C. Walsall

Object

Representation ID: 15593

Received: 08/10/2021

Respondent: Tony Carter

[see rep 15592] I am absolutely furious that you are even contemplating using Pouk Hill and Reedswood park for housing and employment, might I remind you that the road between pouk hill and the motorway is the most polluted road in Walsall. Pouk hill stops a lot of pollution, the environmental impact would be huge, this area should be protected and designated as an Air quality enhancement urban green lung area. Also reedswood park serves the local community how the hell can you justify cutting down trees and digging up park land for housing especially with all the emphasis on global warming at the moment. Town parks should not be used for housing and employment, reedswood park is a key wildlife corridor. We have diverse wildlife around this area that should be protected. You must look at the wider health implications of what your trying to achieve. Reedswood park should be designated as protected park land public open space on the main polices map of the emerging BCP review.
Also former reedswood golf course with all the trees again should be designated as a wildlife corridor, with all the trees that have been planted should be protected by a blanket tree preservation order.
I think you need to rethink what you are doing instead of trying to line your pockets using government legislation as a cover, I know we need housing but cutting down trees is not the way to do it.
[see rep 15592]

Object

Representation ID: 15637

Received: 07/10/2021

Respondent: Mr Stephen Beavon

Queslett Road East/Aldridge Road
Objection is as follows:-
Green Belt land and conservation area.
We do not have enough school places, Doctors or dentists at the moment so where are all these new people going to go.
Traffic along Queslett Road is already bad and we have had the Netherhall estate which has already impacted on the area.
I live on xxxxxxx xxxx next door but one to the school entrance. We have a dropped kerb and have the zigzag lines outside our house. Only this morning there are two cars parked outside our house blocking us in and the drivers have left their cars and gone in to the school. Add in another nine hundred plus houses it will be an even worse nightmare than it is now.

Object

Representation ID: 15784

Received: 01/10/2021

Respondent: David Baker

4) There seems little thought to infrastructure needed to accommodate these additional houses. In Walsall it is extremely difficult to get on a doctors list as most are at full capacity. There are no NHS dentists willing to take new patients on. The hospitals are over capacity. There are insufficient ambulances for the number of patients requiring them. Schools are at capacity. There are vague references to new health centres and junior schools being
required but no details as to when and where they are to be situated (are they to be built on more green belt land?). Roads around Walsall are very congested already and new housing will only add to it. There are no proposals to mitigate these concerns.

5) Reducing the green belt between Walsall communities within the Walsall borough will have a negative effect as traditional and cultural boundaries merge closer together.

6) New housing built in the future will require better insulation, solar roofs, heat pumps, rainwater catchment and reuse, and electric vehicle charging points all of which tend to increase the footprint of the house reducing the number that can be built on a plot of land. These new building regulations will also significantly increase the cost of houses so will
'affordable housing' be viable.


7) Green belt is becoming more and more important ecologically. In order to combat climate, change we need to increase green belt land and tree planting. Where is the detail on mitigations in the plan to reduce climate change and ecological damage?

9) In conclusion the plan removes green belt protection mainly in the Walsall borough. Other boroughs have relatively small green belt losses so the plan discriminates against Walsall residents who are being let down by their planners. This Black country plan appears to put the majority of the new housing requirement in Walsall. It appears that the other Black Country borough planners want the urban sprawl to be concentrated away from them in Walsall. There is no mitigation for this loss of green amenity to Walsall residents. There are no climate change mitigations for this loss and there is insufficient brownfield regeneration and reclassification proposed within Walsall. Although the plan refers to certain studies and investigations/ mitigations in regard to the green belt, these are not accessible to view as part of the plan. This plan is flawed.

Object

Representation ID: 15873

Received: 04/10/2021

Respondent: Mrs Christine Fellows

Before using Green Belt land why not clean up Stafford Street Walsall, Silvercourt Brownhills, also Walsall town centre is a disgrace.
I know houses are needed but not on precious Green Belt land.

Comment

Representation ID: 15881

Received: 11/10/2021

Respondent: Mr Stirling Jackson

With reference to building on greenbelt land by Walsall Council at Grange Crescent Shelfield Walsall WS4 1NS
This is totally wrong
After years and years of planting hundreds of trees and encouraging all the wildlife to thrive and the fish have returned to the brook which runs through this plot of green belt land.
It is used all day long by all the people in the area for dog walking and a place they can walk and do jogging for their health.
The road in the Crescent is far to narrow for all the extra traffic this would incur.
I am totally opposed to any building or change of use of this land.

Object

Representation ID: 15882

Received: 11/10/2021

Respondent: Mrs Christine Perkins

We as a family object to this development. It will create more noise, pollution and take away the natural space for wildlife and walks around the village in Pelsall. It will also cause more congestion and traffic queues, at the crossroads and through the village. The area is beautiful and Pelsall is known for all its greenery and space for walking. Please reject this and save our green belt for the local residents, local wildlife and local community. This will also effect mental health as green space is VITAL! We need to protect this space.

Object

Representation ID: 15909

Received: 11/10/2021

Respondent: Mr Stuart Dukes

We do not need more housing in our area / we need less people. Unchecked immigration is the problem. There is no point building more houses when all our services are already overwhelmed. To use our greenbelt would be a disgrace one of the only pleasure's we had during lockdown was a good walk with our dog's around the green belt area's. Now you propose to sell these area's off. Its a big No from me leave our green areas alone!!!!

