Comment

Representation ID: 21267

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV1 – Nature Conservation
Policy ENV1 states that Sites of Local Importance for Nature Conservation (SLINCs) will be protected from development proposals that could negatively impact them. Confirmation is requested on how SLINCs which are included within proposed strategic allocations will be approached by the Council and whether mitigation will be accepted as part of development proposals.

SLINCS are non-statutory sites identified by the Black Country Wildlife Trust (BCWT) and they are not defined or recognised within the NPPF or PPG as sites which should be afforded protection. Walsall Council’s website states that SLINCs should be given a lesser protection than SSSIs or SINCs which are protected by national policy. The PPG references ‘Local Wildlife Sites’ which the Wildlife Trust has defined as including SINCs. The PPG also lists a range of criteria that LWS will be assessed against (Reference ID: 8-014-20190721). As the Council has not demonstrated that the proposed SLINCs meet the LWS criteria, we do not consider that they should be given the same protection as LWS / SINCs.

In light of the above, as part of the Council’s local plan process, a review of call for sites has been undertaken and as a result, the BCWT has designated additional SLINC’s across the BCA. Within proposed allocation Site WSA2, two sections of our client’s land has been designated as SLINCs (Site WAH 238). Our client’s Ecologist has previously assessed our client’s land and identified that the two areas of land which have now been designated as SLINCs are areas of ‘poor semi-improved grassland’.
Further clarification is required as to why poor semi-improved grassland has been considered as having ecological importance which warrants protection as a SLINC.

Within the BCWT’s Site Assessment Report for our client’s land the site has only scored ‘high’ against the ‘Position & Connectivity’ criteria because BCWT consider that the site acts as a wildlife corridor between Jockey Fields SSSI, Grange Farm Wood SINC and Ford Brook SLINC. We do not consider that this should mean that parts of our client’s land are designated by a SLINC. As part of further development proposals, green infrastructure provided could bolster and improve any existing green infrastructure links.

Additionally one of the SLINC’s proposed within Site WSA2 (north western corner) comprises woodland. It is unclear why only the part of the woodland within the allocation boundary is proposed as a SLINC and not the wider woodland adjacent to the northern and eastern edge of the SLINC.

In light of the above, we do not consider that there is sufficient justification to support the proposed SLINC on our client’s land or to afford SLINCs the same protection as SINCs. However, regardless of the SLINC designation, as part of future development proposals, these areas could be retain as far as possible within the green infrastructure of the development layout as part of good design, and if some loss is unavoidable, this could be mitigated elsewhere within the site.