Object

Representation ID: 17799

Received: 11/10/2021

Respondent: Mr Mark Boden

Re: Proposed Large Housing Site (Strategic Allocation) WAH237 – Land north of Stonnall Road, Aldridge

I am writing to express serious concerns at the proposed release of around 300 hectares of Green Belt land as part of the Spatial Strategy for Walsall included within the current consultation on the draft Black Country Plan.

The proposed Spatial Strategy for Walsall provides only 59% of its future housing allocation on brownfield land, and with some 41% of housing provision due to come from sites currently in the Green Belt this could seriously undermine regeneration of the urban areas.

Whilst I realise that there is only a finite amount of brownfield land available, the amount of new homes provided on available brownfield sites could be raised by increasing densities.

With regard to Proposed Large Housing site WAH237, land north of Stonnall Road, Aldridge, there are a number of reasons why this land should not be allocated as a housing site within the Black County Plan. These are as follows:

Green Belt

The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Green Belts, and that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.
This land performs the Green Belt purpose of assisting in safeguarding the countryside from encroachment and clearly housing development on this site would result in an outward sprawl of the urban area of Aldridge, contrary to the advice of the NPPF.
It is noted that the 'Green Belt Study', forming part of the Plan's evidence base, classified this area of land as having a 'harm' rating of 'High' i.e. that a potential high level of harm will be caused by removing this parcel of land from the Green Belt.
The NPPF advises that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, following appraisal of all alternative options.
I consider that Walsall Council should look again at the alternative options to release of this Green Belt land; alternatives which the NPPF sets out as including whether as much use as possible has been made of suitable brownfield sites and underutilised land; optimising densities in town centres and areas well served by public transport; and by accommodation of housing growth by neighbouring authorities under the Duty-to-Cooperate.

Loss of Agricultural Land

The land is classified as Grade 3 and is therefore some of the best and most versatile agricultural land in England and is constantly under crop.
The NPPF advises that where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of higher quality.
Development for housing on this site would mean the permanent loss of this highly productive agricultural land.

Historic Landscape

The site evidently contains and is bordered by ancient hedgerows.
The 'Birmingham and Black Country Local Sites Assessment Report', that forms part of the evidence base to the Black Country Plan, notes that the site comprises a field system with hedgerow boundaries that has changed little since 1840.
Additionally, the Report notes that the surrounding rural land has connections to medieval ridge and furrow ploughing practices.
The historic landscape of this site contributes significantly to the character and setting of this rural edge of Aldridge and housing development would adversely impact on the character and distinctiveness of this area.

Habitats and Biodiversity

Whilst the site is not designated as being of importance for nature conservation, the historic hedgerows provide habitats for a variety of wildlife, including foxes, squirrels and many bird species.
New data released only yesterday, 10th October 2021, as part of a report by MPs on the Environmental Audit Committee, shows that the UK is one of the world's most nature-depleted countries.
Whilst it may be possible to retain some of the hedgerows and develop the site for housing, it is very unlikely that these ecological networks will not be damaged, and biodiversity further depleted.

Visual Impact

There is an intrinsic character and beauty to this area of countryside, and from the most northerly boundary of the site are the most amazing long views of Lichfield Cathedral and Staffordshire, even stretching as far as the Derbyshire border on some days.
It is noted that the Sustainability Appraisal, which accompanies the Black Country Plan, states that the site was selected for housing development due to "limited visual impact". This is clearly not the case as the land rises towards both the northern and southern boundaries of the site and housing development on this land will be very visually intrusive.
I would recommend that site visits and a full Landscape and Visual Impact Analysis are undertaken, in order to fully appreciate the visual impact that will result from the development of this site.

Minerals

It is noted that the site is in a proposed MSA and that Policy WSA3 states that prior extraction for bedrock and superficial sand and gravel, shall take place where feasible prior to the housing development.
Whilst it is understood that plans should provide for the extraction of mineral resources, it is clear from the information provided within the evidence base to the Plan, that the area of sand and gravel in the east of Walsall is very extensive. It is therefore quite baffling as to why the identified 'Preferred Area for Sand & Gravel' is located directly to the rear of housing.
The NPPF advises that planning policies should prevent existing development from being put at unacceptable risk from, or adversely affected by, unacceptable levels of air or noise pollution. Clearly the extraction of sand and gravel from this site, in such close proximity to residential properties, will give rise to very high levels of air and noise pollution, adversely affecting the amenity of residents and impacting on their quality of life.

Highways

The 'Design Principles' of Policy WSA3 includes a transport strategy for the widening of Stonnall Road for the extent of the site.
Whilst widening would be necessary, this would only be for a section of Stonnall Road and would mean that access from the A452 Chester Road would be via the winding, and at times narrow, Birch Lane/Stonnall Road.
363 houses on this site would mean a massive increase in traffic movements on what is essentially a rural lane. In addition, there would also be several years of construction traffic utilising highways that are inadequate for large vehicles, together with noise and vibration caused to existing residential properties in the area and this would be further exacerbated by extraction of minerals from this site, prior to the housing development.

Conclusion

Overall, I consider that the spatial strategy for Walsall included within the Black Country Plan, should be re-examined to reduce significantly the amount of Green Belt proposed to be released for housing development.
Strategic Allocation WAH237, Land north of Stonnall Road, Aldridge, should be deleted from the Plan, for the various reasons set out above and the land should also be removed from the Minerals Safeguarded Area.

I would also like to add that the 'Black Country Plan' leaflet that was distributed to residents is extremely misleading due to the fact that despite Strategic Allocation WAH237 being shown on the 'Walsall Spatial Strategy' map, the site is not included in the list of large housing sites in the accompanying table on the opposite page. Clearly, as a site for 202 houses was included here, this site for 363 homes, should also have been listed.

I trust that my comments will be taken into consideration as the Black Country Plan is progressed to the next stage.