critera:
. the Three Fields site fulfilled all the Part A criteria (support from community, distance to community, site size, etc.)
. the site additionally fulfilled Part B criteria for Beauty, and for Recreational Value to the local community.
. Given that a site only had to fulfil ONE of the criteria in Part B, the Three Fields therefore meets national criteria for the designation of Local Green Space.

So why was the site not allocated as a Local Green Space?
The Summary section of Dudley’s assessment (p. 537) states: “the site does fall within greenbelt and is therefore already protected through greenbelt policy. The NPPF states: ‘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‘”. The sentence which follows this is somewhat confused, but concludes there would “not be any additional local benefits and that the site will be adequately protected by the current designations of the site.”

This above is in line with Dudley’s statement in Site Assessment sections 2.16 – 2.22 (from p.11) which reads: “As LGS’s are given the same protection as Green Belt, the NPPF makes it clear that a consideration should only be given to designating a site as LGS that is already designated as Green Belt when it would provide additional local benefit. Despite some sites potentially meeting LGS criteria where they are currently designated as Green Belt it was felt that designating them as LGS would bring no additional local benefit or protection to these sites, as they are protected by current policy” (section 2.21)

However this statement does not appear to take into consideration Government guidance on the designation of LGSs: In “Open space, sports and recreation facilities, public rights of way and local green space” (2014) it is stated that even if land is protected by Green Belt policy, a “Local Green Space designation could help to identify areas that are of particular importance to the local community” (Paragraph: 010 Reference ID: 37-010-20140306).

We disagree that there would be ‘no additional local benefit or protection’ given by a LGS designation for the Three Fields:

In Section 2.1 of our LGS application we set out our arguments for the need for a Local Green Space Designation for the Three Fields, in short:
. there is an ever-growing pressure exerted on local authorities to release Green Belt sites for development.
. 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, 11, Feb 2019, para.134)
. The Government believes that LGS designations will be of assistance to local planning departments in helping them identify sites within the Green Belt which do not meet other protected criteria (e.g. being a SSSI (Site of Special Scientific Interest)), but that are of significant importance to the local community, quotes:
“Local Green Space designation could help identify areas that are of particular importance to the local community” (HMG 2014, para. 10)
“Local Green Space designation is a way to provide special protection against development for green areas of particular importance to local communities” (HMG 2014, para. 5)


Therefore we suggest:

PLEASE NOTE: WE ARE AWAITING INFORMATION FROM DUDLEY PLANNING. PLEASE DON’T COMMENT ON THE THREE FIELDS UNTIL WE HAVE CONFIRMED THE PROCESS, AND THAT IT IS POSSIBLE TO COMMENT ON UNALLOCATED SITES.

. that you use the BCP Comment Form (from here: How to Comment)
. quoting the Site reference number 10511 (TO BE CONFIRMED)
. site address: Three Fields/Dunsley Fields, Dunsley Road, Norton DY8 3LS
. select the option ‘OBJECTION’ (note: the form defaults to ‘neutral’ comment)
. refer to the documents and sections you are commenting on, which are:
Section A-6: Sites Assessed for Local Green Space in Appendix A:Dudley
Draft Black Country Plan Site Assessment Report (sections 2.16-2.22)
. refer to the arguments and references above, to state that you believe there would be additional benefit in designating the Three Fields as a Local Green Space
. use the bullet points below, or refer to our application, to form your argument that the site is of local importance for its Beauty, and for Recreation, (or for any of the other criteria).

Bullet points: Beauty:
. the site has a 360 degree panoramic view
. has views across local countryside to Clent Hills and the Malverns, and across Stourbridge and beyond
. possible to view sunrise and sunset from the site
. lack of light pollution makes it a good place to view the stars at night
. rural in character, with views across neighbouring countryside
. tranquil, offering a place of peace and calm on the edge of the urban area
. mature hedgerows and trees filled with birdsong
. attractive to a number of wildlife species including bats, hedgehogs, bees and other pollinators
. there are plans for the development of the site as a wildflower meadow
. importance for the physical and mental health of local residents

Bullet points: Recreation:
. easily accessible site, located close to the residents who use it
. used for over 50 years
. popular with walkers, cyclists, and joins up with footpaths in wider area
. popular for keeping fit and ‘green gym’ activities
. used by dog walkers, and
. encourages a sense of community amongst the elderly and socially isolated
. provides a site for informal recreation, childrens’ game playing
. a site for nature study for local community groups and schools
. used for organised social activities such as bonfires, with future events planned

Please read our Application for the designation of a Local Green Space for further information. And see also the Historical Report compiled by Kevin James


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