Comment

Representation ID: 15935

Received: 08/10/2021

Respondent: Mrs Susan Gibson

We pay full Council Tax, but we are not allowed to use the Anchor Lane amenities site - its a disgrace that people who live in Sandwell (who have to pass over house) are allowed to use it. We have almost beg for hedges to be cut and our cul-de-sac to be swept. Also the amount of cars which race and park in front of our house, we are [Redacted-GDPR] old and it is becoming a nightmare. I do hope someone will take notice of these complaints.
Yours faithfully
[Redacted-GDPR]

P.S. This is a residential street, but it is being used as a business by some

Object

Representation ID: 15936

Received: 08/10/2021

Respondent: Stuart Yardley

Black Country Plan (August 2021) - Pouk Hill open space, Bentley Lane, Reedswood, Walsall
I am writing to express my concerns in connection to the above. I have lived in the Reedswood area now for [Redacted-GDPR] and was horrified to learn that Walsall Council has included the Pouk Hill public open space within a proposed "core regeneration area" on page 499 (Figure 19: Walsall Spatial Strategy Plan) of the Black Country Plan (August 2021) public consultation document (Regulation 18 consultation). This will encourage highly damaging and unsustainable patters of development within the Reedswood area.
Walsall Council is promoting damaging patterns of development within the local area. The Pouk Hill public open space is important for the following reasons: -
- It provides an outdoor recreational resource for local residents
- It provides an important habitat for wildlife, including bat species
- It forms part of a wider connecting wildlife corridor from East to West across the Reedswood area
- It provides and essential urban green lung which helps to reduce harmful levels of air pollution from one of the busiest sections of Motorway highway networks in Europe.
- It has climate change benefits for surface water storage and promoting urban cooling.
- It enhances the local landscape quality, providing an essential green space
The fact that Walsall Council is actively promoting the development of the Pouk Hill public open space within the Black Country Plan (2021) underlines the failure and incompetence of Walsall Council in relation to urban green space planning matters.
Walsall has one of the worst obesity epidemics within the whole of the UK. With increasing cases of childhood and adult obesity. Yet Walsall Council still considers it a good idea to encourage the re-development of Reedswood's last few urban green space areas. This underlines the failure and incompetence of Walsall Council in relation to public health matters.
Walsall Council should be taking a more pro-active approach to tackling the local obesity epidemic. Its planning policies are doing the exact opposite, and making the situation alot worse.
Walsall Council should be stopped from damaging the local area any further.
The Pouk Hill green space provides an essential urban green lung that protects thousands of local residents from high levels of air pollution from Junction 10 of the M6 motorway. The mature woodlands within the Pouk Hill green space help to filter-out harmful levels of air pollution from the M6. By placing Pouk Hill open space within a proposed "Core regeneration Area" to encourage its disposal for new housing development, Walsall Council's proposed approach in the Black Country Plan is conflicting with Government planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy Framework (2021).
Walsall Council's planning approach is also conflicting with Article 2 of the Human Rights Act Legislation which "protects your right to life" It states that "... Public authorities should also consider your right to life when making decisions that might put you in danger or that affect your life expectancy ..." By placing thousands of residents at increased risk and increased exposure to air pollution by redeveloping an important green lung, Walsall Council is contravening the Human Rights of thousands of Reedswood local residents on the eastern side of the Junction 10 M6 motorway. As local residents we have a clear, justified, and fundamental Legal right "to be able to breathe clean air". Walsall Council's planning policy approach within the Black Country Plan is a clear breach and infringement of our Human Rights under Article 2 of the Act. Walsall Council should be stopped from introducing further levels of environmental damage to the local area. The above issues highlight the failure and incompetence of Walsall Council on a range of public health and green space policy protection matters.
The re-development of the Pouk Hill green space area by including it within a "Core Regeneration Area" will also expose thousands of local residents within the Reedswood area to increased levels of noise pollution from the M6 motorway network near junction 10 of the M6. This will breach our Human Rights under Article 1 of the Human Rights Act Legislation, which provides a Legal Right ",,, to enjoy your property peacefully ..." Walsall Council's approach at encouraging the redevelopment of an important woodland urban green lung is therefore breaching Article 1 of the Human Rights Act.
Walsall Council has also failed to take on board the impact of the coronavirus (Covid-19) pandemic. These local green spaces have played a critical key role in helping provide a key green space recreational resource during the lock-down restrictions. By actively promoting their redevelopment Walsall Council is promoting inappropriate, damaging and unsustainable patterns of development within the local area, contrary to guidance in paragraphs 11, 92, 98 and 179 of the Revised National Planning Policy Framework (July 2021).
To stop Walsall Council from delivering considerable landscape-scale ecological habitat damage to the local area, and from damaging key urban green space lungs (critical for air quality enhancement) and outdoor green space recreational resources the Pouk Hill public open space site should therefore be: -
- Removed from the "Core Regeneration Area" designation on page 499 (Figure 19)
- Should be specifically designated as an "urban green lung / air quality enhancement area" on the main Policies MAp of the Black Country Plan (2021).
- designated as a "Site of Importance for Nature Conservation (SINC)" on the main Policies Map of the Black Country Plan
- protected by a blanket tree preservation order
- designated as a "key wildlife corridor"

