Policy ENV 5 - Historic Character and Local Distinctiveness of the Black Country

Support

Representation ID: 10982

Received: 19/09/2021

Respondent: Jonathan Browning

Fully support, but stronger wording and binding agreements are needed to ensure these requirements aren't watered down due to "viability concerns" from developers.

Support

Representation ID: 10987

Received: 19/09/2021

Respondent: Mr David Cookson

The meadow is a valuable site for wild life and an oasis of calm, especially for people attending the hospital.

Comment

Representation ID: 11491

Received: 04/10/2021

Respondent: Woodsetton Charitable Trust

The designation of Turls Hill and Swan Brook Valley as areas of High Landscape Value is very much Welcomed given their value to the local community and

Support

Representation ID: 11581

Received: 06/10/2021

Respondent: Mr. Dennis R Whittaker

We are the result of our heritage - and we need to protect it for future generations.

Support

Representation ID: 12035

Received: 10/10/2021

Respondent: Miss Emma Thompson

I support the inclusion of features (both natural and made-made) which contribute to local distinctive character of the Black Country’s open spaces and surviving rural landscapes. The policy could be further strengthened by the inclusion of other habitat features beyond those currently included (e.g. hedgerows, holloways, banks, ditches, field systems, ridge and furrow, areas of open space, woodland and watercourses) to include other habitats and features of historic origin that are a valuable contributor to distinctive character. These should include heathland, permanent grassland
(pastures and meadows), colliery spoil tips, furnace slag and historic quarries.

Support

Representation ID: 12261

Received: 21/09/2021

Respondent: Ms Denise Hamblett-Price

am writing with regard to Corbett Meadow hoping that you will do the right thing for this beautiful & historic space and designate it as a Local Green Space (LGS) in the Black Country Plan (ref Policy DSA4, page 434) and also as an Area of High Historic Landscape Value (ref policy ENV5, page 230).
At a time when environmental issues and a high priority I consider any other plans for this meadow to be not only senseless but almost immoral. This land was given to the people of Stourbridge and having already witnessed the reckless sale of the old Corbett Hospital for housing development I feel that doing the same for this meadow would be an act of violation to our local urban areas and all the wildlife that exists within it.
Please don't sell this land for a quick profit but invest in the long term future and the benefits that this green space can give us all.
Please do the right thing and find alternative brown sites for redevelopment!

Object

Representation ID: 12874

Received: 07/10/2021

Respondent: Mrs Sadie Lambert

I am a resident of the Walsall borough [Redacted-GDPR]. In the hope that my views are listened too I have composed this email. As part of my complaint is that l/we are being treated quite poorly during this consultation process, I fear you may live up to my expectations and merely ignore me if you should read this at all.
I cannot speak of this matter without mentioning the Black Country Plan, which is in consultation at present.
I understand the need for a 25 year review, as requested by Central government. I understand the need for a request for more housing and the imposition on the planning committee to seek out areas of development.
Then why are the residents of the local area angry at what they perceive is an attempt to blindside us by this poorly communicated important issue when considering our conservation areas?
Running alongside the Black Country Plan, which has been appallingly managed from a consultation issue with the public, it has been seen as a smokescreen to mask the conservation status and potential changes.
I have knocked doors all around the area. Those on the perimeter of the conservation area don't know about it. I was told only those living within it are informed. I can tell you categorically this is not true as I have asked some of them!
Why has there been no consultation?
Are you trying to hide something. Deceive us?
Because of the complaints a small consultation was given at the Collingwood Centre. But this could only be advertised by us on the internet at this late date.
Not all resident can access the internet due to the age demographic.
Nothing you can say would placate me/us to say that your communication has been anything other that shameful.
25 years ago the council voted to keep the conservation area. Yet there are no records to say what happened in the meeting other than a vote of 4-3.
The reasons for shrinking the conservation area centres around Great Barr hall. Another shameful episode in the history of Great Barr and the public servants who are supposed to represent us.
That one reason given that you cannot see Great Barr hall from Barr Beacon now that the trees have grown is ridiculous. You've never been able to. To then leave Barr Beacon in the hands of a group of trustees, who have not met in nearly 2 years.
My husband is a trustee elsewhere and has had virtual meetings. That one ex trustee at Barr Beacon extended his garden boundary onto ancient woodland in Streetly, does not fill me with the hope that Barr Beacon would be looked after should it bE merely designated as Greenbelt land.
The Black Country plan also states that the Greenbelt boundaries are to be re-drawn. Therefore, the Prime Ministers statement that he won't build on Greenbelt may well be true. Just shrink the boundaries and build on the land!
1. Please represent my views.
2. Please consider an extension to this matter, communicate properly and have a proper consultation on the matter. Not with just those living inside the conservation area.

