Object

Representation ID: 11892

Received: 29/09/2021

Respondent: Mrs Roberta Owen

It is my belief that site ref SA-0078-WAL is not suitable for development of housing based on the following issues
Objection 1 – Green Belt THIS IS GREEN BELT THAT ADDS TO BEAUTY OF WALSALL ARBORETUM AND THE ENJOYMENT OF VISITORS WHO VISIT THE ARBORETUM
The proposed development of 592 houses on green belt land sits alongside Walsall Arboretum. It is the only stretch of the park with open field views of grazing animals and as such is particularly popular with families. The rest of the park is close bordered, the proposed development will destroy the openness of the views for all Arboretum users.
The NPPF July 2021 states:
137 the government attaches great importance to green belts the fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of green belts are their openness and their permanence
The proposals do exactly the opposite to this as the areas of Walsall , Aldridge and Streetly merge. Indeed, the site assessment rates the green belt harm as very high harm and high harm. the definition of this red RAG rating in the draft Black Country plan site assessment report: assessment and selection methodology and results is
“there is a very substantial negative effect or issue that is unlikely to be capable of acceptable mitigation”
The NPPF states:
138. Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built up areas;
b) to prevent neighbouring towns merging into one another
c) to assist in safeguarding the countryside from encroachment
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration by encouraging the recycling of derelict and other urban land.
The proposed development would directly contravene a, b, c and e and the NPPF also states that:
147. Inappropriate development is by definition harmful to the green belt and should not be approved except in very special circumstances.
148. When considering any planning application local planning authorities should ensure that substantial weight is given to any harm to the green belt. ‘Very special circumstances will not exist unless the potential harm to the green belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.
Objection 2 – Selection does not follow the Black Country Plan’s own methodology
Draft Black Country Plan Site Assessment report: Assessment and Selection Methodology and Results. Aug 2021, Chapter 3, Page 16, Paragraph 5 states:
“sites located in areas where development is likely to cause very high harm to remaining green belt and where landscape sensitivity to development is likely to be moderate-high or high have been considered not suitable for development”
Appendix C-4, Page 137 Sites Assessed for Housing and Selected (Walsall), St Matthews, Site Reference SA-0078-WAL has rated the site as follows:
Green Belt Harm: North East Very High Harm, West High Harm = Red
Landscape Sensitivity: Moderate High = Red
According to the Black Country plans own methodology this site is not suitable for development. Why has it been selected as suitable?
Objection 3 – there has been no Ecological Report and Bat Survey for the site
Draft Black Country Plan Site Assessment Report: Assessment and Selection Methodology and Results. Aug 2021, Page 18, Biodiversity and Geodiversity states:
“Existing council records inform the status. Ecological appraisals which informed local site assessments were carried out for the most sensitive sites and their findings are included in the assessment. impacts on local sites such as these can sometimes be mitigated by providing environmental enhancements to net biodiversity gain on the site or nearby land.”
Although this site is green belt assessed as likely to incur very high harm there has been no ecological survey of the site.
This site has:
- [redacted - protected species] (photographs available). The known sites exist on [Redacted-Ecology] the development site, so it is difficult to see how [Redacted-Ecology] the developers would avoid damaging or destroying [Redacted-Ecology] are a protected species.
- [Redacted-Ecology] this development will cause he loss or fragmentation of their habitat it will expose him to dangerous light pollution which in turn has ecological impacts; [Redacted-Ecology] being the principle predators of night time insects. [Redacted-Ecology] are protected species
- [Redacted-Ecology]
Currently there are unrestricted wildlife corridors from Calderfields Farm to:
- The Arboretum
- The Arboretum extension. The extension is a Site of Importance for Nature Conservation (SINC) and
- Stencils Farm, a Site of Local Importance for Nature Conservation (SLINC)
Additionally, Park Lime Pits to the North West of Stencils Farm and Hayhead Wood are local nature reserves, SINCs and Hayhead Wood is an SSSI. These areas provide an even greater biodiversity and also form part of the UNESCO global geopark. These sites surrounds Calderfields so the development of 592 houses will destroy the wildlife corridors and the light and noise pollution will significantly and negatively impact the wildlife in each of these sites
the Wildlife and Countryside Act 1982 and the Conservation of Habitats and Species Regulations 2017 all demand that the local planning authority request a detailed ecological survey including a bat survey before any decisions are made. This can also take account of any pond life butterflies etc.
The Black Country Plan Site assessment report, assessment and selection methodology and results (August 2021) defines an Amber RAG as “There is a moderate negative effect or issues which may be able to be adequately addressed but only subject to mitigation.”
This alone should be enough to demand that the ecological report was completed before the site was selected.
Objection 4 – the concept of a ‘call for sites’ on green belt land is flawed
It is common knowledge that it is more expensive and challenging to build on brownfield sites. It is more profitable to build on green belt. When green belt land is made available developers will choose to develop it ahead of brownfield. So the concept of a call for sites including green belt land actively discourages redevelopment of brownfield sites
Objection 5 – Brownfield First (Two source documents: Brownfield Land Register supplied by BCP and Walsall Brownfield Register 2017-12-29_for_web)
There are 100 Brownfield sites listed on the more recent register providing a total dwelling figure of 3,100.
Of the 100 sites on the register they are all annotated ‘First Added Date’ of 29-12-2017. One item says it was added 20-03-2020 and yet strangely it received planning permission 17-01-2019. So there have been no new sites added to the Brownfield register since 2017.
Brownfield Sites given Permission
41 of the brownfield sites on the recent register have permission for development (1169 dwellings)
Permission was given: 2015 – 7 sites, 2016 – 13 sites, 2017 – 13 sites, 2018 – 1 site, 2019 – 2 sites, nothing since although 5 sites have no date stating when planning permission was given.
15 of thes e41 sites on the recent register have not been updated since 29-12-2017
3 sites are under construction (50 homes). 6 sites have completed (76 homes).
So basically, no new sites have been added to the register.
Brownfield Sites without Planning Permission
There are 59 sites without planning permission (1487 dwellings) of these 37 sites are annotated ‘planning permission expired’ (599 dwellings) or 59 sites were transferred from the 2017 register. 56 of these sites have not been updated on the register since 2017.
Additionally I am told by the BCP team that the Walsall town centre health check indicates that as at July 2019 26.5% of retail units were vacant. I am sure this is significantly higher now. Walsall town centre is dead. The 2019 index of multiple deprivation ranked Walsall as the 25th most deprived English local authority out of 317 placing Walsall within the most deprived 10% of districts in the country (33rd in 2015, 30th in 2010 and 45th in 2007) everyone can see the pattern. There has to be opportunity to develop parts of Walsall town centre to provide family homes positively impacting access to services climate control (less cars), town centre etc, etc.