Object

Representation ID: 16168

Received: 23/11/2021

Respondent: Mr Anthony Hook

The Draft Plan appears to be in direct conflict with a number of requirements of the National Planning Policy Framework and the Council’s own policy requirements and design principles, the latter two of which have presumably over time been approved by elected members as part of the democratic process.
Where is the evidence to support the assertion there are insufficient brownfield sites to satisfy the demand for new build housing in Walsall? Of the 13,344 new homes, more than half, 7133 (figure given from a laptop at drop in session on 1st October) or 5418 (identified in the Summary document) are proposed to be built on the green belt with a derisory claim this is only 8% of the Borough total. What is the comparable figure for brownfield sites?
...
The Draft Plan places an unacceptable and unfair burden on the Aldridge/Brownhills area with 5,500 new houses out of a total of 7,100 proposed on the green belt for the whole Borough of Walsall. What is the percentage of green belt land being sacrificed in Aldridge/Brownhills?

Comment

Representation ID: 16331

Received: 11/10/2021

Respondent: Frazer Powell

Please see below my comments on the Walsall MBC section of the above Plan.

In making my comments on the Plan, I have had regard to the following documents:

Black Country Plan: Draft Plan Consultation 16 August – 11 October 2021- Walsall Borough
Summary
Black Country Plan: Green Belt Assessment Summary
Black Country Landscape Sensitivity Assessment Final Report prepared by LUC -September
2019
Black Country Green Belt Study Stage 1 and 2 Report prepared by LUC – September 2019
Walsall Landscape Sensitivity Assessment (Copy attached)

I am particularly concerned regarding the green belt proposals in respect of Calderfields West, Land at Aldridge Road, Walsall and Land off Sutton Road/ Longwood Lane, Walsall. This would involve the development of 794 houses across the two sites if approved.

Before detailing my particular concerns regarding the above two sites, I think it relevant to comment about the consultation arrangements in general.
Walsall MBC has approximately 37% of its land classified as green belt. It is relevant and I would suggest legally crucial to the decision making of both the Planning Committee, Planning Inspector and the Secretary of State that it is explained clearly and transparently how it is decided which sites in Walsall could be removed from the green belt, ie setting out the “exceptional circumstances” test for the amendment of Green Belt boundaries. As I am sure you are aware, the five point criteria used to assess “Exceptional Circumstances is set out in the judgment of Jay J in Calverton Parish Council v Greater Nottingham Council and others (2015).

[Redacted-GDPR]
This e mail has taken me a deal of time and effort to prepare. However, I think it necessary and important that comments be submitted on the planning proposals.
The Councils Planning Committee and the Planning Inspector have a difficult and complex task before them in balancing the various competing interests in a manner which is both lawful and demonstrably fair.

Comment

Representation ID: 16462

Received: 11/10/2021

Respondent: Mr and Mrs Geoff and Joanne Reader

Number of people: 2

7. All parts of the Black Country should have equal access to community facilities. We live in Great Barr and have very few leisure facilities for instance.

Comment

Representation ID: 16509

Received: 03/10/2021

Respondent: Ian Newman

Comments relating to developments in Walsall not covered by the BC Plan

Whilst we’re on the subject of “GREENBELT”, what is going on with the old Fox Hollies Riding Stable area. There are “large” wooden gates to the entrance and there appears to be development work going on, on that land, also the development on the Beacon Dairy Farm site, maybe fourteen to fifteen houses being built but they are to be built, in keeping with the surrounding location. Not sure how this can be because it’s farmland and riding stables with a few co age style businesses in barns or outbuildings, again, hearsay, nothing in black and white, maybe it’s been a private negotiation but you can understand the frustration of the local residents.

Object

Representation ID: 17280

Received: 11/10/2021

Respondent: Mr Paul Wheeler

Local Authority - Walsall Council
As a resident of [Redacted-GDPR] Aldridge [Redacted-GDPR], I wish to raise the following objections to the Black Country Plan 2021, as outlined below.
Several residents have been in contact with local MP Wendy Morton and Walsall Councillor John Murry about this matter since it was raised during the Covid-19 restrictions in 2020. Assurances have been given in writing, there will be no building in Aldridge on the Green Belt land, this has been reiterated today by the Prime Minister and supported by the Mayor of West Midlands, Andy Street, that building on green-belt land is now not on the Governments agenda.
The wedge of green belt land on the junction of Middlemore Lane West and Bosty Lane, which is bounded by Daw End railway cutting, is unsuitable for development for the following reasons: -
1. The site is adjacent to a Site of Special Scientific Interest (SSSI), please see attached Defra plan below.
This is an ancient site as documented on Walsall Council's website, please see https://go.walsall.gov.uk/parks and green spaces/conservation and the environment/sit es of special scientific interest sssis/daw end railway cutting
'The old quarry and railway cuttings at Daw End provide excellent exposures on Wenlock Shale (Coalbrookdale Formation) and the overlying Wenlock Limestone which were deposited during the Silurian Period about 410 million years ago.
These are the best exposures available in Britain for this particular group of rocks. During deposition of the Wenlock Limestone marine organisms grew in patches on the sea bed trapping sediment and forming low mounds or reefs. These patch reefs are well seen in the Wenlock Limestone at this site. This is an important geological locality for the study of the Wen/ock Series in Britain.
2. Any development on this important sensitive site would comprise the existing delicate ecostructure and be extremely detrimental to the wildlife and to the historic flora and fauna of the site and area generally.
3. Heavy industrial goods traffic on the roads bordering the site, makes access to the site difficult. Access to the Middlemore Lane Industrial estate from Bosty Lane is restricted and can only be accessed by a single-track bridge. This already causes significant tailbacks along the section of Middlemore Lane West onto Bosty Lane.
Furthermore, the use of this route by heavy goods traffic is set to increase when the proposed Council recycling centre on Middlemore Lane opens.
4. The junction of Middlemore Lane West and Bosty Lane has been the cause of numerous serious accidents, with some incidents involving the deployment of the air ambulance service. Development on this site will increase traffic at this junction and would be likely to create a high number of incidents without significant improvements to the highway, including the potential to construct a new double-track road bridge over the railway.
5. The development of this green belt site will create additional environmental air pollution and exacerbate the existing noise pollution from the container base.
6. Very limited public transport services in the area, with the local bus service providing a maximum service of two busses per hour. There are currently no public rail links in the area.
7. The green belt creates an important natural division-between the parishes of
Aldridge and Rushall and prevents coalescence. This land provides a much-needed haven for wildlife, and currently includes a haven for several horses which graze the pasture and provides a buffer zone to the SSSI.

