Comment

Representation ID: 23470

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Dear Sir/Madam

I am writing to you to raise my concerns in relation to the Black Country Plan (Review). In particular, I have concerns that Walsall Council is proposing to include
the Pouk Hill urban green space area within a proposed designated "Core Regeneration Area" within figure 19: Walsall Spatial Plan Map on page 499 of the Black Country Plan (BCP) Regulation 18 public consultation document.

The Pouk Hill open space area forms a very important green space resource which I have used for many years as a place to exercise my dog and as a natural environment urban green area in which to relax. The urban area has increasing shortage of these important open space sites. Walsall Council does not appear to
have any credible evidence to back up and support its planning policy approach for this site. For example, the Council does not have an up to date and robust Green
Infrastructure Study. The Council's position on this issue is not based on credible or accurate information or robust evidence. The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.

The Walsall Metropolitan Borough has some of the worst health data within the whole of the United Kingdom. Such as high numbers of childhood and adult obesity cases, a prevalence of Type 2 Diabetes, strokes etc. Walsall Council's planning approach within the Reedswood area of Walsall will make the situation a lot worse.

The situation is concerning and very alarming. Walsall Council should be doing more to protect the Pouk Hill public open space. This important green space area forms part of an important wildlife corridor, the southern woodland within Pouk Hill space is designated as a 'Site of Importance for Nature Conservation' (SINC) habitat.
The green space provides an accessible natural green space area located on the doorstep of residential communities within the Reedswood area. It forms a critically important public open space area.

The Coronavirus (Covid-19) global pandemic has shown how important these local nearby natural green space areas are to the health and wellbeing of local communities as they help to support more physically active healthy lifestyles, and tackle the obesity pandemic currently affecting the Walsall area. The Coronavirus
pandemic has highlighted the increased relevance of green space to health.

In my opinion, these "pandemic-related factors" have been given an insufficient level of material planning weight by Walsall Council in its approach to spatial town
planning taken within the wider Reedswood area of Walsall. The Council's position is insufficiently robust and unsound.

Given my knowledge of the Pouk Hill green space areas, having lived very near to this site for many years, the green space site clearly meets "Local Green Space"
(LGS) designation criteria as set out in paragraph 102 of Central Government (London) National Planning Guidance in the Revised National Planning Policy
Framework (NPPF) (July 2021). The green space site in question strongly performs against the Local Green Space (LGS) planning policy designation criteria in
paragraph 102.

On this basis, there is a compelling and robust case to designate the Pouk Hill green space as LGS on the main 'Policies Map' of the emerging Black Country Plan
(Review). This designation should be brought forward as a matter of urgency. I request the urgent removal of the Pouk Hill green space areas from the proposed
Core Regeneration Area'.

Please stop Walsall Council from damaging the local area.

Walsall Council's proposed approach being taken within the Black Country Plan (BCP) (Review) conflicts with the following national planning guidance set out in the
Revised National Planning Policy Framework (NPPF) (July 2021) paragraphs 92 (indent C), 98, and paragraph 179. All these parts of the NPPF stress the importance of protecting important urban green space area.

Paragraph 185 of the Revised NPPF (July 2021) states that planning policies should take into account the likely effects of pollution on health. This is relevant given that
Walsall Council is encouraging the re-development of critically important "urban green space lungs" on the edge of the M6 motorway network. Notably, Pouk Hill
woodland green space and the urban green space bordering Churchill Road.

Pouk Hill Close Reeds wood Walsall- Residents Petition in relation to the emerging Black Country Plan (BCP) (Review) (2021) (Regulation 18) public consultation which runs up until 5pm on Monday, 11th October
2021

This is a signed residents petition by local residents who live on Pouk Hill Close, Reedswood, Walsall. As local residents living within Pouk Hill Close immediately
adjacent to the Pouk Hill natural green space area, we specifically request that:

1) Given its high level of green space sensitivity, the Pouk Hill Close green space site off Bentley Lane, Reedswood, Walsall should be fully removed from the 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan (and other parts of the emerging Black Country Plan which identify this site as a Core Regeneration Area. Within the Figure 19 Plan (Walsall Spatial Strategy Plan) and on the main Policies Map of the emerging Black Country Plan
(BCP) (Review), the entire Pouk Hill green space area should be specifically designated as a 'Protected Public Open Space area' (see below).

