C. Walsall

Comment

Representation ID: 22201

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Druids Heath Golf Club additional land (adjacent to SA-0309-WAL)

In addition to the above site the Club are proposing the allocation of a parcel of land located to the south of the Stonnall Road between the north eastern edge of proposed allocation SA-0309 and a residential property. It comprises a single agricultural field with no features of note. This site forms an obvious extension to proposed allocation SA-0309. The site performs well against all the assessment criteria identified in the BCSAR. To confirm:

Green Belt Harm – Whilst the site is within the Green Belt, Green Belt land release is required to meet the housing target. The development of this site will not extend into the Green Belt to the same degree as proposed allocation SA-0309. It is well contained and has strong boundary features.

Landscape Sensitivity – The site is flat and featureless. It has no particular landscape sensitivity. The development of site SA-0309 will change the nature of this location and this site will become an obvious rural transition site.

Greenfield/PDL – Whilst the site is greenfield, greenfield land release is required to meet the housing target.

Topography – The site is generally flat.

Agricultural land quality – The site is too small to be used for agricultural purposes.

TPO / Trees – There are no trees within or on the edge of the site.

Biodiversity – There are hedgerows along the edge of the site that can be retained. The site itself has no other biodiversity features of interest.

Heritage Assets – The development of the stie will not adversely impact any heritage assets.

Visual Amenity – The site can be developed to respond to the layout of proposed allocation SA-0309. There is a residential property to the north east, however, it sits within a large plot and it does not constrain development.

Flood Risk – The site is within Flood Zone 1.

Ground Contamination – The site has not previously been developed, there are no records of any ground contamination.

Air Quality – The site is not in a Nitrogen Dioxide Area of Exceedance Zone 2015

Noise – There are no nearby noisy uses.

Minerals – the site is too small to extract minerals from.

Waste Infrastructure – There are no waste infrastructure constraints.

Social Infrastructure – The site has the same access to services and facilities as proposed allocation SA-0309.

Give the lack of constraints and its suitability for development it is our view that this parcel of land should also be allocated for development within the Plan.

Support

Representation ID: 22485

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Green Belt site delivery in Walsall
Notwithstanding our concerns regarding Dudley’s site selection process, we support the Black
Country’s efforts to identify housing growth within the Green Belt. Across the Black Country, the
Draft Plan appears to release land capable of delivering 7,720 dwellings within the Green Belt up to
2039. The vast majority of this supply arises from Walsall, which is proposing 5,418 dwellings up to
2039 on Neighbourhood Growth Areas identified within the local authority’s Green Belt.

South Staffordshire does not object to the sites selected in the Walsall area, subject to cross-
boundary working to understand and mitigate any cross-boundary infrastructure impacts.
However, we do have concerns that the figures given in the Draft Plan for the selected sites under-
represent their true contribution to housing supply within the plan period (i.e. up to 2039). Having
reviewed the sites in Tables 30 and 31 of the Draft Plan, we consider that the true capacity of the
selected Neighbourhood Growth Areas identified in Walsall is likely to be around 1,715 dwellings
higher than the figure given in the consultation document. This is due to what appear to be overly
conservative estimates of larger site delivery affecting five housing sites allocated in the Walsall
area. The site-specific reasoning behind this is given in Appendix 2 of this response, but in
summary assumptions used to estimate site delivery up to 2039 appear to be contrary to the
assumptions given in paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study
(May 2021).

We would request this matter is revisited to ensure that the true capacity of Green Belt release in
Walsall is reflected in the submitted plan. Failing to do so will put unnecessary pressure on Green
Belt elsewhere in the Black Country and in other neighbouring authorities.

Comment

Representation ID: 22489

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

Appendix 2 – South Staffordshire comments on Walsall Green Belt site delivery [table] [See attachment]

[Table headers:] Site Reference/Address/Claimed delivery
potential (Black Country)/Estimated delivery potential (South Staffordshire)/Comments [appear below these]

WAH232 Yieldsfield Farm
(sometimes recorded as
Yieldfields farm), Stafford
Road, Bloxwich

978 (600 dwellings
by 2039)

978 by 2037 This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 dpa build rate



WAH234 Land between Queslett
Road, Doe Bank Lane and
Aldridge Road, Pheasey

1426 (960 dwellings
by 2039)

1426 dwellings by
2039

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 – 200 dpa build rate on sites significantly above 500 dwellings (implying a maximum potential
capacity of between 1,200 – 2,400 dwellings up to 2039)



Based on the above assumptions, the site only needs to achieve a 118 dpa build rate to be delivered
fully in the plan period. Given the site’s size and the recommended range of 100 – 200 dpa given in
the May 2021 report for such sites, it seems realistic to assume the site will be completed within the
plan period.