Support

Representation ID: 13357

Received: 07/10/2021

Respondent: Mrs Anna Goodman-Lines

Local Green Space + Policy DSA4
Area of High Historic Townscape Value Policy ENV5

Do not touch the land of historic value.. which is treasured by the community as valuable green space

Object

Representation ID: 14326

Received: 19/08/2021

Respondent: Mr Craig Baker

My house seems to fall under the Designated Landscapes of High Historic Value, as shown in yellow. I am [distance] to the Northycote Farm, but I am a private resident.
I would like to know how or who I speak to about the proposed development.
Specifics:
Why I fall under the above in YELLOW?
How or why I would be consulted, if at all?

Support

Representation ID: 15880

Received: 26/09/2021

Respondent: Amblecote History Society

2. Fully support the proposed designation for the Corbett Meadow
Policy Number ENV5 to become an Area of High Historic Landscape Value.

The meadow is an important part of Amblecote’s History and Heritage
It is essential that this parcel of land should be preserved, as the area of Amblecote has been targeted for high density housing over the last five decades.

The meadow is a beautiful green open space with undulating landscape, pleasing to the eye, a breath of fresh air within the surrounding stifling infrastructure.

As a local Green Space it is vital that it should be retained for the protection of its wildlife value and the natural history education for local schools it could offer.

We propose that the meadow should be retained for the health and well being of the community and for Stourbridge and the surrounding areas, as John Corbett stated if the land was to become surplus.

It is certainly an Area of High Historic Landscape Value. The meadow is part of “The Hill” estate, when entrepreneur and benefactor John Corbett purchased it in 1892 it was to be known as The Corbett Hospital.
The meadow is the last historic visible part of the ‘The Hill’ estate and should be retained for opportunities for further interesting research into old Amblecote. The site shows the possibility of being a location of an historic windmill.
(See research by borough archeologist John Hemingway - Township Map 1750)

The Corbett Meadow is a visible part of Amblecote’s History and Heritage and it is imperative that it should remain so.

Support

Representation ID: 17458

Received: 08/10/2021

Respondent: Mr Peter Orme

I write in support of your proposals to designate the Corbett Meadow an Area of historic landscape. My reasons for this are as follows.

The Corbett Meadow is an ancient Green Field meadow it was originally bequeathed to the people of Stourbridge and the surrounding areas by John Corbett philanthropist.

The precious land is a green island contains various habitats: 2 ponds and wetland area, traditional meadow grassland / meadow flora and veteran trees. All of these habitats within the 14 acres sustain wildlife that is now under threat or in decline. It also provides food and cover for animals and birds passing through. The meadow is an untouched natural green field site and a rarity in the middle of a high-density built-up area.

