Object

Draft Black Country Plan

Representation ID: 21844

Received: 11/10/2021

Respondent: Mrs Frances Sayer

Representation Summary:

Site Ref: WAH 242/ SA-0078-WAL

I am writing to object to the proposal to build 592 houses on the site of Calderfields Farm in the Ward Of St Mathews Site Ref: SA-0078-WAL on the following grounds Black Country Planning have not followed its own Assessment & Selection Methodology in identifying the area of Calderfields Farm as potential suitable Green
belt for redevelopment.

1. Black Country Planning has not followed its own Assessment and Selection Methodology in the following area:

Page 18, Biodiversity and Geodiversity states:
“Existing Council records inform the status. Ecological appraisals which informed Local Sites Assessments were carried out for the most sensitive sites and their
findings are included in the assessment. Impacts on local sites such as these can sometimes be mitigated by providing environmental enhancements to deliver net
biodiversity gain on the site or nearby land.”

Although this site is Green Belt assessed as likely to incur ‘very high harm’, there has been no Ecological Survey of the site.

This site has:

o Bats this development will cause the loss or fragmentation of their habitat.

o Red deer (Deer Act 1991)
o Tawny Owls and Barn Owls
o Woodpeckers
o Sky larks
o Nuthatches
o Buzzards
Currently there are unrestricted wildlife corridors from Calderfields Farm to:
o the Arboretum
o the Arboretum extension. The extension is a Site of importance for Nature
Conservation (SINC) and
o Stencils Farm, a Site of Local Importance for Nature Conservation (SLINC).

Additionally, Park Lime Pits (to the North West of Stencils Farm) and Hayhead Wood are Local Nature Reserves, SINCs and Hayhead Wood is an SSSI.

A local wildlife site assessment is required to provide evidence to inform the BCP site assessment process. This has not been undertaken and therefore I object to the allocation of WAH 242 and therefore should be removed from the list of potential sites for development.

2. Black Country Planning has not followed its own Assessment and methodology policy in the following area:

The Black Country Plan Site Assessment Report, Assessment and Selection Methodology and Results (August 2021) defines an Amber RAG as “There is a
moderate negative effect or issue which may be able to be adequately addressed but only subject to mitigation.”

This alone should be enough to demand that the Ecological Report was completed before the site was ‘selected’.

Further objections =

 The impact on visual amenity from the Arboretum will be substantially impaired.
 There has not been an assessment of the site for flooding.
 Any houses built behind these barns would be looking directly into bedrooms and bathrooms of the houses impairing any privacy for residents of the barns
 The increased traffic resulting from 592 houses, potentially with 2 cars per household.
 The Brownfield register has not been updated since 2017. BCP have a duty to look for Brownfield sites to build on before looking to Greenbelt.
 I object that the BCP consultation has not been carried out in a fair and transparent way.