WAH235 Home Farm, Sandhills,
Walsall Wood

1417 (800 dwellings
by 2039)

1417 dwellings by
2039

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (4 years max. lead-in time)
- 100 – 200 dpa build rate on sites significantly above 500 dwellings (implying a maximum potential
capacity of between 1,200 – 2,400 dwellings up to 2039 on large sites in the Black Country)



Based on the above assumptions, the site only needs to achieve a 118 dpa build rate to be delivered
fully in the plan period. Given the site’s size and the recommended range of 100 – 200 dpa given in
the May 2021 report for such sites, it seems realistic to assume the site will be completed within the
plan period.



WAH238 Land at Vicarage Road /
Coronation Road, High
Heath

504 (400 dwellings
by 2039)

504 dwellings by
2035/36

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (3 years lead-in time, reflecting greenfield site)
- 50 - 60 dpa build rate (assuming one outlet)



WAH242 Calderfields West,
Aldridge Road, Walsall

592 (442 dwellings
by 2039)

592 dwellings by
2036 - 2038

This is based on the plan being adopted in 2024 and the following assumptions set out in
paragraphs 4.55 – 4.69 of the Black Country Plan Viability and Delivery Study (May 2021):
- Build commencement 2028 (3 years lead-in time, reflecting greenfield site)
- 50 - 60 dpa build rate (assuming one outlet)

Object

Representation ID: 22514

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Paragraph 4.3-4.17 The site assessment SA-0066-WAL is challenged in response of the assessment of harm to green belt purposes and the size of the parcel assessed for the Landscape assessment which includes 'high value' features for which would not be within the setting or can be mitigated for. The sustainable credentials of the site are also commented on and argued.

Object

Representation ID: 22609

Received: 11/10/2021

Respondent: Mrs Michelle Parry

WAH233
Local Authority - Walsall Council
As a resident [personal details redacted] 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: -
The site is adjacent to a Site of Special Scientific Interest (SSSI), please see attached Detra 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 Wenlock Series in Britain.
2. Any development on this important sensitive site would comprise the existing delicate eco-structure 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.
[plan included in main representation]

Object

Representation ID: 23166

Received: 28/09/2021

Respondent: Mr + Mrs Mr + Mrs Corry

Number of people: 2

Queslett Road East/Aldridge Road

This is Green Belt land
Also this amount of New Homes (960) we do not have the schools or Doctors and other facilities. for them. We have lived here for 49 years

