Object

Draft Black Country Plan

Representation ID: 21101

Received: 11/10/2021

Respondent: Mr John Davis

Representation Summary:

I am writing to Object to the Black Country plan for Land Groups WAH 230, 246 and specifically WAH254

The Black Country Plan States Paragraph 6.
"Core Expansion Zone 1 comprises land use parcels that are of lower ecological value than those in the Core Habitat Zone but, due to inherent value or location, have the most potential to contribute to a coherent ecologic network. These sites are a priority for investment in the restoration and creation of new habitats."

Situated between the A452 Chester Road and the Sutton Park Railway Line the land areas WAH230, 246
and WAH 254 have been identified as Neighbourhood Growth Areas.

Land Area WAH 254 has been identified on the Spatial Strategy within Core Habitat Zone 1. It cannot be both a Neighbourhood Growth Area and in a Habitat Zone.
Area WAH254 (Hingleys Covert) at the rear of Lindrosa Road is a rare (in Walsall) 10-acre woodland that has remained so from the pre-industrial era. To destroy this woodland as proposed for Area WAH254 conflicts with the Environment Policy ENV1. The major wildlife corridor
into Sutton Park is the railway line but without the environment which borders the railway, the
environmental value is seriously diminished. Land Areas WAH230 and 246 if built upon would seriously diminish the environmental value of this wildlife corridor. The existing narrow railway border retention proposed on the map is not continuous and needs much more tree cover to be successful.
Hingleys Covert (WAH254) together with Hardwick Wood are the only broad- leaf woodland in Streetly
to the East of the A452 which together with the railway line and associated borders form a wildlife corridor the strategy purports to support yet proposes to destroy.


Area WAH254 (Hingleys Covert) at the rear of Lindrosa Road is a rare (in Walsall)
10-acre woodland that has remained so from the pre-industrial era. To destroy th.is woodland as
proposed for Area WAH254 conflicts with the Environment Policy ENV1. The major wildlife corridor
into Sutton Park is the railway line but without the environment which borders the railway, the
environmental value is seriously diminished. Land Areas WAH230 and 246 if built upon would
seriously diminish the environmental value of this wildlife corridor. The existing narrow railway
border retention proposed on the map is not continuous and needs much more tree cover to be
successful.
Hingleys Covert (WAH254) together with Hardwick Wood are the only broad- leaf woodland in Streetly
to the East of the A452 which together with the railway line and associated borders form a wildlife
corridor the strategy purports to support yet proposes to destroy.

Policy ENV4 states: No areas of ancient woodland / no veteran trees lost in Black Country by 2039 [text in bold].

Hingleys Covert and Streetly wood are clearly identified on the 1914 Ordnance Survey Map. They are
least 100 years old and they are veteran trees. The Bartholomew's Gazetteer of 1887 also clearly show these woods. Building on WAH254 contravenes the Environmental Policy (ENV4) of the proposed strategy.
Policy ENV4 also states "Tree canopy cover up to 18% of surface area of Black Country by 2039" [text in bold]. How
does this destruction of one of the 2 veteran wooded areas to the East of the A452 Chester Road contribute to increasing canopy cover?
Planting young trees is no substitute for destroying mature woodland.

Finally
The Black Country Plan's Sustainability Appraisal states (amongst others) as Objectives:
Biodiversity, flora, fauna and geodiversity: Protect, enhance and manage biodiversity and geodiversity.
• Climate change mitigation: Minimise the Black Country's contribution to climate change. [underlined]
• Climate change adaptation: Plan for the anticipated levels of climate change. [underlined]
Building on WAH 230, 246 and 254 contravenes [text in bold] these stated objectives.