Comment

Representation ID: 17290

Received: 11/10/2021

Respondent: Surinder Kaur

Please accept this letter as an objection to the proposed development of: Reedswood Town Park open space, former­ Reedswood Golf Course, Pouk Hill green public open space, and the public open space located north of Churchill Road & the Jane Lane School, and as a request for you act/ vote on my behalf against the proposal.
The proposed development will remove much needed and loved open spaces in the area, that are vital to the environment and people's mental health and wellbeing. They allow residents to re-connect with the natural environment close to home and help escape the stresses of urban life. They were areas of critical importance during the lock-down restrictions, and continue to provide local residents with external spaces for recreation.
The proposed sites, especially Pouk Hill and the public open space north of Chrurchill Road/Jane Lane School should be removed from any future development proposals, as these spaces offer a vital noise & 'green lung' barrier to residents living so close to the much congested and polluting, M6 motorway. Even Walsall Councils own ADMS-Urban Air Quality Model shows how these areas already exceed the acceptable levels of Nitrogen Dioxide (N02), so I urge that these sites are saved and planted with more trees to help improve the air quality and reduce noise levels.
In a time where we are being told to do all we can to reverse climate change and to be mindful of our metal health, it seems ludicrous to be tearing down these open spaces for development
Our local area is already so highly built up that these spaces are all the more precious, and whilst we do understand the need for more housing, building in already densely built up areas, is irresponsible. Residents in this area lack green and open spaces more than other parts of the Walsall borough, therefore, I would suggest that Dudley & Walsall Council look at alternative sites where the impact of green/open space losses would be less detrimental.

Support

Representation ID: 17374

Received: 11/10/2021

Respondent: Mrs Josephine Martin

Safe access onto the busy Queslett Road/|Aldridge Rd will need careful consideration.

Object

Representation ID: 17449

Received: 08/10/2021

Respondent: Mrs Susan Sutton

It is a residental area which will suffer a great deal of disruption, mess, pollution, possible dangerous scenarios.
There are no beneifts to local residents who are paying enourmous amounts of council tax.
We should be protecting nature.
I also feel we should support and improve social housing in areas where it already exists- plenty of those near to WS4.
Who are the faceless people who are making these life changing decisions?
Who is profiting from this proprosal and how?

Object

Representation ID: 17556

Received: 03/10/2021

Respondent: Mr Anthony Smith

I am commenting in relation to the Draft Plan (Walsall Borough Summary) for the Black Country Plan.

I am shocked and very concerned that there is thought being given to building new homes on greenfield sites. It is undeliverable in light of pressing environmental and climate change issues that this could be given any kind of consideration.

I cannot see one bit of evidence that all available brown-field sites in the local area have been exhausted for necessary development. Post pandemic in particular, there must be multiple available sites that could be used.

I am strongly opposed to this reckless and irresponsible plan

Object

Representation ID: 17574

Received: 10/10/2021

Respondent: Mrs Tammy Brimson

I object to the plans to build on Green Belt in Pelsall.
It will destroy one of our very few local areas of undisturbed nature. We will lose an area where we can enjoy the nature that is on our doorstep and which we don't need a car to access. It is a lovely local area and is well used by dog walkers, children and nature lovers and we will have to travel to find similar elsewhere (causing more cars to be on the road, adding to congestion and pollution). It is a very high cost to the environment to lose green belt and agricultural land to housing. To continue to lose these relatively small areas of nature will gradually add up to more damage to the environment as a whole. Please consider the problem of climate change causing problems like flooding etc. To think it will be lost forever is quite devestating and upsetting. I am also concerned about the extra congestion on the roads in the Pelsall area that the considerable number of extra housholds will bring.
Surely there are areas in Walsall and Pelsall that need regenerating, areas of brown belt, derelict and unused buildings that can be bought and developed before considering using Green Belt?

Object

Representation ID: 18005

Received: 11/10/2021

Respondent: Mrs Mary Edwards

These are bullet point reasons for my objection. You will also get a drift of my strength of feeling.