Local naturalist [name] who lives here in Stourbridge and is a BCC radio presenter and author, recently said of the site My impression was incredulity – how had this gem survived intact for so long in a built-up area? this relatively small area was wonderfully contoured and featured marshy hollows, a steep scarp, two willow-lined pools and many mature trees. Needless to say, these features are in very short supply within Dudley Borough. There are many rea species on this site including Palmate Newts which are very scarce in the Black Country conurbation. Hawthorn Jewel Beetles I’d never seen them in Stourbridge before or indeed anywhere in the Dudley Borough. I think that was my strongest impression of the meadow - that it is one of the most important ecological lynchpins in the Stourbridge area. Corbett’s Meadow is not just another piece of grassland: for many of its species, whether they are Palmate Newts or Small Heath Butterflies, it is a life-raft out of the past and its loss would be nothing short of a tragedy not only for local wildlife, but also for the future generations who I hope will be able to enjoy it and explore its history and natural history.

Comment

Representation ID: 17554

Received: 04/10/2021

Respondent: Mrs Pamela Downing

Policy DSA4 and ENV5

Corbett Meadow is a valuable legacy which was left to the people of Stourbridge for local use.
After a consultation in the hospital it is heart warming to sit with a cuppa overlooking the green space with its trees and wildlife.
It is a well known fact as experts tell us, that looking at nature is good for our mental well being.
All of our green space in Dudley need protection.

Comment

Representation ID: 17745

Received: 07/10/2021

Respondent: The Black Country Society

The Black Country Society (BCS) is dedicated to promoting the history, heritage, culture, arts, including literature and identity of the Black Country and its four metropolitan boroughs and individual towns and townships: see: https://www.blackcountrysociety.com/ It has a membership of 1,200 individuals within the Black Country and beyond, including overseas. The BCS and its members work with other organisations, including the Black Country Living Museum to promote the area. We strongly welcome and support the attention paid in the Plan to protect, preserve and enhance the historic environment (in all its different dimensions), as well as the identities and special characteristics of individual localities, several of which are specifically named in the Plan. For many years the area has been home to a rich artistic tradition, including poetry and novel writing as well as the better-known entrepreneurial and technological achievements and high-level skills of its people. We affirm the importance of history, heritage, culture and the arts in enhancing and promoting a dynamic, resilient and confident Black Country and its diverse citizenry in the future.

We therefore support the aims of the plan and welcome the opportunity alongside other community organisations, such as local history and arts societies, museums, libraries and archives, to comment on specific schemes in the future and engage in joint activities to promote the wellbeing of the area and its people. Protecting and enhancing the language, traditions and cultures of communities and their expression in landscapes, buildings, objects, events and different media are central to identity and future progress. We are delighted that this is recognised by the Plan.

Support

Representation ID: 17808

Received: 11/10/2021

Respondent: Kenneth Carrington

Support:
I support saving of the Corbett Meadow and its proposed designation as a green space as stated in Policy DSA4 Page 434 and as an area of historic landscape value Policy ENV5 Page 230.

Comment

Representation ID: 17979

Received: 11/10/2021

Respondent: Dr Michael Hodder

Policy ENV5 Historic Character and Local Distinctiveness of the Black Country

I generally support this policy and I generally welcome the Historic Landscape Characterisation Study in the Evidence Base.

Comment

Representation ID: 17984

Received: 01/10/2021

Respondent: Save the Corbett Meadow Action Group

COMMENTS ON BLACK COUNTRY PLAN in relation to Corbett Meadow ‘Local Green Space’
POLICY DSA4 – CORBETT MEADOW LOCAL GREENSPACE: BCP pages 434-435, Sub paras: A115-A120
POLICY ENV5 – CORBETT MEADOW AS AN AREA OF HIGH HISTORIC LANDSCAPE VALUE: BCP pages 230-235

NOTE: THIS IS A SEPARATE SUBMISSION. MY MAIN COMMENTS I WISH TO MAKE ARE IN RELATION TO THE NATURE CONSERVATION AND WILDLIFE VALUE OF CORBETT MEADOWS SITE, AS WELL AS POTENTIAL LOCAL ENVIRONMENTAL IMPACTS OF DEVELOPMENT.
BUT AS ONE OF MY HEADINGS (PARA 4 BELOW) IS EMBODIED IN MY FULL TEXT AND REFERS TO “HISTORIC VALUE”, I AM COMMENTING HERE ON A SEPARATE PDF FORM IN RELATION TO ENV5 P230 OF THE BCP. I HOPE THIS MAKES SENSE!



