Comment

Representation ID: 17186

Received: 29/09/2021

Respondent: Walsall Arboretum User Group

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.