1) Loss of extensive wildlife.
2) Loss of greenbelt area.
3) Loss of important well kept farmland.
4) Massive increased risk of local flooding.
5) Traffic conjestion on Lichfield and Chester Rd leading to Shire Oak lights.
6) Increased traffic pollution.
7) Increased travel times to and from work.
8) Lack of facilities for a massive increase in population.
9) Drop in local house prices.
10) Increased noise pollution.
11) Loss of views.
12) Total lack of time in consulting local residents.
13) Increased waste pollution.

Object

Representation ID: 18026

Received: 11/10/2021

Respondent: Leah Knight

Please accept this letter as an objection to the proposed development of: Reedswood Town Park open space, former Reedswood Golf Course, Pouk Hill green public open space, and the public open space located north of Churchill Road & the Jane Lane School and as a request for you act / vote on my behalf against the proposal.
The proposed development will remove much needed and loved open spaces in the area, that are vital to the environment and people's mental health and wellbeing. They allow residents to re-connect with the natural environment close to home and help escape the stresses of urban life. They were areas of critical importance during the lock-down restrictions and continue to provide residents with external spaces for recreation.
The proposed sites, especially Pouk Hill and the public open space north of Churchill Road / JAne Lane School should be removed from any future development proposals , as these spaces offer a vital noise and "green lung" barrier to residents living so close to the much congested and polluting M6 motorway. Even Walsall Councils own ADMS-Urban Air Quality Model shows how these areas already exceed the acceptable levels of Nitrogen Dioxide (NO2), so I urge that these sites are saved and planted with more trees and shrubs to help improve the air quality and reduce noise levels.
In an time where we are being told to do all we can to reverse climate change and to be mindful of our mental health, it seems ludicrous to be tearing down these open spaces for development.
Our local area is already so highly built-up that these spaces are all the more precious, and whilst we do understand the need for more housing, building in already densely built-up areas, is irresponsible. Residents in this area lack green and open spaces more than other parts of the Walsall borough, therefore, I would suggest that Dudley & Walsall Council look at alternative sites where the impact of green/open space losses will be less detrimental.

Object

Representation ID: 18452

Received: 05/10/2021

Respondent: Mr Nigel Roden

Healthcare:
Why isn't this included? My neighbourhood was promised 4 years ago, a new health centre in Hatherton Road, Walsall and I am struggling to find out what is happening. I was hopeful that this would have been included - please advise.
Please ensure that highly important issues like this are better communicated - you cannot rely on social media alone. The fact that so many of my neighbours (of all ages) were not aware or were confused about the proposal, is extremely poor. Please confirm how you have communicated this important subject and over what timescale.

Object

Representation ID: 19265

Received: 11/10/2021

Respondent: Mr Ryan Baker

The proposal to build on the greenbelt will destroy natural habitat where a large number of wildlife are living including [REDACTED] along with many others.
Not only this but it will remove an area that sees a lot of foot traffic from dog walkers, hikers and elderly that use it as one of the few places they can use as it is right on their doorstep.
This greenbelt is one of the biggest pros to living in the local area as it is getting harder to find homes in such beautiful areas.
The council planted most of the trees there 20 years ago to help create this area so it seems crazy to undo all that work to build on an area that in places gets very small meaning that anything built there would simply be squashed in.
The local area will not benefit from any of this, not to mention the disruption and damage that will be caused from the proposal.

Comment

Representation ID: 21195

Received: 06/10/2021

Respondent: Mrs Margaret Owen

Consideration should also be given to light pollution particularly in the area of what I believe to be designated a ‘ Dark Sky’ area ( Barr Beacon).

Support

Representation ID: 21200

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Representations of Taylor Wimpey – Land at Barns Lane, Walsall
Avison Young (‘AY’) is instructed by Taylor Wimpey Strategic Land (‘Taylor Wimpey’) to prepare and submit representations to the Draft Black Country Plan (Regulation 18) consultation (‘Draft Plan Consultation’). Taylor Wimpey controls land at Barns Lane, Aldridge (‘the site’), edged red on the Site Location Plan attached to these representations at Appendix I.

Taylor Wimpey has reviewed the Black Country Authorities’ (‘BCAs’) consultation document and wishes to make representations on it. This letter should, therefore, be taken as Taylor Wimpey’s comprehensive response to the consultation. It should be read alongside the completed response form that we have provided as part of the representations.

In particular, our Client welcomes the Draft Plan’s recognition that the site can, and should, deliver a development that is capable of materially contributing to Walsall’s, and the Black Country’s housing requirements. In this respect, Policy HOU1 (site ref. WAH251) allocates the site for 112 dwellings.

Notwithstanding the support for the site’s allocation, these representations made by Taylor Wimpey make a number of observations on the policies contained within the Draft Plan and the emerging evidence base that underpins the draft policies and allocations contained in the Plan.

With these introductory points in mind, the remainder of our submission goes on to:
• describe our Client’s site and the merits of it as a development opportunity;
• provide our Client’s response to the Draft Plan consultation; and
• summarise the key points arising and overarching conclusions.