RELEVANT SECTIONS OF ENV 5
ENV5 p 230 2)
Development proposals will be required to preserve and enhance local character and those aspects of the historic environment - together with their settings - that are recognised as being of special historic, archaeological, architectural, landscape or townscape quality.

ENV5 pp 232,233 7) b & c
b.Areas of High Historic Landscape Value (AHHLV) that demonstrate concentrations of important wider landscape elements of the historic environment, such as areas of open space, woodland, watercourses, hedgerows, and archaeological features, that contribute to local character and distinctiveness;
c. Designed Landscapes of High Historic Value (DLHHV) that make an important contribution to local historic character but do not meet the criteria for inclusion on the national Register for Parks and Gardens;

ENV5 pp233-234 8)-10)
8) Development proposals that would potentially have an impact on the significance of any of the above distinctive elements, including any contribution made by their setting, should be supported by evidence that the historic character and distinctiveness of the locality has been fully assessed and used to inform proposals. Clear and convincing justification should be
provided, either in Design and Access Statements, Statements of Heritage Significance, or other appropriate reports.
9) In some instances, local planning authorities will require developers to provide detailed Heritage Statements and / or Archaeological Desk-based Assessments to support their proposals.
10) For sites with archaeological potential, local authorities may also require developers to undertake Field Evaluation to support proposals.

HISTORIC LANDSCAPE CHARACTERISATION POLICIES MAP
(Fig 12 P 235)
…..which shows the Corbett Meadows Local Greenspace as….
“an area of high historic landscape value”.
Denoted by green oblique hatching – see key

Support

Representation ID: 18278

Received: 04/10/2021

Respondent: Mr Lance Cartwright

SUPPORT POLICY ENV 5 Historic Character & Local Distinctiveness of the Black Country and designation of Corbett Meadow (Dudley) as Area of High Historic Landscape Value.

The legacy of the philanthropist John Corbett very much lives on in Amblecote through road names, local industry and more than anything else the Corbett Hospital on The Hill estate which John Corbett gifted to the people of Stourbridge - the site is often referred to when giving directions to those who don’t know the area in detail.

The history of John Corbett is well known and locally people look upon him with pride and affection. The Lodge Building by the Corbett Gates bears his coat of arms and more modern tributes to this great man are displayed on the exterior pharmacy walls just below the meadow and very appropriately on John Corbett Drive.

It would morally be quite fitting if the remaining meadow was once again used to benefit the local community in the way that he originally prescribed and intended.

The designation of the Corbett Meadow as an Area of High Historic Landscape Value is wholly justified and I fully SUPPORT it.

Support

Representation ID: 18281

Received: 04/10/2021

Respondent: Corbett Meadow Action Group

Agent: Mr Lance Cartwright

SUPPORT POLICY ENV 5 Historic Character & Local Distinctiveness of the Black Country and designation of Corbett Meadow (Dudley) as Area of High Historic Landscape Value.

The Meadow has a rich history of community use and provides a distinctive & attractive green space that is vital to & emblematic of of the history and character of the area.

Its designation as AHHLV is wholly justified.

Object

Representation ID: 20823

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

paragraph 10.13 - Policy ENV5 should make a distinction between local character and historic environment.

Comment

Representation ID: 21351

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY ENV5 – HISTORIC CHARACTER AND LOCAL DISTINCTIVENESS OF THE BLACK COUNTRY
Whilst the scope of Policy ENV5 is recognised by WDH, the policy requirements go above and beyond the requirements of the NPPF in some cases. For example, the policy requires developments to “sustain and enhance the locally distinctive character of the area”, “preserve and enhance local character”, “retain, and wherever possible, enhance” physical assets that contribute to local character and respect their settings, be designed to make a “positive” contribution to local character and distinctiveness, and “sustain and reinforce” special character and “conserve” the historic aspects of locally distinctive areas of the Black Country.

