Object

Representation ID: 12821

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

We have concerns in relation to the inclusion of the following public open space sites within the proposed Core Regeneration Area designation
Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway.

The Churchill Road urban green space area is critically important for the following reasons:
• • It provides an essential partly wooded urban green lung helping to significantly reduce harmful levels of air pollution: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing pockets of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of harmful air pollution from the M6 motorway network. It therefore helps to play a critical role in helping to protect the health of thousands of local residents living nearby. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• • Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Noise reduction from the M6 motorway: It forms a natural green space partly wooded buffer which helps to protect nearby residential communities, by reducing the levels of constant traffic noise from the M6 motorway network.
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). See further
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 29


• above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.

• • Helping support populations of protected wildlife species by providing an important wildlife habitat: This natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging habitat for different bat species.
• • Important wildlife corridor: This natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to the Pouk Hill natural green space area (located on the opposite side of the M6) and to the Reedswood Town Park natural green space area. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential areas by providing a large natural green space area with areas of mature broadleaved woodland.

Within the emerging Black Country Plan (BCP) (Review) (Autumn 2021) consultation document, Walsall Council are proposing to allocate part of this sensitive urban green space site (bordering Churchill Road) as an area for new-build industrial uses (new employment land). See the blue shading area on page 499 (Figure 19 - Walsall Spatial Strategy Plan) of the BCP (Review) (2021). We specifically object to this employment land allocation as, in our view it will substantially erode this areas urban green lung benefits, reducing its ability to mitigate harmful levels of air pollution Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 30

from the adjacent M6 motorway network. Re-developing this sensitive urban green space lung for either new employment land or new housing will minimise the extent of a key urban green space lung alongside the M6, potentially placing large communities at increased risk from air pollution. Rather than promoting this site as a potential development area, Walsall Council should be promoting large-scale tree planting across this area of urban green space to help maximise and improve its effectiveness at mitigating air pollution from the M6 and to help strengthen its wildlife corridor function.
The local residents living nearby, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act Legislation) and should therefore be identified (through a designated green lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Additional tree planting measures are required within this urban green space area for reasons explained below.
Public open space located North of Churchill Road and the Jane Lane School: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Churchill Road public open space area, including its pockets of natural green space woodlands
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Churchill Road public open space area should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 31


• help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 motorway should be given special recognition and planning policy protection on the main Policies Map within the emerging BCP (Review).
• • New tree planting should be actively encouraged across this wider urban green space site which is currently dominated by areas of open fields. Additional tree planting (using native tree species to help support biodiversity and therefore deliver net gains for biodiversity) is considered necessary to help strengthen this area’s performance and role as an essential urban green lung to help mitigate the effects of high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6. Expanding tree cover across this largely open urban green space area will help to support the health of nearby residential communities and reduce traffic noise from the M6.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically designated as a ‘Protected Public Open Space’ area.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with guidance in paragraph 102 of the Revised NPPF) (July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Local Importance for Nature Conservation (SLINC)’. This is considered necessary as the whole green space site warrants SLINC designation status given its ecological sensitivity.
• • The entire Churchill Road public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). This protection is necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with guidance in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Pouk Hill natural green space on the opposite side of the M6 motorway network and Reedswood Town Park natural green space area. The Churchill Road natural green space area forms part of the ‘stepping-stone’ natural green space network. This ecological network function needs to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 32


• be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of urban green space is protected for the benefit of thousands of local residents to enjoy for outdoor recreation purposes, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected, to help support biodiversity.