We address each of the above in turn.
Taylor Wimpey’s Land at Barns Lane
The site extends to 4.3 hectares (ha) and is located on the western edge of Aldridge, along Barns Lane. It consists primarily of arable farmland and associated buildings. To the south and southwestern edges of the site, the site is bound by existing residential dwellings along Barns Lane. To the north east lies a lake known locally as The Swag, along with Aldridge Sailing Club. To the northwest, the site is bound by Barns Lane Pool and Nature Reserve.

The site is positioned in a highly sustainable location, approximately 1.5 miles (2.4km) north west of the centre of Aldridge and 1.2 miles (1.9km) south of the centre of Shelfield, both of which contain a range of facilities and employment opportunities. Bus stops are located directly opposite the site along Barns Lane and are served by routes 35 and 35A, which provide frequent services to Walsall, Lichfield and Castlefort.

Taylor Wimpey is in the process of appointing a team of technical consultants and masterplanners to carry out various surveys and investigations and use these to comment on the development potential of the site. The findings will be published in a Development Statement and will be submitted to Planning Officers at Walsall Council in due course, who have agreed to accept the submission of additional supporting information after the Draft Black Country Plan consultation deadline. Nevertheless, Taylor Wimpey has, for the purposes of demonstrating the deliverability of the site, prepared an Illustrative Masterplan (attached to these representations at Appendix II), which demonstrates that the site is capable of accommodation approximately 130 dwellings at a density of 35 dwellings per ha. This is subject to further technical investigation.

Housing Allocations

In order for the Draft Plan to be sound it must provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the Plan period. Because the BCAs must also identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against its housing requirement, the Draft Plan is also required to identify specific, deliverable sites for years one to five of the plan period and then sufficient developable sites, or broad areas of growth, for the remainder of the plan period.

The Glossary to the NPPF defines ‘deliverable’ sites as being available now, offering a suitable location for development. In order for a site to be considered ‘developable’ it should be in a suitable location for housing development with a reasonable prospect that it will be available and could be viably developed at the point envisaged.

Our Client welcomes the Draft Plan’s recognition that the site can, and should, deliver a development that is capable of materially contributing to Walsall, and the Black Country’s housing requirements. The site is available, offers a suitable location for development and is achievable with a realistic prospect of delivering housing within the first five years of the plan period.

Comment

Representation ID: 21216

Received: 11/10/2021

Respondent: Quadrant Estates

Agent: Quadrant Estates

We are instructed by our client, Walsall Bescot RP Limited (c/o Quadrant Estates), to submit representations to the Draft Black Country Plan 2039 (Regulation 18) Consultation which is being jointly prepared by the four Black Country Authorities (Dudley, Sandwell, Walsall and Wolverhampton). Our client has a site which lies in the jurisdiction of Walsall Council at Bescot Retail Park, Walsall, WS1 4SB (‘the Site’) of which they own the freehold.

We set out below the background behind our clients’ interest in the emerging planning policy within the Draft Black Country Plan 2039 (‘the Plan’) before addressing the relevant employment policies and outlining how the Site should be included going forward.

The consultation expires on 11th October 2021 and we therefore trust these representations will be taken into account.

1 Background
Walsall Bescot RP Limited own Bescot Retail Park which is managed by Quadrant Estates (‘Quadrant’). In view of the changing nature of the retail sector, Quadrant is exploring potential redevelopment opportunities to repurpose existing asset for alternative uses. Indeed, Quadrant have recently undertaken a pre-application meeting (ENQ/0132) with Walsall Council to discuss the potential of redeveloping the Site for employment uses.

Bescot Retail Park has previously been identified as a suitable site to deliver employment development. The Site benefitted from a draft employment allocation within the Issues and Options Site Allocations Document which underwent consultation in 2013 (site ref. IN309). The Site assessment stated that it was suitable for industrial uses due to it adjoining an existing industrial area (Bescot Crescent); and its proximity to Junction 9 of the M6. Its release for employment uses was dependent on the ceasing of the current retail use. However, at that time the existing retail use was performing well and a number of tenants had several years remaining on their leases. This position is now changing.

The feedback from the pre-application meeting, held on 5th October 2021, was positive and Quadrant were encouraged to submit representations to the Regulation 18 Consultation.

These representations outline the potential for the Site to be allocated within the Plan for employment uses but also state the need for the existing use (retail) to be recognised and respected. Whilst the potential for industrial should be promoted, the existing uses need protecting and therefore this letter requests a flexible approach to the allocation of the Site to be adopted.

2 Employment Policies
The Draft Black Country Plan 2039 (Regulation 18) Consultation will direct where new development will be locate up to 2039. Crucially it will also guide key issues such as employment land, answering key questions such as:
• Where does employment land need protection?; and
• How much new employment land is needed and where should it go?

The Plan includes a number of draft policies as well as a Policies Map and these have been considered against Quadrant’s intentions below.

Policies Map
It is understood that given its previous history, the Site was not included within the Black Country Economic Development Needs Assessment Stage 1 Report (May 2017). This is one of two documents which forms the evidence base for the emerging policy. The Site has therefore not been considered to date and therefore is currently shown as ‘white’ unallocated land on the draft Policies Map.
Quadrant wish for Bescot Retail Park to benefit from an employment allocation and it is proposed that the land is allocated as “Land for Employment” (Policy EMP1) or as a “Local Employment Area” (Policy EMP3). This is a natural extension to neighbouring Strategic Employment Allocation in which the remaining land at Bescot Crescent benefits from. The allocation will differ from the neighbouring allocation but this is necessary to protect the existing use in the short term. The medium to long term future of the Site currently looks to lie in employment uses and therefore this allocation will still assist in this land coming forward for employment uses within the Plan period.