Object

Representation ID: 23224

Received: 11/10/2021

Respondent: Member of Parliament

As one of the thirteen Members of Parliament in the Black Country area I welcome the opportunity to comment on the proposed new Draft Plan that includes my Aldridge­Brownhills constituency.
In recognizing that there is a requirement on the part of all local planning authorities to undertake a Local Plan that identifies where development will take place over a 20-year framework, the Plan in its current form is significantly flawed particularly in the Borough of Walsall and in large parts of the eastern flank of the Borough which includes the entire Aldridge-Brownhills constituency.
Throughout this submission I wish to outline how in repeated instances the land proposed in the Plan, which for a large part is for development on designated Green Belt, fundamentally goes against public opinion and planning guidance. Whilst accepting that there are to be further iterations of this document it is important that these concerns are expressed at this stage of the process, and addressed.
I note that under the heading 'What does this mean for Walsall?" the following figures are quoted: ­
• Additional Land needed to build additional homes: 13,344
To be provided as follows:­
• Urban areas and Brownfield sites: 7,928
• Green Belt sites: 5,418
However, throughout the proposed Plan there is no information available to explain the rationale for how these figures have been derived. Furthermore, if these figures are extrapolated over a 20 year period they are likely to be over exaggerated, and certainly not reflective of need.
The Office for National Statistics states:­ "The UK population growth rate from mid-2018 to mid-2019 was at 0.5% slower than any year since mid-2004".
In addition it states:­ "migration has continued to be the main driver of UK population growth since the 1990s".
On the basis that there is falling migration and a falling UK population growth rate, the forecast number of homes used for the purpose of the Black Country Plan is over exaggerated and must be revised downwards before moving forward. Furthermore it takes no account of the impact on business or housing needs as we emerge from the Coronavirus pandemic.
Yet for the purpose of the Black Country Plan there is an inbuilt assumption that these figures are accurate, thus locking communities across my Aldridge-Brownhills constituency into a plan that is fundamentally unfair and which at its heart devastates several of our most valuable Green Belt sites and our natural environment, at a time when the focus should be on building back better, greener and more sustainably. A key way to achieve this is to develop on brownfield sites first, of which we have many across the West Midlands, and focus as a priority on our town and urban/district centres.
Constituents from across Aldridge-Brownhills would be forgiven for not sharing the sentiments set out in the Black Country Plan where in Paragraph 4.6 it states:­
"The BCP adopts a brownfield-first approach to maximise delivery of development within the urban area".
As a community we are on the urban fringe of the West Midlands 'Metro' conurbation and I am still seeking to understand in the Borough of Walsall the extent to which that policy has been put into practice.
Furthermore in the same paragraph the authors of the Plan undermine their opening statement by declaring:­ "however, poor ground conditions are a legacy of the Black Country's mining and industrial past are a significant constraint, in both physical and financial terms". This assertion must be challenged.
In recent years, we have seen the steps taken and significant investment to successfully assist with the remediation of brownfield sites for housing. The United Kingdom is on the verge of playing global host to the UN Climate Change Conference (COP 26), yet it is unclear what full and proper assessment has been undertaken of all available brownfield sites in my constituency ahead of proposing large swathes of development on existing Green Belt sites.
It is extremely disappointing that the Black Country Plan fails to live up to its brownfield first policy aspiration, nor even recognises the value and multiple benefits that such a policy and protections would create.
By failing to live up to that policy the Green Belt will undoubtedly be sacrificed first, our communities and environment damaged and the opportunity to regenerate urban and brownfield sites lost for a generation, if not forever.
Turning again to the figures on which this Plan is based and even on the basis of the flawed starting point of 13,344 units required over 20 years, this equates to 667 units per year.
Adopting an urban and brownfield sites first policy would provide 12 years of homes without having to touch any of the Green Belt sites.
If the trajectory of population growth continues to fall and migration flows reduce, the preservation of our Green Belt would endure for longer, if not indefinitely, whilst housing need can be met on brownfield sites, and our towns and district centres are regenerated and reinvigorated to be able to meet the challenge of the post Covid-19 era and provide the needed homes.
Without such a commitment to uphold the development of brownfield sites first, developers will simply continue to choose Green Belt sites over brownfield sites seeing them as the easier and cheaper model for development.
The stated aims of the Green Belt and the protections that it is given are well documented. There should be no de-designation of existing Green Belt.
As identified in the National Planning Policy Framework, the Green Belt serves 5 key purposes. Key amongst those objectives is to check the unrestricted sprawl of large built up areas.
On all of the key sites identified on Green Belt land in my Aldridge-Brownhills constituency, these principles are being set to one side to meet questionable targets and quotas that for the reasons I have identified above have not been justified in the Plan.
The Plan states, "the density of housing development in the existing urban areas will be increased to ensure that the land is used efficiently". There is widespread support to ensure the better utilisation of existing development land especially were it allows an increase in density and infilling for new homes, however there are no details or examples contained within the Plan as to how this can be fully achieved.
Whilst such an approach is to be welcomed, to fully understand whether this approach has been adopted by the Plan more information is required, particularly to understand if these are reflected in the proposed numbers.
Strategic Priorities 3 and 4 contained within the Plan carry widespread public support: ­
"to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents".
"to improve and diversify the Black Country housing offer".
However, the proposed Plan identifies a large number of sites within the Aldridge-Brownhills constituency that will certainly not meet the identified strategic priorities as set out. The average spend by a first time buyer across England stands at £205,246. Average house prices in Aldridge, Pelsall and Streetly all stand above the average first time buyer rate and the West Midlands average.
Indeed, in the case of two of the proposed sites (Aldridge Road/Queslett Road East and Stonnall Road) average prices based on the West Midlands average are between 51% and 110% higher.
Several of the current proposed sites will not manage to meet the stated objectives in these strategic priorities, they could in fact further fuel levels of unaffordability as this proposed plan will not provide the necessary housing mix.
In seeking to achieve a balanced plan, I applaud the aim of seeking to enhance the vitality of our town centres. Key Government support projects prior to and since the Covid-19 pandemic seek to recognise the changing face of our High Streets and Village Centres.
Yet the Black Country Plan fails to take full advantage of any changing High Street within my own constituency. All of the development is predominately focussed on existing Green Belt sites and on the outskirts of Village Centres well away from our High Streets.
Transport Infrastructure and the enhancement of sustainable and active travel are to be applauded and should be central to any development plan, but it is unclear from within the proposed plan how this will be underpinned by the current document.
A number of the proposed sites across Aldridge-Brown hills currently suffer from severe daily congestion, including Aldridge Road/Queslett Road East, Wolverhampton Road, Pelsall Road/Clayhanger junction and Stonnall Road.
Large parts of the road network cannot cope with the existing number of properties/vehicles, in the case of the proposed Aldridge Road/Queslett Road site the imposition of 960 properties most of which would turn right towards Birmingham would lead to even further increased gridlock in both directions given at the same time more than 1,900 school children are currently seeking to access the existing road network.
Whilst constituents would welcome steps towards more sustainable levels of transportation, it is highly questionable as to whether we can justify attempting to take these vital necessary steps when there is a lack of detailed transport modelling to accompany the proposed plan.
Further, Paragraph 4.9 supports the fact that this has not happened and only remains 'on-going'. Improved sustainable travel will not account for the loss of the natural environment with large swathes of Green Belt being lost for a future generation.
No proper thinking has underpinned education needs and the impact that the proposed sites in Aldridge-Brownhills would place on the already pressured school network. With large numbers of schools across the constituency already at capacity and the pressure of the additional number of homes being proposed, I am concerned as the Member of Parliament that schools would not be able to accommodate such an influx of new development.
Equally, across my Aldridge-Brownhills constituency, we have witnessed in recent years an increase in the amount of flooding that has taken place in areas where the Black Country Plan has proposed a large number of these new properties. Areas such as Wolverhampton Road and Aldridge Road/Queslett Road East sites have had repeated instances of flooding in recent years including the flooding of homes.
To remove even more natural soakaway in several of these areas would have a detrimental effect on existing residents. This should not be overlooked at the initial stages of site allocation/preference in this Plan as it should include work on the existing drains and sewers too.
The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.
Whilst acknowledging that the current consultation has worked within the framework of the statutory guidelines set down, I do not believe that it has worked within the spirit.
A more rigorous communication plan should have been in place to raise the spectre of the importance of this consultation particularly in areas which could potentially be most affected by any future plan to implement.
In my own constituency Councillors alongside volunteers have been left to play their civic role in seeking to encourage large-scale participation, but we all believe that this should have been backed up with greater central co-ordination.
There is widespread understanding amongst residents from my Aldridge-Brownhills constituency that we need to plan new homes for future generations, the only question we would ask is do we have to facilitate these whilst destroying some of our most precious Green Belt and Open Spaces?
The latest iteration of this Plan is unacceptable to me as the Member of Parliament for Aldridge-Brownhills and to large numbers of my constituents who have contributed to this consultation.
In responding to your consultation, I am insisting, on behalf of the constituency of Aldridge­ Brownhills, that the Black Country Plan lives up to its own aspiration to promote a development policy of Brownfield First.
As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.
Green Belt sites can only be developed once, and we owe it to all the future generations of this country in an era of environmental vigilance to protect designated Green Belt sites and adopt a policy of Brownfield First development. On behalf of my constituents from Aldridge­ Brownhills I urge the next iteration of this strategy to do exactly that.

