Comment

Representation ID: 17184

Received: 29/09/2021

Respondent: Walsall Arboretum User Group

Our objection relates primarily to the proposed development of housing on the greenfield site
adjacent to the Walsall Arboretum. This area is denoted as Walsall BL31, with a proposal to develop
442 houses by 2039. (Page 495 of the black country plan.)
While this particular geographical area is of interest, it is part of the valley which links the Arboretum
through Rushall Canal to Hayhead, the Dingle, Cuckoos Nook and on to Barr Beacon. This area (8L31)
is thus part of a wildlife corridor of vital importance, and should not be considered in isolation. The
Black Country Core Strategy (2011) stated "fragmentation and weakening of wildlife sites and
wildlife corridors by development will be opposed" within the environmental policy ENVl (page 131)
Our objections are in two parts, firstly the need to protect the Green Belt per se, and secondly the
ability to mitigate biodiversity and habitat loss.

PART TWO Biodiversity and habitat
The document makes reference to net gain to compensate for losses describing Policy ENV3 ­
Nature Recovery Network and Biodiversity Net Gain. (Page 213) while seeking that "All development
shall deliver a minimum 10% net gain in biodiversity value when measured against baseline site
information". There is recognition of the challenges in para 10.49; it can be challenging to establish
new habitats. It is essential that the most important and irreplaceable habitats in the Black Country
are protected, and so mitigation rather than retention will not be appropriate in some circumstances.

We would suggest that mitigation will not be appropriate in this particular circumstance. The
following account of bird life prepared by Walsall Arboretum User Group members, which includes
birds of concern suggests that retention is by far the best strategy. [REDACTED-SENSITIVE INFORMATION] feed in these field nearly on a daily basis. In the autumn and winter months and leading up to spring large flocks [REDACTED- SENSITIVE INFORMATION] aIso use these fields on a daily basis. Flocks [REDACTED- SENSITIVE INFORMATION] inhabit the treeline and hedge between the Arboretum and the fields and the fruiting hedge between the two fields. This hedge acts as a useful food source in the autumn and a roosting sight
for winter [REDACTED-SENSITIVE INFORMATION] birds are RSPB Red Listed species (Birds of Conservation
Concern 4 (BoCC 4)) and are categorised as sharply declining and of major concern. Indeed, we have
noticed falling numbers of these species over the last 20 years as it is. Fields [REDACTED-SENSITIVE INFORMATION] represent some of
the avian biodiversity in this wider landscape, all linked in with the new housing developments
areas. All these species above are unlikely to survive the further encroachment of built-up areas.
We could offer similar accounts of wildflowers, butterflies and insects, but suggest the bird life
account may be proxy for all.
Policy ENVI -- Nature Conservation states
Development within the Black Country will safeguard nature conservation, inside and outside its
boundaries, by ensuring that: a) development will not be permitted where it would, alone or in
combination with other plans or projects, have an adverse impact on the integrity of an
internationally designated site, including Special Areas of Conservation (SAC), which are covered in
more detail in Policy ENV2; b) development is not permitted where it would harm nationally (Sites of
Special Scientific Interest and National Nature Reserves) or regionally (Local Nature Reserves and
Sites of Importance for Nature Conservation) designated nature conservation sites; c) locally
designated nature conservation sites (Sites of Local Importance for Nature Conservation), important
habitats and geological features are protected from development proposals that could negatively
impact them; d) the movement of wildlife within the Black Country and its adjoining areas, through
both linear habitats (e.g. wildlife corridors) and the wider urban matrix (e.g. stepping-stone sites) is
not impeded by development; e) species that are legally protected, in decline, are rare within the
Black Country or that are covered by national, regional, or local Biodiversity Action Plans will be protected as far as possible when development occurs.

We contend that the planned development contravenes this policy.
We thus strongly object to this proposal, and seek that Walsall Council and the Planning Department stick to their previously laudable aims of brown field first, protect the Green Belt, seek only
"exceptional" changes to their announced and adopted policy of supporting wildlife corridors, and
heed our plea.