Whilst it is not desirable to have any impact on heritage assets, NPPF paragraph 202 states that development proposals should be permitted where they have less than substantial harm to the significance of a designated heritage asset, so long as the harm is outweighed by the public benefit; and as such, those policy requirements go over and above the requirements of the NPPF and are contrary to the NPPF in that regard.

The policy should therefore be revised with reference to NPPF paragraph 202 in particular.

Comment

Representation ID: 21484

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy ENV5 – Historic Character & Local Distinctiveness of the Black Country

6.7. The policy seeks to ensure that development proposals sustain and enhance the locally distinctive character of the area, respecting and responding to positive attributes in order to help maintain the cultural identity and strong sense of place of the Black Country. This is an important

consideration for development within the Plan area, however should be balanced against other considerations both in respect of plan-making and decision-taking. In order to meet the development needs of the Plan area, there are likely to be circumstances where changes to the landscape will be required in order to facilitate development that may be considered to adversely affect landscape features, as assessed and demonstrated through the accompanying landscape statement for the Corbett Hospital site. Whilst to a degree this would conflict with this policy, this must be balanced against the need to meet other policy objectives and requirements. As such the safeguarding of existing landscape settings and contexts should not be absolute and must provide for suitable development opportunities in order to achieve the overall strategy and accommodate development within sustainable locations.

Comment

Representation ID: 21495

Received: 11/10/2021

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy ENV5 – Historic Character & Local Distinctiveness of the Black Country

6.7. The policy seeks to ensure that development proposals sustain and enhance the locally distinctive character of the area, respecting and responding to positive attributes in order to help maintain the cultural identity and strong sense of place of the Black Country. This is an important

consideration for development within the Plan area, however should be balanced against other considerations both in respect of plan-making and decision-taking. In order to meet the development needs of the Plan area, there are likely to be circumstances where changes to the landscape will be required in order to facilitate development that may be considered to adversely affect landscape features, as assessed and demonstrated through the accompanying landscape statement for the Corbett Hospital site. Whilst to a degree this would conflict with this policy, this must be balanced against the need to meet other policy objectives and requirements. As such the safeguarding of existing landscape settings and contexts should not be absolute and must provide for suitable development opportunities in order to achieve the overall strategy and accommodate development within sustainable locations.

Support

Representation ID: 21690

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV5, its scope and recognition of a broad range of features and characteristics which contribute to locally distinctive character, and the level of detail that is included in the wording of both the policy and the justification.

Comment

Representation ID: 21691

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBBC support the inclusion of features (both natural and made-made) which contribute to local distinctive character of the Black Country’s open spaces and surviving rural landscapes. WTBBC are of the view that the policy could be further strengthened by the inclusion of other habitat features beyond those currently included (e.g. hedgerows, holloways, banks, ditches, field systems, ridge and furrow, areas of open space, woodland and watercourses) to include other habitats and features of historic origin that are a valuable contributor to distinctive character. These should include heathland, permanent grassland (pastures and meadows), colliery spoil tips, furnace slag and historic quarries.

Comment

Representation ID: 22161

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

We are aware that there are heritage-related consent regimes under the Planning (Listed Buildings and Conservation Areas) Act 1990 that apply in the case of this site, given the Grade II and II* listed buildings present on site. We are also great weight should be given to the conservation of such assets. Paragraph 190 of the Framework states that 'Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account: a} the desirability ofsustaining and enhancing the significance ofheritage assets, and putting them to viable uses consistent with their conservation; b} the wider social, cultural,
economic and environmental benefits that conservation of the historic environment can bring; c}
the desirability ofnew development making a positive contribution to local character and distinctiveness; and d} opportunities to draw on the contribution made by the historic environment to the character ofa place.'