Support

Representation ID: 23435

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

10.1 The strategy for Walsall is set out at paragraph C.8 in Chapter 13 of the draft Black Country Plan, which is as follows:

‘In the future, Walsall will be a more confident place, with renewed investment in key infrastructure and key centres, greater opportunities for work and leisure and an affordable, accessible housing stock.’

10.2 We are supportive of this strategy

10.5 We strongly support the proposed Neighbourhood Growth Areas and consider that land at Yieldfields can contribute to the aims for these areas. In Walsall, the Site extends to 38.9 hectares and has the potential to deliver up to 978 new homes alongside the provision of a 2 form entry primary school, a Community Hub, local health centre, significant open space and informal sports provision in a sustainable location. The Site will also seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement.

Comment

Representation ID: 43832

Received: 11/10/2021

Respondent: Mrs Val Rutter

I am greatly concerned by the proposed reduction in the Green Belt and the resultant loss to fauna and flora and to recreational amenities for the local populous.

Great Barr Conservation Area (Walsall) – the proposed reduction in the area does not seem to gain anything other than to weaken its cohesiveness. Splitting off the Beacon removes it from its importance with Great Barr Hall. Likewise with Great Barr Golf Course, surrounded as it is with ancient heritage in Merrions Wood, Chapel Farm and other historic buildings. The Course itself represents the remainder of the medieval deer park. All this would suggest the likely chipping away at the area and the loss of a unique area which has changed little since at least the 1600s.

Comment

Representation ID: 43836

Received: 25/02/2022

Respondent: Rev Martin Rutter

Great Barr Conservation Area (Walsall MBC) - Although I agree with the proposals to identify and protect individual properties, the proposed reduction of this area back to the 1996 lines allows for the weakening and chipping away at the area with potential new or inappropriate development. The Conservation Area is a unique historical area around Great Barr Hall, now so sadly dilapidated.
Splitting off Barr Beacon loses the impact that the Scott Family used to fly the flag from there when in residence. This was not a view for themselves but for the locality and the Beacon was very much part of their estate as shown in the various paintings of that time. Similarly, although Great Barr Golf Course is a more modern invention, it is surrounded by the historical Merrions Wood, Chapel Farm and other ancient buildings and features. Indeed the whole network of Lanes goes back to the 1600s with a richness of flora and fauna associated. If the removal of the Golf Course from the Conservation area takes place then this delicate balance, history and green lung can be chipped away. I would argue for the Conservation Area to remain intact as at present.

Object

Representation ID: 44958

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Chester Road, Streetly

24.15 Taylor Wimpey notes that Land at Chester Road Streetly has not been allocated for residential development and objects to the Draft BCP on this basis.

