Primary Evidence

Comment

Representation ID: 21339

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Primary Evidence
Comment: The Draft Local Nature Recovery Opportunity Map and components description (published as Appendix 18 in the BCP) should be added to the list of Primary Evidence.

Comment

Representation ID: 23591

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

5.5 The evidence relating to this designation is ‘An Ecological evaluation of the Black Country Green Belt’ (Evaluation) October 2019, produced by EcoRecord. This was a desk-based exercise.

5.6 WDL has a number of concerns with this evidence. In simple terms, the evaluation report maps the whole of the Black Country Green Belt and then assigns land parcels a rating based on the use they are currently in, what use they are next to, if there are water features nearby and if they are next to designated sites. It then provides a final ranking figure for each parcel of land.
5.7 In the case of WAS6 this forms part of a much wider parcel which includes Grange Park and the Walsall Arboretum to the West and the designated SLINC sites to the north. It is therefore washed over with a ‘very high’ ecological score.
5.8 WLD strongly object to the site being included as a SLINC on the basis of this report. It contradicts WLD’s own findings which were based on site specific data and a walkover of the site.
5.9 The NPPF at Paragraph 16 states that Plans should:
“d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;”
5.10 WDL is of the view that this poorly thought-out designation renders the WAS6 allocation ambiguous. On one hand the site is suitable for allocation, but on the other it has ecological value which would hinder development. Housing allocations need to be clear and robust, particularly to get local support. This designation will also confuse environmental stakeholders who offer advice to the Council.
5.11 As this designation is new and not based on rigorous on-site assessment (as was the WDL survey), WDL respectfully request the Council to remove it and as such, provide certainty on the Council’s behalf, that the site is deliverable.