However, it is vital that this future allocation must recognise that it is still an active retail park with tenants and the allocation should reflect this. The employment allocation cannot prejudice the existing use. The NPPF at Paragraph 81 outlines the need for “planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt.” Indeed, this will allow the Site to adapt when the time is right and continue to be occupied, employment generating and an asset to Walsall.

Policy EMP1
This policy, titled ‘Providing for Economic Growth and Jobs’ seeks to ensure there is a sufficient quantum of development opportunities in order to meet the employment needs of the Black Country economy.

The Site can help meet the large 164ha target for Walsall by providing another 5.14ha of employment land. Not only this but the land should be considered high-quality, given the neighbouring uses, existing use and proximity to the M6 as well as the A4148. The allocated employment land for Walsall would therefore increase to 169ha.

Within Policy EMP1 at ‘4’ we suggest the following amends to the policy to ensure that allocated employment sites, such as Bescot Retail Park, have their individual needs acknowledged:
“The key clusters of sites are shown on the Employment Key Diagram and individual sites listed in Chapter 13: Sub-Areas and Site Allocations. These sites will be safeguarded for industrial employment uses within Use Classes E(g)(ii), E(g)(iii), B2, and B8, unless stated otherwise.”

The Site will need to be described fully in Chapter 13 of the Plan, specifically within Table 36 under ‘Further Information’. Here it will need to include that whilst the land is allocated for employment uses it is an existing retail park and due respect and flexibility must be applied to recognise the current use. This will ensure that the existing use is recognised and not prejudiced in the short term.

This approach gains support from the NPPF at Paragraphs 81 and 82. At 82 d it states that planning policies should:
“be flexible enough to accommodate needs not anticipated in the plan… and to enable a rapid response to changes in economic circumstances.”

Policy EMP3
This Policy allocates and describes Local Employment Areas which would be a suitable allocation for the Site in the emerging Plan subject to the suggested changes below. Given the Site is a long standing, well-established commercial and industrial location it would be entirely suited to this allocation as it is characterised by “a critical mass of industrial, warehousing and service activity with good access to local markets and employees” as stated within the draft policy.

However, in order for the policy wording to ensure the short-term protection of the retail use in the short term and to allow suitable flexibility to the SIte, we propose the following amends at ‘2’ and ‘3’:
“These areas will provide for the needs of locally-based investment and will be safeguarded for the following uses;
a) Industry and warehousing (E(g)(ii), E(g)(iii)), B2 and B8 use)
b) Motor trade activities, including car showrooms and vehicle repair
c) Haulage and transfer depots
d) Trade, wholesale retailing and builders’ merchants
e) Scrap metal, timber and construction premises and yards
f) Waste collection, transfer and recycling uses as set out in Policy W3
g) any existing uses.
3) Not all areas will be suitable for all uses and any existing uses should be taken into consideration.”

The above amended will ensure that the Site’s existing use will be recognised going forward and duly taken into account. Again, this approach gains support through Paragraphs 81 and 82 of the NPPF.

3 Summary
In view of the changing nature of the retail sector, which has seen a notable contraction of large format retailers, Quadrant is exploring potential redevelopment opportunities to repurpose the existing asset for alternative uses. Having gone through a positive pre-application with Walsall Council, it was encouraged that representations were submitted to this Regulation 18 Consultation to express how the Site could be allocated as an employment site.

Quadrant are therefore looking for the Site to be allocated for employment uses. However, key to any future allocation being accepted, any allocation or policy wording relating to the Site will need to recognise the need for the short-term use (retail) to be safeguarded or for due flexibility to be applied.

The retail park remains active and with a number of tenants still trading. Whilst an application for redevelopment for industrial uses is envisaged in the short term, given the existing tenants are still in occupation, redevelopment is more likely to come forward in the medium term. Any future allocation or site-specific policy will need to reflect this and not prejudice the current retail use.

Object

Representation ID: 21312

Received: 11/10/2021

Respondent: Mr Ronald Stevens

Ref: Black Country Plan (BCP) (Review) (August 2021} Regulation 18 public consultation document.
Dear Cllr Gaz Ali,
Please accept this letter as an objection to the proposed development of; Reedswood Town Park Open Space, former Reedswood Golf Course, Pouk Hill green open space, and the public open space located north of Churchill Road & the Jane Lane School, and as a request for you act/vote on my behalf against the proposal.

The proposed development will remove much needed and loved open spaces in the area, that are vital to the environment and people's mental health and well being. They allow residents to re-connect with the natural environment close to home and help escape the stresses of urban life. They were areas of critical importance during the lock-down restrictions, and continue to provide local residents with external spaces for recreation.

The proposed sites, especially Pouk Hill and the public open space north of Churchill Road/Jane Lane School should be removed from any future development proposals, as these spaces offer a vital noise and 'green lung' barrier to residents living so close to much congested and polluting, M6 motorway. Even Walsall Councils own ADMS-Urban Air Quality Model shows how these areas already exceed the acceptable levels of Nitrogen Dioxide (NO2), so I urge that these sites are saved and planted with more trees to help improve air quality and reduce noise levels.