24.16 For the reasons set out in these representations, it essential that further housing sites are allocated in the BCP. This will involve the release of additional Green Belt land as insufficient alternative land is available to meet housing needs.

24.17 A Delivery Statement, which sets out the reasons why the Chester Road site is suitable for allocation, has been submitted to the Council previously and also submitted alongside these representations. We have also provided a description of the site and the reasons why it is suitable for allocation below.

Site Description

24.18 The 25.6 ha site comprises agricultural fields which fall from south-east to north-west. The land is currently in use for arable and pasture. Overhead transmission and high voltage electricity cables cross the western part of the site in a north-south direction.

24.19 The site is dominated by arable fields delineated by hedgerows, with mature standard trees, areas of semi-improved grassland and a small copse of semi-natural broad-leaved woodland present within the site. Towers Covert ancient woodland site lies directly adjacent to the western boundary of the site.

24.20 The site is contained within defined boundaries. It is bounded to the:
• North predominantly by a hedgerow that demarks the edge of the site with agricultural fields beyond. To the far north east of the boundary is Water Works Farm which has been redeveloped for residential development.
• East by Chester Road and the residential properties fronting onto Chester Road and Leacliffe Way.
• South east by Chesterwood and the residential properties which front onto Chesterwood beyond which lies Little Hardwick Road. The south western boundary is bounded by Little Hardwick Road and the residential properties of Little Hardwick Road.
• West by Bourne Vale Road, areas of mature tree groups and hedgerows and the properties along Bourne Vale Road. Further to the north west of the site is Tower’s Covert, an area of ancient deciduous woodland.

Suitability of Chester Road for Green Belt Release
24.1 In the Green Belt Technical Report submitted with these representations we set out the reasons why land at Chester Road, Streetly is suitable for release from the Green Belt and why the findings of the BCGBS do not accurately assess its contribution.

24.2 In particular, we note that the site has not been considered in isolation in the BCP Green Belt Assessment and this has a resultant impact upon the ratings identified in the Assessment. In the Green Belt Technical Report, we have carried out our own assessment of the site in isolation as this is considered to be the most appropriate and transparent method of assessing its suitability for Green Belt release.

24.3 As detailed in our Technical Report, land at Chester Road, Streetly does not make a significant contribution to the purposes of the Green Belt and is suitable for release.


Deliverability of Chester Road

24.4 The Chester Road site is entirely deliverable and would make a valuable contribution to meeting future housing needs. The proposed allocation and development of the site:

• Will make a valuable contribution towards meeting the quantitative and qualitative needs of the community for market and affordable housing. It could deliver up to approximately 505 high quality family houses.
• Is being promoted by a national housebuilder, Taylor Wimpey who can deliver the proposed residential scheme. Taylor Wimpey is seeking to develop the site as soon as it is allocated.
• Is not subject to any known constraints that would impede deliverability. There are no legal impediments, need for land in third party ownership. The site is therefore is fully deliverable
• Streetly is identified as a vibrant Local Centre. Therefore, the provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider Black Country is important.
• The land has strong boundaries and it is considered that its allocation and future development is unlikely to have a detrimental impact on the form and character of the settlement.
• Taylor Wimpey has undertaken an evaluation of the technical and environmental constraints that could prevent or restrict the development of the land. This work has identified that there is no overriding constraint that will impede its delivery.
• Taylor Wimpey confirms that the development of the site is economically viable and is confident that residential development can be achieved within the first five years of the plan period.

Sustainability of Chester Road

24.5 Streetly is identified as a Local Centre in the emerging BCP. Therefore, the provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider Black Country is important. The development of the site would contribute to retention of a good level of access to local convenience and comparison retail, services, community facilities and other amenities.

24.6 The site is sustainably located being situated the edge of the settlement in close proximity to a number of services. Public transport services operate to the south of the site and are within walking distance.

24.7 It will provide a range of open market and affordable housing in various types, sizes and tenures to help meet local needs.

24.8 The site is currently in agricultural use and has limited ecological value. Suitable ecological mitigation will be incorporated within the site. Where possible existing hedgerows and trees will be retained and incorporated within the proposed development.

Masterplan for Chester Road

24.9 The vision for the site is to create an attractive housing development with distinctive local character offering a choice of high-quality new homes to meet local needs. The proposed masterplan is designed to:
• Create a development that complements the character of the surrounding area through appropriate development densities, street scenes, housing types and retaining the existing landscape structure.
• Create a Public Open Space network that improves pedestrian and cycle connectivity from the site and Bourne Vale to the centre of Streetly via attractive routes set within green corridors.
• Provide a local park that is easily accessible via the public open space network. This park would provide opportunities for informal recreation, children’s play, habitat creation and improved surface water drainage through the integration of SuDS attenuation basins, swales and wetland areas. As well as a Locally Equipped Area for Play, there is the potential to accommodate a junior sports pitch and a series of Local Area’s for Play throughout the development to ensure residents have access to a variety of informal recreation and play opportunities.
• Create a high-quality residential scheme within the site with a coherent landscape structure, which conserves the natural assets present on the site, as well as improving the local recreational and children’s play opportunities and connectivity within Streetly.

