Evidence

Object

Representation ID: 23595

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

6.1 Whilst in principle WDL does not have any objection to the wording of this policy, it does strongly object to the extension of the Grange Country Park Area of High Historic Landscape Value (AHHLV) boundary to cover the majority of site WAS6.
6.2 The evidence base which links to this policy is the Black Country Historic Landscape Characterisation Study. This is a desk-based study and from reading no site visits appear to have been undertaken to inform the recommendations.
6.3 Grange Country Park is identified as AHHLV 13, reading the description of this AHHLV it firstly gives no explanation as to why the boundary of the AHHLV was extended or even makes reference to the boundary having been extended. It is not clear, what, if any, assessment was made on site WAS6 and there is no clear justification for its inclusion.

6.4 The Study states that the importance of the AHHLV13 is in the main in relation to Ridge and Furrow features on site. WDL undertook an Archaeological Desk Based Assessment, (which includes a site walkover). This is attached as Appendix 4. The report identifies that extensive and well-preserved earthwork remains of ridge and furrow are to be found to the west of the site in the area of Walsall Arboretum. However, in regard to site WAS6, although there are intermittent areas of truncated and poorly preserved ridge and furrow on the site’s western and northern sides, they are of no more than local significance. The findings of this report reflect the previous boundary of AHHLV13 and WDL can see no justification for extending the boundary to cover the entirety of site WAS6.
6.5 The description also refers to the ‘potential to contain historic hedgerows’. Whilst WDL acknowledge that the site does contain hedgerows, these are afforded protection under policies ENV1, ENV3 and ENV9 and more specifically ENV 4 of the Plan and would not on their own constitute a reason for designating the site as an AHHLV.
6.6 WDL therefore object to the widening of AHHLV13 boundary to include site WSA6 as this has not been properly evidenced and is therefore not justifiable.