Object

Representation ID: 15696

Received: 11/10/2021

Respondent: Natural England

Natural England objects to the above allocations. The above sites are in close proximity to Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve. Sutton Park is one of the most important wildlife site in West Midlands and is known as the green lung of the Black Country. It is a local destination green space for local people in maintaining their connection to nature thus supporting their mental health and wellbeing. A mosaic of habitats including ancient woodland, heathlands and wetland habitat. The wetlands are natural being ground fed but are affected significantly by sewage
and storm water mixing during high intensity rainfall. The wetland habitats here although severely impacted in areas by water pollution, are exceptionally rare in the Midlands and of better quality than those found at Cannock Chase. The topography of the land means that surface water and surface
water drainage which contains pollutants will flow down into the park area consequently compromising the site. It is imperative that any additional housing does not impact upon the wetland environment.

The following issues would need to be addressed for us to be able to remove our objection:

• Water pollution from foul drainage and surface water drainage

The Sutton Park SSSI is currently suffering from significant damage through urban water pollution (e.g. sewage and storm overflow mix during flooding events). The addition of these sites without proper mitigation will worsen an already dire situation.

• Recreational impacts

The SSSI currently suffers from significant recreational pressure. The increased scale of new housing might reasonably be expected to exert excessive pressure on the SSSI through added recreational visits. We advise the councils within the Black Country to review any existing
visitor surveys and commission a new one as necessary in order to identify if there is a threat to the SSSI. Policy in Black Country Local Plan will need to reflect evidence base/any moves to
better understand the situation e.g. alongside Birmingham City Council.

• Air quality. The site is currently exceeding ammonia, nitrogen deposition and acid deposition levels.

The site is highly urbanised in nature and air quality is already an issue for the site.

However these proposal sites also present an opportunity to maintain the vital wildlife corridor (green infrastructure) that links Barr Beacon Local Nature Reserve and existing surrounding green space. There is good green infrastructure connectivity here for bats along the railway corridor which must be maintained to facilitate bats’ movements across the borough. There are good green infrastructure opportunities to enable the Nature Recovery throughout this area.