BCP Site Assessment Report

24.10 The Chester Road site has been considered in the Council’s Site Assessment Report [Site Reference SA-0037-WAL]. The Assessment Report concludes the following on the site:

“The site is part of a larger area which is characterised by its openness and helps to define
Streetly's semirural character. Although it is recognised that wider visual amenity impacts
are limited due to the development to the South and East, this land forms part of the transition between the urban and the rural so any development here would erode that having a significant visual amenity impact. Employment uses would have more significant character impacts”.

24.11 We do not agree with this assessment. Any site on the edge of the urban area forms part of the transition between urban and rural and the site would not have a significant visual amenity impact. It is well enclosed by existing residential uses to the east and south, with the western boundary enclosed by the Bourne Vale residential development, which obscures views from the west. The northern boundary is currently defined by an existing hedgerow and individual trees, and a new housing development, introducing urban features in this location. Suitable landscape planting to the boundaries of the site, including enhancing the northern boundary with new woodland planting, would ensure that the visual impact of the development is minimised.

24.12 These built and natural features serve to separate the site from the wider open countryside and the site would essentially provide an ‘infill’ plot between the existing built development to the east, south and west (and partially to the north).

24.13 We therefore consider that the findings in the assessment are inaccurate and for the reasons we have identified in these representations, the site is suitable for removal from the Green Belt and allocation for residential development.

Alternative Masterplan

24.14 Taylor Wimpey have worked collaboratively with St Philips (adjacent landowner to the north) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached at Appendix 6). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the Draft BCP at present and would allow for the inclusion of significant community infrastructure.

Conclusions
24.15 It is essential that further housing sites are allocated in the BCP in order to meet housing needs.
This will involve the release of additional Green Belt land as insufficient alternative land is available to meet housing needs.

24.16 In summary, land at Chester Road, Streetly is considered suitable for allocation for residential development because:
• It does not make a significant contribution to the purposes of the Green Belt and is suitable for release.
• There is no overriding constraint that will impede the delivery of the site.
• It would provide a local park that is easily accessible via the public open space network
• It is entirely deliverable and would make a valuable contribution to meeting future housing needs, including affordable housing, within the first five years of the plan period

Object

Representation ID: 45359

Received: 07/10/2021

Respondent: Mr Nigel Wood

- During the build and subsequently more people in a peaceful park location.
- Noise and pollution from all of the extra cars/vans from the proposed 900 houses. Example, most houses will have one car, some two cars that equates to 900/1800 extra cars in the area. The road system can not and will not cope.
- This is green belt land that divides two large housing areas, Pheasey estate and Streetly (so preventing neighbouring towns merging)
- Drain on local services and amenities:- schools/shops/GPs/Dentists which even now are full and it can be hell trying to get an appointment, even before Covid 19
- Surely the green strip is an emergency landing/flight path for Birmingham airport. Yes there may be overhead wires, but better to try and land there than into the houses of Kinstanding/Castle Vale/Sheldon/all built up areas before the airport
- More tarmac and slabs will not help with rainwater drainage etc.
- The government and councils are always talking about air pollution, well this is not going to help with all the extra traffic.
- Once its gone, its gone. The word hindsight will not bring the green belt back.

Object

Representation ID: 45441

Received: 07/10/2021

Respondent: Steve and Claire Jennings

1, The sites in question are Green belt and the allocation of such sites for housing development should be resisted when there are alternative numerous brownfield sites within the Black Country area and specifically Walsall. The proposals appear to be an easy option to address central government demands for future housing rather than investigating former unused and available industrial sites in the Borough.
2, At a time when climate change is a key issue the impact on what is now arable land is catastrophic. The proposed extraction of bedrock and sand and gravel will have a massive impact on the local community causing disruption, noise, smell, fumes and a threat to health.
3, The proposed widening of Stonnall Road to accommodate large industrial vehicles and increased traffic will further erode the rural nature of the area to aid an urban sprawl with little or no demarcation.
4, If this development is permitted the real winners are the land owners who sell, and the developers who build the housing. The so called improvements to the local facilities such as a local primary school and health care, are a sop to the existing community which will suffer from the increased demand for services. Coupled with the change in the environment this proposed development cannot be justified.
5, The land in question has always been farming land and should be maintained as such if Britain is to be addressed self sufficient rather than being held to ransom by foreign market forces.

