Comment

Representation ID: 43939

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Environmental transformation and climate change
Policy ENV1 (nature conservation) and ENV3 (nature recovery and biodiversity net gain)
3.51 Policy ENV1 of the BCP seeks to ensure that development is not detrimental to the
natural environment, and outlines a series of measures / tests to ensure that any
development can have a measurable improvement to the natural environment.
3.52 The field parcels which make up Land at Queslett Road, are mainly used for agriculture
and are demarcated by low-trimmed hedgerows, mostly species-poor and dominated
by hawthorn. Over-grown hedgerows, with a higher diversity of shrubs, are locally
present (i.e. to the south of Doe Bank Farm). These comprise of ash and sycamore

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trees. Along other boundaries hedgerows are absent or intermittent or are marked by
the planting of non-native tree species.
3.53 Mature trees are locally frequent within certain hedgerows and also occur to a lesser
extent in fields (former hedgelines). The tree species component is varied but mainly
comprises of ash, English oak, sycamore and holly.
3.54 Two small copses of mature trees are present within arable fields. The copses are
dominated by mature oak, beech and sycamore trees. In places tree cover is lower and
more open conditions prevail.
3.55 There are no ponds or watercourses within the site and the site is not designated as a
statutory or non-statutory designated ecological site.
3.56 The illustrative masterplan included in the Vision Document establishes a development
framework which seeks to maintain and bolster as much of the existing natural
features of the site as possible, including the provision of a robust open space network
through new planting and the creation of new wildlife areas within the site to deliver a
net gain in biodiversity value across the site.
6 Referenced at paragraph 7.7 of the Viability and Delivery Study (May 2021), paragraph 6.6 of the draft BCP,
specific site commentary in the SHLAAs, and paragraph 3.1.24 of the Black Country Urban Capacity Review Update
(May 2021)