Object

Representation ID: 18510

Received: 29/09/2021

Respondent: Mrs Roberta Owen

Site WAH242 Site assessment SA-0078-WAL.
I object to proposals to develop the Calderfields, Aldridge Road Site WAH242, SA-0078-WAL on the
following grounds:
1. Information and RAGs in the Site Assessment SA-0078-WAL The Site Assessment rated Green Belt Harm as Very High and High. It rated Landscape Sensitivity as
Moderately High, when you align this with the following Rags that should be regraded, Site SA-0078-
WAL should not be selected for development.
a) Topography - has anyone visited the site because there is no mention of the annual flooding of the
field in the west of the site.
b) Agricultural land has been assessed as Amber but as the site is over 20ha and the land is
purportedly Grade 3 (possibly Grade 3a?) shouldn't Natural England have been consulted? Potentially
this should be ragged Red and I would expect the assessment to err on the side of caution where it
does not have the required information.
c) Biodiversity and Geodiversity - this should be Red. As mentioned above there has been no
Ecological Report. We have evidence of a number of protected species including [redacted-Ecology] etc. These are the species we are
aware of. Currently there are unrestricted wildlife corridors from Calderfields Farm to: the Arboretum, the
Arboretum extension, Park Lime Pits and Hayhead Wood. The Arboretum Extension is a Site of importance for Nature Conservation (SINC) and Stencils Farm, a
(SLINC) Site of Local Importance for Nature Conservation. Park Lime Pits (to the North West of Stencils Farm) and Hayhead Wood are Local Nature Reserves and Hayhead Wood is an SSSI.
These areas provide an even greater biodiversity and form part of the UNESCO Global Geopark.
These sites surround the proposed development site, so the development of 592 houses will destroy
the wildlife corridors and the light and noise pollution will significantly and negatively impact the
wildlife in each of these sites. There should be an ecology report and the RAG should be Red i.e.
Capacity significantly limited unless harm is caused to habitat of SINC / SLINC value, which cannot be
wholly mitigated.
d) Heritage Assets on site or significantly affecting boundaries. Part of the proposed development is
the old site of Caldewelle Hall and the surrounding fields include ridge and furrow that may denote old
boundaries. The Rag rating should not be green.
e) The impact on visual amenity of adjacent Land Users, including existing residents. This
should be a Red RAG by the BCP Methodology definition i.e. Capacity significantly limited unless harm
is caused to visual amenity / local character which cannot be wholly mitigated. Existing Residents in
Calderfields, on the Aldridge Road, Cameron Road and Buchanan Road are obviously negatively
impacted but perhaps more importantly the Users of Walsall Arboretum experience a negative impact
on visual amenity. This is the only view of open grazing land from the arboretum. This helps to create a
great sense of well being most significantly because of the peaceful 'space'. Walkers along the Beacon
Way will have altered views of the countryside and open space. Development will reduce the
perception of space and tranquility. A row of trees does not mitigate this. It should also be considered
that as the land rises to the Aldridge Road, the houses will be above the tree line anyway. The Rag
should be Red.
f) Flood Risk, drainage and ground water; The West field of the site floods each winter and the
ducks move in. The Aldridge Road to the North East Floods and the Arboretum to the south and on
lower ground, is well known to flood. There are already drainage issues in the South West corner of the
site. Hard surfacing this site will create further flood issues to the cost of Walsall Residents. I am not
sure if anyone has been to the site at the right time of year to RAG this accurately? Appendix H of the
Sustainability Appraisal Page 319 Rags Site SA0078 as Red for the risk of surface water flooding.
g) Employment Land; the methodology says a Red Rag = retain for employment, The site
Assessment states "Not employment land near to residential uses and out of character" and RAG it
red. It feels as if the words in the SA are right but maybe the definition of the red RAG in the
Methodology make the RAG inappropriate? I am not sure what is intended here.
h) Highways access and transportation and Impact on the wider road network- the Site
Assessment states "No housing numbers are provided" yet the site assessment also states 592
Housing Units. Potentially an additional 2000 car journeys a day negatively impacting travel and travel
time not to mention traffic related pollution. Has your assessor travelled these roads in rush hour?
Cameron Road etc. are already used as cut-throughs as people try to avoid the congestion on the
Aldridge Road, Mellish Road / Lichfield Road and down to the Arboretum Junction and that is just the
traffic heading into Walsall. You could try the traffic queues on Longwood Lane or into Aldridge. There
isn't an uncongested route in or out of Walsall in the mornings or evenings. These RAGS should be
red. Please ask the commuters.
"In United Kingdom Planning Law, a Sustainability Appraisal is an appraisal of the economic,
environmental and social effects of a plan from the outset of the preparation process to allow decisions
to be made that accord with sustainable development." There are negative impacts to 11 of the SA
Objectives and only 2 have positive impacts. The decision to proceed with this development will not
accord with sustainable development.
2. Flawed / poor methodology
a) Green Belt Harm and Landscape Sensitivity both ragged 'Red' i.e. Very High Harm to the Green Belt
in the North East, High Harm to the Green Belt West and Moderate High Landscape Sensitivity. The
Black Country Plan site assessment report: Assessment and Selection Methodology and Results
August 2021 Chapter 3, Page 16, Paragraph 5 states that "Sites located in areas where development
is likely to cause very high harm to remaining green belt and where landscape sensitivity to
development is likely to be moderate-high or high have been considered not suitable for development,
as set out in box 3 of Diagram 2." So this site should NOT have been selected for development
according to BCPs own methodology.
b) The above mentioned methodology Diagram 2, Page 10 then states that the Site Assessment
process should " Collate planning evidence e.g. ecological surveys, historic value, flood risk, transport
and seek further evidence / advice if required". There has been no Ecological Report. The historical
value of the medieval site has not been acknowledged and the flood risk has been underplayed.
Transport issues will result from such a development. All routes are congested. If you overlay access to
the site, the issues get worse. These roads cannot take the additional traffic. I contest that the report
has not collated the required evidence or sought further advice.
c) Page 11, 2.18 of the above methodology states "The NPPG states that a site should also be
supported by the local community". This development is NOT supported by the local community. A
local petition with over 1700 signatures attests to this fact (submitted separately).
The BCP should address the issue of climate change -traffic related air pollution - change in air quality.
Building on Green Belt Land further exasperates climate change. Building where travel is necessitated
further exasperates climate change.
d) It doesn't matter how long a period a consultation occurs over. It is only a consultation when the
consultees are aware of the process. Making information available 'on line' (a plethora of information)
and putting up a few posters in libraries is not a consultation. Local residents without the access and
resources available to BCP have tried very hard to fill the gaps left by the planning team. But it is
thought that many users of Walsall Arboretum are still totally unaware of BCP proposals. To be honest
the consultation process doesn't do justice to the work that has gone into developing the plan. No, I
don't agree with the plan but I can see that a number of people have worked over a long period of time
to get to this point. So to undertake a cursory consultation that plays lip service to the word
'consultation' is an insult to the people who have worked on it. Regards,