Object

Representation ID: 45907

Received: 11/10/2021

Respondent: Mrs Patricia Chilton

I have lived in Shelfield for [Redacted-GDPR]
their will be know Green spaces left for our grandchildren and Great Grandchildren their will be problems with Environment and pollution, Access and more Traffic Problems.

Object

Representation ID: 45928

Received: 31/03/2022

Respondent: Walsall Labour Group

Agent: Cllr Aftab Nawaz

Dear Sirs,
Re: Response to Black Country Plan consultation

Please accept this response to the Black Country Plan in my capacity as the Leader of the Labour Group, the main opposition, in Walsall Council.
First and foremost the consultation has been left wanting and has not engaged with the residents of Walsall. I accept that all that is required statutorily has been done but nonetheless the mark of a good consultation is that people feel that that they have had a fair opportunity to respond. I have found that in Walsall this has not been the case and that the people of Walsall feel disenfranchised of their democratic right.
The process needs to carry the confidence of the people in order for them to feel, whether they agree with the proposals or not, that it has been an honest, transparent
and appropriate consultation. I am afraid the people of Walsall, in my opinion, do not feel that this is the case and have no confidence in the process that has been followed.
The method by which this process moves forward also needs to be more than a cabinet approval. The people of Walsall, through their elected representatives, need
to have a deciding vote on whether to accept these proposals or not. Allowing only a nine member group to decide the fate of our greenbelt will not be seen as
democratically sufficient by the public – and their opinion MUST be respected.
On the actual proposals as the Leader of the Labour Group I am AGAINST these proposals on the following reasons
The proposals have the potential to change our borough for the worse meaning that invaluable greenbelt land will be lost for the residents of our borough and for our future
generations. Once lost the Greenbelt is gone forever and this cannot be something that we can accept as the representatives of the people.
The enjoyment of the land and its use for the wellbeing of our communities is something we vale highly. The removal of this land will impact the health and wellbeing
of our residents and will be harmful to them. We cannot support these proposals that will be detrimental to the health and wellbeing of our residents.
In addition to this many Green Spaces, for example in the Reedswood area of the borough (another unwelcome proposal), are a buffer to the pollution that comes from
being so near to a major road network like the M6. This buffer that removes, alleviates or mitigates the impact of the pollution helps the health of residents in the area
particularly children. The removal of this ‘buffer zone’ will therefore impact negatively and directly on the health of residents and therefore cannot be supported by us.
The destruction of valuable habitats from proposals set out will be huge and will be directly opposite to our responsibility to the natural environment. These habitats are not only important to the biodiversity within our borough but are also significant natural amenity for our communities and residents. The negative impact on wildlife cannot be justified on the basis of needing more homes.
The development of brownfield land and former industrial land has not been exhausted and therefore the proposals for development should be focussed on this type of land.
It is highly irresponsible to develop Greenbelt land, Greenspaces or on areas of Special natural significance without exhausting brownfield / former industrial land.
Finally these proposals are aimed at helping developers maximise their profits and not helping residents and protecting them from unfair, inappropriate and unacceptable developments. The fact that developers may have to spend a little extra in remediating brownfield / former industrial land and thereby reducing some of their profit margins should not be the basis of attacking our most valuable land. It is not a financial issue for us but a moral issue. The land that is covered by the
proposals cannot be measured in pounds. It is invaluable in the benefit that our residents get from this land.
I would be grateful if you would accept this as our response to the Black Country Plan on behalf of the Labour Group in Walsall.