2.15. We consider that in light of this, more emphasis should be placed on flexible approaches to alternative uses (viable uses consistent with their conservation) within ENVS to take account of the above guidance.

2.16. Paragraphs 20l and 202 of the Framework require the decision maker to assess whether a proposal will lead to substantial or less than substantial harm to, or total loss of significance of, a designated heritage asset. If the harm is assessed as substantial or resulting in the total loss of significance of a designated heritage asset paragraph 20l confirms that consent should be refused unless there are substantial public benefits that outweigh that harm or loss or all of the four criteria listed in the paragraph apply. If the harm is less than substantial, paragraph 202 requires this harm to be weighed against the public benefits of the proposal, including securing its optimum viable use. It is our view, even at this early stage, that the conversion and regeneration of these buildings is capable of resulting in 'less than substantial' harm (lower end) and that the public benefits generated from the new development and securing the building long term from future damage are substantial public benefits.

Given that the proposals in the emerging plan would be to preserve the colliery buildings (those listed) in situ, it is clear that a conversion to residential use is most likely the most viable (and therefore optimum) use. This could be a requirement of any future development to be proposed on the adjacent land - and to make it clear that one would 'cross-subsidise' the other.

2.18. We would therefore like the council to reconsider their position on this.

Comment

Representation ID: 22362

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust welcomes the specific reference to the need to sustain and reinforce the special character and conserve the historic aspects of the canal network, including associated infrastructure, buildings and structures in policy ENV5.

Comment

Representation ID: 22565

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy ENV5 – Historic Character and Local Distinctiveness of the Black Country

As set out in our comments on Policy HOU2 – Housing Density, Type and Accessibility, we agree that the historic environment should be protected, but that this needs to be appropriately balanced with other objectives of the DBCP in accordance with national policy. This policy seeks to restrict development which in the LPA’s opinion would negatively impact on the historical landscape.
The policy makes no reference to the need to balance impacts the historical environment with the ability to bring forward sites for housing within both urban and rural areas of the Black Country. As discussed in our previous comments, land values across the Black Country are generally low, and therefor the ability for brownfield sites to come forward has often been slow or non-existent without significant public funding/investment due to viability. Often the only way to increase the viability of sites on brownfield land has been to increase densities which then means increasing heights. Also, as we have set out, density and heights do not take into account typography of the land or any existing footprints. The NPPF is clear in this regard at paragraph 124 when dealing with achieving appropriate densities.
Respecting the historic character of the Black Country doesn’t simply mean re-creating the same types of development; new development of different densities and material pallets can improve the historic character by focusing views on monuments and buildings of historical interest.
It is inevitable, the Strategic Centres where development is on existing elevated sites or sites with steep gradients near historical sites/buildings may have have some sort of ‘impact’; however, the policy reads to say that any impact is negative by simply having an impact. The policy refers to the need for developments to preserve and enhance aspects of the historic environment and achieve a locally response design. Developments need to assess views into, from, to or within historic environments/buildings. This requirement is too general and doesn’t make it clear what the hierarchy of views are; for example, if there are no impacts on the principal views/elevations of listed buildings, then would this then be acceptable in principle. Or does the policy mean that even if one view is impacted then the development is unacceptable?
The justification of the policy also appears to be short given the policy itself is so detailed. Paragraph 10.83 states “To ensure that heritage assets make a positive contribution towards the wider economic, social and environmental regeneration of the Black Country, it is important that they are not considered in isolation but are conserved and enhanced within their wider context. A holistic approach to the built and natural environment maximises opportunities to improve the overall image and quality of life in the Black Country by ensuring that historic context informs planning decisions and provides opportunities to link with other environmental infrastructure initiatives.” . We agree that a holistic approach is needed, but it needs to be clearer what this approach includes, as well as actually being explicit in the policy wording itself. This does not mention the need to look at physical site constraints, viability, the public benefits a development could bring or even a reference to developments being of high quality.
Paragraph 10.82 states in the last sentence “Whilst a legislative framework supported by national guidance exists to provide for the protection of statutorily designated heritage assets the key challenge for the future is to manage change in a way that realises the regeneration potential of the proud local heritage and distinctive character of the Black Country.” Historical assets at a national and statutory level already benefit from a high level of protection, and Policy ENV5 should seek to be more precise with regards to what needs to be demonstrated to allow developments which do impact on the historical environment acceptable.
Overall Policy ENV5 as drafted is overly restrictive and allows no flexibility for high density development to come forward in Strategic Centres where there are many listed buildings as well as well as historical environments/character.
The Site is located near the Grade II*Listed St Matthew’s Church and also adjacent to the Church Hill Conservation Area and other listed and non-listed buildings and parks. The typography of the site means that any development which increases the floorspace will be visible from a few viewpoints from the southwest of Walsall, however the principal view of the church from St Matthew’s Quarter will not be impacted, due to the elevation of the church. It should also be clear that the immediate area around the church in the core Town Centre has changed significantly over the last 20 years and the access to the Church cut by the creation of a main road (Peal Street/Upper Rushall Street), which effectively from a visual point of view, cuts off the Church from the Town Centre.
As mentioned, the development of the Site would bring a number of public benefits; much needed housing on a poor quality employment site with limited access (brownfield), regeneration of an area within a Strategic Centre with excellent access to different modes of public transport, the ability to create more critical mass/population to bring back in use the closed memorial gardens, as well as the community centre associated with the church, and also to help the viability and vitality of the Town Centre.
Paragraph 206 of the NPPF is clear “Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably.” Policy ENV5 does not make it clear which elements of the setting of heritage assets are the most important, leaving this all down to interpretation. Given that this is the main policy with regards to protection of heritage assets, it is clear that the purpose of the policy is to make development which is located near or next to heritage assets more difficult, without having a clear, concise and positively prepared policy which is contrary to the NPPF. Unless the policy is able to be applied in a flexible holistic approach, it will not aid in the redevelopment of urban, brownfield land.
This is a direct contradiction to what the DBCP is trying to achieve overall, and which Walsall Town Centre sites should be actively supporting in accordance with the NPPF.