2) Pouk Hill natural green space area (the entire green space site) should be specifically designated as 'Local Green Space' (LGS) given that the Pouk Hill green space area strongly meets the site-selection and site designation planning policy criteria for Local Green Space (LGS) designation as reinforced within paragraph 102 of central Government (London) national planning
guidance set out in the Revised National Planning Policy Framework (NPPF) (published July 2021). Given that this sensitive green space site strongly performs against the Local Green Space (LGS) site-selection and site
designation criteria as set out in paragraph 102 of the Revised National Planning Policy Framework (NPPF) (July 2021), the Pouk Hill natural green space area should therefore be specifically designated as Local Green Space (LGS) and shown as LGS on the main Policies Map of the emerging Black Country Plan (BCP) (Review) (2021). And also specifically shown as Local
Green Space (LGS) within the Figure 19: Walsall Spatial Strategy Plan, referred to above. As local residents living along Pouk Hill Close, we consider that designating the Pouk Hill publicly accessible natural green space area as
'Local Green Space' (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council's to deliver a 'More Effective, Positively Prepared and Justified Plan, consistent with national policy', in accordance with Local Plan 'tests of soundness' as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).

3) The existing 'Site of Importance for Nature Conservation (SINC)' designation within the mature deciduous woodland located within the southern tip of the
Pouk Hill natural green space area (bordering Junction 10 of the M6) should be retained and carried forward within the emerging Black Country Plan (Review) (2021 ). This existing 'Site of Importance for Nature Conservation' (SINC) designation should also be fully extended across
the remainder/ across the entire Pouk Hill natural green space site. This is considered necessary as the whole green space site warrants SINC designation status, given that as residents we have robust, up-to-date and
credible evidence to suggest that the wider Pouk Hill natural green space site provides an habitat for different
important wildlife habitat for a number of protected wildlife
species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging and [Redacted- Sensitive information] for different [Redacted- Sensitive information species. The Pouk Hill natural green space site also forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider heavily urbanised
Reedswood area, providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to Reedswood Town Park natural green space area, and other 'stepping-stone'
natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. The importance of protecting 'landscape­ scale green infrastructure' is specifically reinforced within paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021). The wider sites designation as a proposed SINC would therefore have a strong level of planning policy support within paragraph 179 of the Revised NPPF (2021). As local residents living along Pouk Hill Close, we consider that designating the entire Pouk Hill publicly accessible natural green space area
as a 'Site of Importance for Nature Conservation' (SINC) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council's to deliver a 'More Effective, Positively
Prepared and Justified Plan, consistent with national policy', in accordance with Local Plan 'tests of soundness' as reinforced in paragraph 35 of the
Revised NPPF (July 2021).

4) The entire Pouk Hill public open space area should be covered by a 'blanket Tree Preservation Order (TPO)' (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021) to help protect the green space landscape enhancement benefits of this natural green space area containing areas of native tree species broadleaved woodland, to ensure that this areas wildlife habitats are sufficiently protected, and to help ensure that its key function as a woodland urban green lung helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain
protected into the future, by receiving the necessary and justified planning policy protection within the emerging Black Country Plan (BCP) (Review).

5) In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

As local residents, we have signed this petition to ensure that the emerging Black Country Plan (BCP) (Review) (2021) takes on board these critically important issues.
The above issues will help to ensure that the emerging BCP (Review) promotes a much more sustainable spatial planning approach, in accordance with Government
guidance set out in paragraph 11 of the Revised NPPF (July 2021).