Comment

Representation ID: 46269

Received: 11/10/2021

Respondent: Walsall Group of the Ramblers

Walsall Group of the Ramblers wish to make the following comments in the consultation phase of the Black Country Plan. (BCP).
[Our remarks focus on the perceived impact of the BCP on the Walsall Borough - other boroughs in the Black Country have similar Ramblers groups who may wish to comment with respect to their particular areas].
Introduction.
The recent pandemic has clearly illustrated how valuable open spaces are for the health, (physical and mental), of people everywhere. With the Black Country’s already identified lower rates of physical activity, higher rates of obesity, alcohol abuse, depression and social isolation, opportunities for exercise and outdoor outlook changes are vital as the population expands and issues relating to social support within the community are further increased.
Naturally enough we anticipate the erosion of green space that will occur as the Plan is implemented, especially in the strategic building areas bordering on the Green Belt, but look forward to observing the commitments in the Plan that not only aim to preserve trees, woodlands and hedgerows, but also to develop canal towpaths to enable links to other cycle and walking routes. We also look forward to the proposed changes that will lead to multi-functional green spaces and greenway systems. The use of Green Belt land for public open space, sport and recreation appears, to us, a good use of the asset - providing it is done with appropriate care. We welcome resources aimed at furthering the protection of the local natural environment, (SSSIs, etc), whilst also utilising funds to bring these areas nearer to the public, (sensitively), via an enhanced system of cycle and footpath routes.
Footpaths and Byways.
From the footpath perspective we see an opportunity to have footpaths in local boroughs planned/implemented in association with those who might use them. (We have seen enough paths ‘wedged’ into development plans that have proved to be not only unsuitable for users involved, but also prone to ASB and damage).
There is also the further possibility of an expansion of Black Country-wide footpaths - that were popular some years ago - linking boroughs, but which have declined more recently and need refurbishment/improvement, (e.g. The Beacon Way, The Wulfrun Way).
[Four years ago we re-labelled the Beacon Way from Sandwell Park Farm to Castle Ring on Cannock Chase, but lack of resources within Walsall Council has meant we have been unable to publicise this on a local web-site].
Our Concerns
We do however, have significant concerns that there are some of the areas of the Plan which may work to generate a negative effect on the Borough. Having such a considerable amount of open space in the east of the Walsall Borough, we cannot but feel it is inevitable that these areas will be impacted by future housing/employment demands in the Black Country, especially as more brownfield locations are occupied.
However, acceptance that this must be the case does not necessarily mean we are at all complacent about the revised National Planning Policy, nor are we unconcerned about the percentage of building land across the borough which is protected by Mineral Safeguarding Area, (MSA), restrictions.
Instinctively we feel that with some many houses planned in strategic areas, (3710), and also (515), in brownfield sites standing on MSA locations, that there will be an advancement of mineral extraction activities ahead of the building deadlines that not only have the potential to disrupt local existing footpaths for several years, but also indirectly impact on any proposed ones.
We also fear that the revised National Planning Policy will generate inappropriate building developments that whilst being contained within the confines of the Plan will generate areas of rapid urban decline/inaccessibility in the short-term thus further reducing available space to those wishing to actively travel in the borough.
Proposal.
As a Ramblers group committed to furthering the interests in walking for both health and social motives, [at the same time as supporting fully the Plan’s strategic policy 11- to protect the natural environment, wildlife corridors, countryside landscapes, etc including an interlinked green infrastructure protection/maintenance of the countryside], we would wish to see introduced a separate Black Country-wide Footpath Development Plan, that is clearly documented and approved.
We would see this running in parallel to the wider BCP timescales and fully accessible to all interested parties. On a positive note, however, we feel that as far as Public Rights of Way, (PROWs), are concerned the implementation of the BCP should be used as a means of expanding the footpath network in both Walsall and across the other boroughs of the Black Country.
Black Country-wide Footpath Development Plan, (BCFDP).
We seek a coordinated development of this network expansion between the BCP itself and reviewed/updated Rights of Way Improvement Plans, (ROWIPS), in all boroughs. We see this operating via a Black Country ROWIP, (created from individual borough ROWIPs), that is monitored via Local Access Forums, (LAFs), whose members are drawn from ROW user groups, (e.g. walkers, horse riders, cyclists, canal boat owners, etc).
As in the BCP itself, the current Walsall ROWIP places much emphasis on the maintenance and development of public open space and hence the ROWIP/BCFDP should work in parallel over the entire duration of BCP to ensure a long-term strategy for footpaths and adjoining spaces is produced and enacted.
(The Walsall ROWIP is already being prepared for an overdue review and we hope to have some input into that once more).
However, recent reductions in resource levels with ROW Teams throughout the Black Country suggests that currently this might be unattainable and that cost-saving will continue to dominate this area allowing an uncertain and likely unplanned development of leisure services in this section.
(Walsall Situation).
Ramblers volunteers in Walsall have worked closely with Walsall MBC Rights of Way team for some years to help keep footpaths and byways in order throughout the borough, but whilst being exceptionally grateful for their commitment, we are acutely aware of their limitations.
We are working closely with the ROW Team in Walsall Council, both in monitoring footpath situations and actively volunteering to help keep local routes open and viable. (This is particularly important in an urban area where paths are somewhat limited, but as a result our more rural footpaths are heavily used by the general population).
Our own LAF has been operating in ’background’ mode owing to pandemic restrictions, but we are seeking to reinstate it shortly. We see this function as a means of keeping abreast of the BCP’s progress whilst also permitting representation of implicated Council departments for discussion along the way.
Like many other areas of the Council, the ROW Team is under-resourced and consequently all project and proposals take a long time to move forward – especially since COVID restrictions.
[We are currently attempting a DMMO to formalise the route of Sutton’s Drive on the Great Barr Hall Estate, but progress is particularly slow further and exacerbated by delays incurred by continued remote working by the MBC].
In Conclusion.
Footpaths and opportunities to take exercise in the wider environment have already demonstrated their benefits and will continue to do so. We therefore need to understand the changes implied by the BCP to make sure that in future our ROWs are not only preserved, but wherever possible expanded and developed. These are assets which all community members within the Black Country have a right to understand and access whenever they wish.

(See Rep ID 11482 for the original submission)