Comment

Representation ID: 23069

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy ENV5 – Historic Character and Local Distinctiveness of the Black Country

The plan has proposed to designate Areas of High Historic Landscape Value (AHHLV) and Archaeology Priority Areas (APA). Policy ENV5 states that development proposals which would have an impact on the significance of a AHHLV and APA should be supported by evidence that the historic character and distinctiveness of the locality has been fully assessed and used to inform proposals

Comment

Representation ID: 23263

Received: 11/10/2021

Respondent: Historic England

Paragraph 10.78 states that where ‘physical evidence of local character persists, it should be conserved’. Can the Plan clarify what is meant by this and how this can be achieved? We are supportive of the aim.

Comment

Representation ID: 23264

Received: 11/10/2021

Respondent: Historic England

Policy ENV5 clause 1 we would recommend amending ‘sustain’ with ‘protect’. It may be useful if at the beginning of the policy the first clause sets out the need to protect and enhance the significance of heritage assets, including their setting. Clause 2 we would recommend amending ‘preserve’ with ‘protect’. We are very supportive of the references to the historic environment of the Black Country and its local distinctiveness. We support the references in the policy to Historic Landscape Characterisation Studies and other up to date assessments. We are supportive of clause 6 and welcome the local elements included within this policy. It may be necessary to have some additional guidance for prospective applicants and development management planners to follow, in order to ensure that this is upheld during the development management process. Clause 8 would benefit from additional detail on what type of assessment would be appropriate including the level of detail and ensuring that the impacts to significance if fully evaluated. Clause 9 and 10 would benefit from the inclusion of a reference to suitable qualified and appropriate persons undertaking relevant assessments. We welcome the detailed consideration of the historic environment within the Black Country and the desire to protect it for future generations.