Object

Draft Black Country Plan

Representation ID: 17167

Received: 06/10/2021

Respondent: Ms Joanne James

Representation Summary:

Re: Black Country Plan WAH242 - Strategic Allocation Policy WSA.7

I wish to make you aware of a number of strong objections I have with regards to the above
Black Country Plan WAH242 and the proposed development of Green Belt land.

I am of the view the addition of 592 houses on our precious, irreplaceable, green land will cause unacceptable harm to neighbouring amenities and disrupt the quiet and peaceful character of the area.

My specific objections are as follows:

NON EXCEPTIONAL CIRCUMSTANCE. NPPF states that Greenbelt is to be protected and requires ‘Very Special Circumstances’ to be built on. There is nothing special about plans to build on unspoilt land just to meet housing targets. I question the use of a computer based algorithm to assess the housing needs which seem totally overinflated. Local Councils rather than the government are surely better equipped to judge housing targets for their particular area.

The projections assume the population of the Black Country will rise at an alarming rate from

2023 - 2039 well above normal growth and does not take into account that this could also decrease as well as increase

If growth were normal, all future developments and improvements to our infrastructure can be fully accommodated within the urban area. Brownfield First. Surely there is more than
enough Brownfield, old Industrial and windfall sites and developments that already have planning permission available to accommodate housing targets without the permanent destruction of Greenbelt.

In 2014 Walsall Council in a refusal decision of planning for 14 houses on the same land said: There is a plentiful supply of available housing land in Walsall without requirement of Green Belt. Sites with planning permission provide sufficient capacity to meet the boroughs housing needs well beyond 15 years including the additional NPPF 5% buffer. The loss of open space as a result of the proposed built development would have a significant detrimental impact to the character of the area which is defined by open countryside which contributes to the quality of the adjacent Arboretum which directly overlooks the application side.

I would also ask ‘has the pandemic changed the housing supply equation’. Working from home and shopping online have hollowed out many urban centres. Walsall in particular is full of offices and shops empty and unused. Could Walsall’s struggling high street and business zones with its good transport links be repurposed as residential neighbourhoods rather than our beautiful countryside.

An example of this would be Crown Wharf Retail Park. Many of the retail units are sitting empty why not relocate the remaining shops to the now deserted town centre, and use this site for housing with it’s excellent access to shopping, leisure and public transport.

HISTORIC CONSERVATION AREA. The development, due to its location and layout, would result in significant harm to the ‘openness of the green belt’ being visually prominent from the Arboretum which is Walsall’s flagship historic park and conservation area where visitors enjoy beautiful views in and out of the park.

The loss of ‘open space’ which contributes to the quality of the Arboretum would have significant detrimental impact to the historic assets of the park which is of a high local importance. Walsall Council should exercise their planning power to pay special attention and recognise the desirability of preserving and enhancing the character of this conservation area.

Walsall Council commented in the refusal planning for 14 houses on the same land said The loss of open space as a result of the proposed built development and incidental landscaping would have a significant detrimental impact to the character of the area which is defined by open countryside which contributes to the quality of the adjacent Arboretum which directly overlook the application side.

Many of the adjacent and surrounding properties postdate the formation of the park in 1840 and they form the framework of the park and as such are important contributors of the landscape.

Calderfields Farm which dates back to mid 1800’s and the surrounding green fields with its

Red Deer, Sheep and Cows forms an essential part of the setting of the arboretum. The development of 592 houses will not sit comfortably within the landscape.

PROTECTING OUR WILDLIFE. The BCP was developed before the pandemic hit, therefore it is out of date and needs to be revisited and reassessed. We have to take into account the dangers posed by climate change that has emerged. Now more than ever we need to protect our local wildlife.

The site itself is known to have the protected species of bats and Great crested newts also red deer, Tawny and Barn owls, woodpecker, skylarks, Nuthatches, kingfishers, buzzards, parakeets and many red listed bird species.

The proposed development site would sit in the middle of the Arboretum, Arboretum extension, Park Lime Pits and Hayhead (SNICs) which would destroy essential wildlife corridors and light overspill may negatively impact the bats and other wildlife causing destruction of habitats. The wildlife will perish as a result.

I would also point out that although the site is of highest ecological value there has been NO
ecological assessment of the site. As mentioned the site has protected species as defined by the
UK legislation and the development would cause potential harm to any populations of these species present on site and therefore are not in compliance with ENV1, ENV2, ENV3 & ENV4 of the BCP.

I also have concerns for the preservation of the ‘protected’ trees which surround the proposed development and the potential damage from heavy excavation equipment on the root systems.

FLOOD RISK. It is known that the Arboretum, the Aldridge Road and the proposed site have a history of flooding and concreting over the countryside will exasperate this.

The SFRA acknowledges that global climate change is having a huge effect. The proposed development may pose an unacceptable risk of causing detrimental impact to groundwater quality and potentially result in contamination to the brook and watercourses that lead to the Walsall Arboretum. SFRA notes a blockage scenario would flood parts of walsall including major infrastructure. I would NOT consider that the site meets the sequential test for flooding and the development is contrary to CC5 & CC6 of the BCP.

RESIDENTIAL AMENITY. The proposed greenbelt is an integral part of the landscape. Loss of the existing views from neighbouring properties would adversely affect the residential amenity of neighbouring owners. If developed on, this connection local people have with their natural environment, will be lost forever.


LOSS OF PRIVACY AND OVERLOOKING The proposed development will have an adverse effect on both loss of privacy and overlooking ‘Cramming’ 592 houses on the plot will mean being uncomfortably close to neighbours and this will allow very little space for planting and landscaping and the gross overdevelopment of the site would significantly alter the fabric of the area resulting in a serious invasion of privacy.

TRAFFIC GENERATION/SECURITY
Traffic generated from the proposed development
would have an adverse effect on the area in particular the island from Buchanan Road and the Mellish Road. This already has severe congestion during busy hours. Air quality and noise pollution will also be an issue.

Access from the Arboretum to the proposed development would surely offer poor levels of security and would raise a fear of crime in the area.

Finally, the coronavirus pandemic exposed how important good quality outdoor green space is for our physical and mental wellbeing. With work-from-home becoming the normal, people have been re-evaluating their lives and as a consequence popularity of rural and coastal properties have seen people moving away from towns in search of a better quality of life.

If Walsall Council agree to the proposed building on our valuable green belt land and permanently concretes over the countryside, the urban sprawl will encourage residents to migrate from the town to the countryside.

Good quality green space should be accessible to all, now more than ever. Nature needs green space to thrive and our access to nature needs to thrive too.

The Priority 6 of a ‘Vision for Walsall’ says 'encourage everyone to feel proud of Walsall.’

Leader of Walsall Council Mike Bird says Walsall is a place to be proud of. We should be
Proud of our Past our Present and our Future. How can we feel proud of our present and for our future generations when the BCP allows the permanent destruction of our beautiful countryside.

Once our green space is gone it’s gone forever.