Object

Draft Black Country Plan

Representation ID: 16194

Received: 11/10/2021

Respondent: David Jackson

Representation Summary:

WAH234 Land between Queslett Road, Doe Bank Lane and Aldridge Road, Pheasey.
West Midland Birds Club strongly recommend that alternative development sites are sought in order to prevent the loss of green belt.
The land at WAH234 supports breeding populations of [redacted]. All three species are Red Listed by the RSPB as species of national Conservation Concern mainly due to over-intensive farming practices.
There is a network of established hedgerows containing mature trees including oak and hawthorn across this designated build site.
Casual observations have noted 11 RSPB Red Listed bird species including [redacted]
Winter and breeding bird surveys will be essential to assess the importance of the land for Skylark, Yellowhammer and Lapwing.
It is WMBC’s position that the land provides an important ecological corridor between Walsall green belt and Sutton Park NNR.
The site is known to have [redacted], but due to public access being limited no proper survey has yet been carried out.
The land provides an opportunity to retain significant open space and create heathland habitats as identified in the Draft Black Country Local Nature Recovery Strategy.
Housing or other development would cause significant damage to the this valuable green corridor.
Current rules strengthen protection of Green Belt Land and ensure that whether it’s new homes, business premises or anything else, developers first look for suitable sites on brownfield land.
https://www.gov.uk/guidance/national-planning-policy-framework/13-protecting-green-belt-land
13. Protecting Green Belt land
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.
138. Green Belt serves various 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;(e) to assist in urban regeneration,
breeding habitat for Linnets and Yellowhammers and a range of commoner bird species.
Duty to Conserve Biodiversity 7.3 Section 40 of the Natural Environment and Rural Communities Act 2006 introduced a duty for all public bodies to conserve biodiversity in carrying out their work. The definition of biodiversity conservation included ‘restoring and enhancing’ a population or habitat as well as the protection of the existing resource.
Biodiversity and Planning 7.6 Planning Policy Statement 9: Biodiversity and Geological Conservation updates National planning guidance. There is a clear emphasis on enhancing as well as conserving biodiversity and local planning policy must be consistent with national, local and local biodiversity priorities and objectives. 7.7 Government Circular: Biodiversity and Geological Conservation- statutory obligations and their impact within the planning system. (ODPM Circular 06/2005) provides more detail on national planning requirements. It states that the effects of development on habitats or species listed as priorities at 33 national or local level are ‘a material consideration’ in the preparation of local planning policy and the making of planning decisions.

by encouraging the recycling of derelict and other urban land.

Proposals affecting the Green Belt are based upon the Biodiversity Reporting and Information Group Report, and UK LBAP Priority Habitat Descriptions (2008) published by the Priorities Species and Habitat Review Group, UK BAP.
Local Priority Species Any species at risk of significant decline due to a substantial threat to a highly specialised habitat. which is a good indicator or ‘flagship’ that highlights a conservation initiative to be put in place.
.Site WAH 234 appears to comprise part Lowland Dry Acid Grassland 4.24 Lowland Dry Acid Grassland is characterised by vegetation dominated by grasses and herbs on a range of lime deficient soils. These are derived from acid rocks, such as sandstones and pebble beds, and on superficial deposits, such as sands and gravels. This habitat includes open communities of very dry sandy soils, which may contain many annual species including Silver, Early and Wavy Hair-grasses, Mat Grass, Heath Rush, Harebell, Heath Bedstraw and bent and fescue grasses. 4.25 In Birmingham and the Black Country, examples of this habitat can be found at Barr Beacon (Walsall) and Sutton Park (Birmingham).
Site WAH234 also appears to comprise Grassland Lowland Meadows 4.20 This habitat is not restricted to grasslands cut for hay, but also takes into account unimproved neutral pastures where livestock, but more frequently, horse grazing is the main land use. Characteristic species include Black Knapweed, Greater Burnet, Pignut, Yellow Rattle, Cowslip, Bird’s-foot Trefoil and the fine-leaved grasses dominated by Crested Dog’s-tail with fescues and bents, and the fern Adder’s-tongue. 14 4.21 Birmingham and the Black Country contains areas of species rich grasslands but they rely on regular management. These meadows are usually small (1 – 3 ha) and occur singly, or in small groups, where they may be separated by established hedgerows surrounded by housing. Good examples can be found at Park Lime Pits (Walsall), The Leasowes and Illey Pastures (Dudley), Northycote Farm (Wolverhampton), meadows along the southern section of the River Cole and Woodgate Valley Country Park (Birmingham) and Sandwell Valley Country Park.
Hedgerows 4.32 A Hedgerow is defined as any boundary line of trees or shrubs over 20m long and less than 5m wide, and where any gaps between the trees or shrub species are less that 20m long. Any bank, wall, ditch or tree within 2m of the centre of the Hedgerow is considered to be part of this habitat, as is the herbaceous vegetation within 2m of the centre. All Hedgerows consisting of 80% or more cover of at least one woody UK native species are covered by this habitat. Ancient and/or species-rich Hedgerows usually pre-date the Enclosure Acts of 1720 to 1840. 4.33 In Birmingham and the Black Country, Hedgerow complexes can be found around the fringes of the conurbation; such as in the Sedgley and Illey areas (Dudley), eastern Walsall, northern Wolverhampton, Sandwell Valley Country Park (Sandwell) and Woodgate Valley Country Park . There are good mature hedgerows at site WAh234 which require protection from development. These hedgerows provide good
147. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.
EXTRACTS FROM THE BIRMINGHAM AND THE BLACK COUNTRY BIODIVERSITY ACTION PLAN 2010 - THE COUNCIL IS REQUESTED TO ACT REASONABLY IN PROTECTING THIS GREEN BELT LAND having regard to the habitat types and ecology at site WAH234.
The Birmingham and Black Country Biodiversity Partnership is supported by the following organisations: Birmingham City Council, Black Country Geodiversity Partnership, British Waterways, Dudley Metropolitan Borough Council, EcoRecord, Environment Agency, Forestry Commission, Groundwork, Natural England, RSPB, Sandwell Metropolitan Borough Council, Walsall Metropolitan Borough Council, West Midlands Fire Service, Wildlife Trust for Birmingham and the Black Country Wolverhampton City Council -
7.15 All public bodies represented on the partnership now have a duty to conserve biodiversity in carrying out their duties. Involvement in the preparation and implementation of the revised LBAP demonstrates the practical observance of the duty to carry out Biodiversity Action .
7.9 Conserving biodiversity- The UK approach (2007) sets out the approach to biodiversity action in the UK. The emphasis is on an ecosystem approach rather than on individual species and habitats. 7.10 Securing Biodiversity (2008) sets out Natural England’s framework for biodiversity action in England. The main change from previous approaches is the consideration of biodiversity at a landscape scale. 7.11 National Indicator 197: Biodiversity was introduced in 2007 and all local authorities have to report annually on the percentage of local sites which are under management. This indicator covers all SINCs and SLINCs in Birmingham and the Black Country.

Priority Habitats and Species within Birmingham and the Black Country National Priority Habitats 4.7 In England there are 56 habitats listed as Habitat Types of Principal Importance for the purpose of conserving biodiversity within section 41 of the Natural Environment and Rural Communities Act 2006. Of these, 22 have been recorded in Birmingham and the Black Country . The following habitat descriptions