In a time where we are being told to do all we can to reverse climate change and to be mindful of our mental health, it seems ludicrous to be tearing down these open spaces for development.

Our local area is already so highly built up that these spaces are all the more precious, and whilst we do understand the need for more housing, building in already densely built up areas, us irresponsible. Residents in this area lack green and open spaces more than other parts of the Walsall borough, therefore, I would suggest that Dudley & Walsall Council look at alternative sites where the impact of green/open spaces losses would be less detrimental

Object

Representation ID: 21374

Received: 11/10/2021

Respondent: Mrs S Tullo

Dear Cllr Gaz Ali,

Please accept this letter as a objection to the proposed development of : Reedswood Town Park Open Space, former Reedswood Gold Course, Pouk Hill green open space, and the public open space located north of Churchill Road & the Jane Lane School, and as a request for you to act/vote on my behalf against the proposal.

The proposed development will remove much needed and loved open spaces in the area, that are vital to the environment and people's mental health and wellbeing. They allow residents to re-connect with the natural environment close to home and help escape the stresses of urban life. They were areas of critical importance during the lock-down restrictions and continue to provide local residents with external spaces for recreation.

The proposed sites, especially Pouk Park and the public open space north of Churchill Road/Jane Lane School should be removed from any future development proposals, as these spaces offer a vital noise & green lung barrier to residents loving so close to the much congested and polluting M6 Motorway. Even Walsall Council owns ADMS-Urban Air Quality Model shows how these areas already exceed the acceptable levels of Nitrogen Dioxide (NO2), so I urge that these sites are saved and planted with more trees to help improve the air quality and reduce noise levels.

In a time where we are being told to do all we can to reverse climate change and to be mindful of our mental health, it seems ludicrous to be tearing down these open spaces for development.

Our local area is already so highly built up that these spaces are all the more precious, and whilst we do understand the need for more housing, building in already densely built-up area, is irresponsible. Residents in this area lack green and open spaces more than other parts of the Walsall borough, therefore I would suggest that Dudley & Walsall Council look at alternative sites where the impact of green/open space losses would be less detrimental.

Yours sincerely,

Object

Representation ID: 21516

Received: 04/10/2021

Respondent: John Lawton

With regard to the proposed plans to release land on pouk hill,golf coarse area next to Sainsbury's,reedswood park and the land opposite Jane lane school ,churchhill road for building houses and industrial use istrongly object,these area reduce pollution from the motorway and are the only open green space in the area,I also strongly object to the lack of consultation on these proposals,I have informed my local councillor and intend to inform my MP , blatant lacof proper procedure,nimbys in action

Comment

Representation ID: 22171

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

The Club have previously submitted representations to the Black Country Call for Sites Consultation. These representations proposed the removal of a parcel of land at the entrance to Druids Heath Golf from the Green Belt and its allocation for residential development. The site has not, however, been identified as a proposed residential allocation in the Regulation 18 consultation document.

The land in the Club’s control that that was subject to the previous Call for Sites representations constitutes site SA-0063-WAL – Land at Druids Heath Golf Club, Stonnall Road, in the Black Country Plan Site Assessment Report (“BCSAR”). It is concluded that the site is unsuitable for development. In essence, and incorrectly, the BCSAR concludes that the vehicle movements and activities associated with a golf club are incompatible with residential development. It is suggested that the development would have an “awkward” relationship with the clubhouse and its associated carparking. As detailed in these representations this is clearly not the case, as golf clubs adjoining residential development are commonplace. Indeed, vehicles traveling to the Club have to pass along residential roads to gain access to the site. Furthermore, the emerging Plan is proposing residential development in this location on land immediately adjacent to this site (proposed allocations WAH253). This allocation has an almost identical relationship to the clubhouse and its car park. This approach is clearly inconsistent

In addition to site SA-0063-WAL the Club are requesting that additional land is allocated for development. The full extent of the land in the Club’s control that is being promoted for development is shown on the Plan attached at Appendix 1. It is suggested that site SA-0063-WAL should be extended to include the area of car parking to the east. This results in this site becoming part brownfield and part greenfield. If the car park is allocated for development the parking will be replaced elsewhere within the Golf Club. The construction of a new car park would constitute an “engineering operation” and would, therefore, fall within “certain other forms of development” that are not inappropriate development in the Green Belt as defined by paragraph 150 of the Framework. The second parcel of land is located to the east of the Stonnall Road, immediately to the north of proposed allocation WAH 253.

It should be noted that the Club are promoting the development of these sites in order to help generate funds that will be ploughed directly back into the Club. The Club have identified a range of projects that cannot currently be afforded. The sale of this land for residential development will generate funds that can be invested to improve club facilities and help retain and attract new members. Nationally golf club membership levels have fallen over the last 10 years with a large number of clubs closing. Additional investment in the Club will help ensure its long term future.

We have reviewed the draft plan in detail and give our observations and representations below. It is clear to us that, notwithstanding the undoubted work which has gone into preparing the plan, it is extremely unlikely that the plan as currently drafted will achieve the objectives for housing in the Black Country and further sites are required. The land owned by the golf club can only help in this regard and, for the reasons set out below, is more appropriate than the adjoining land which is in the draft plan. Also the provisional reasons for its non inclusion are not supportable when analysed in more detail.”