Andy Street, Wendy Morton, Valerie Vaz, Mike Bird have all gone on record opposing building on green belt sites but still the proposals move forward
“Our policy of tackling the many contaminated sites within the borough would allow much needed quality housing to be built on these brownfield sites, while protecting our precious green belt.” Mike Bird in April 2016 when he was campaigning!
Finally a quote from CPRE “there are unbuilt permissions for 1 million homes already, according to Government data analysed by the Local Government Association. (https://www.theplanner.co.uk/news/research-morethan-a-million-approved-homes-not-built). We also note that in 2016 there were half a million unbuilt permissions (https://www.theconstructionindex.co.uk/news/view/half-a- Changes to the Planning System CPRE Response 30 September 2021 Page 5 of 21 million-unbuilt-homes-industry-reacts) so this number has doubled in four years.”
I am not sure of the homes referred to here are Brownfield but I assume they are.
Objection 6 – Infrastructure
Existing road school and health facilities cannot support this additional housing. 592 homes will potentially create another 900 plus cars. The plans state that access could potentially be via either the Aldridge Road or Buchanan Road. Buchanan Road is currently a residential road that is not a through road. Residents were not advised at the potential impact by BCP. Neither road could cope with the additional traffic as current commuters will attest. The traffic jams in the area attest to the fact that the infrastructure does not exist to support this proposal. There are already insufficient school places and doctors’ appointments.
Objection 7 – Sprawl
The green belt developments in the BCP blur the boundaries of Walsall, Aldridge and Streetly.
Objection 8 – Flood and drainage
The Arboretum, the Aldridge Road and the proposed development site all have a history of flooding. Hard surfacing of the development site will aggravate the existing flooding issues. The subsequent flooding and drainage issue costs will ultimately be borne by Walsall Council long after the developers have disappeared.
Objection 9 – The basis of the number of dwellings required: CPRE – Changes to the Planning System CPRE Response 30 September 2020.
“Reliance on centralised prescription and formulae instead of on judgement and local evidence. They will prevent local authorities and local communities from establishing appropriate quantities and types of housing provision that are relevant to localities”.
it is not realistic for a nationally based mathematical formula to generate these outcomes, which can only be determined at pursued using local knowledge.”
These extracts say it all.
Objection 10 – Consultation
Is it really acceptable to call this a consultation where none of the impacted residents were specifically advised of the development I E the information was available online and in libraries but how are people expected to know that the information existed? Available in libraries is also contentious as a number of concerned people have been unable to acquire comment forms in either Walsall or Aldridge libraries
As a resident at Calderfields, I was notified when the golf driving range wanted to build an adventure golf course but it wasn’t important to tell me and my neighbours of proposals to build 592 homes around our homes.
The spirit of this consultation causes distrust and suspicion. It doesn’t feel like consultation and it does feel like a done deal. We say ‘why haven’t you done an ecological report and you say ‘we can do it later and then build in mitigation’, in other words we always find mitigation and this is a done deal. Shame on you.
your version of consultation appears to assume that development of some sort will go ahead and you seek the mitigation needed to make it happen rather than asking is it desirable?