Development Allocations

Object

Representation ID: 45823

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

WAE341 - Hughes Road, Moxley

WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• LNRS core habitat zone with high potential for/evidence of presence of priority/important (post-Industrial) habitats and species

Object

Representation ID: 45844

Received: 11/10/2021

Respondent: Pam Woodhall

Site ID 340 land East on Beacon Road, runs the back of Wimperis Way, Pheasey
(2) My other concern is the area on your plan document showing the fields on the Beacon Road,. What are your plans for this area, housing, industry? All of the above objections apply to this area of planned development too. Beacon Road, is way too narrow to have anymore access points.To loose both areas of open green spaces to developments would be unforgiveable. What a dramatic, detrimental affect this would have on the landscape and communities.Thank you for listening.

Comment

Representation ID: 46206

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

9. Policy ENV1 Nature Conservation
9.1 Part 1(c) of the policy seeks to ensure that locally designated nature conservation sites (Sites of
Local Importance for Nature Conservation, or SLINC), important habitats and geological features
are protected from development proposals that could negatively impact them. The proposed
policies map identifies SLINCs, including . These are discussed
below.

9.2 HIMOR objects to the identification of the proposed .
Paragraph 8-013 of the PPG provides:

How can plan-making bodies identify and safeguard Local Wildlife Sites and
Local Geological Sites?
areas
of substantive nature conservation value and make an important contribution
. They can also provide wider
benefits including public access (where agreed), climate mitigation and
helping to tackle air pollution. They can be in in rural, urban or coastal locations,
can vary considerably in size, and may comprise a number of separate sites.
National planning policy expects plans to identify and map these sites, and to
include policies that not only secure their protection from harm or loss but also
help to enhance them and their connection to wider ecological networks.
Local planning authorities can take a lead in establishing and maintaining
partnerships and systems to identify, manage, enhance and safeguard local
sites. The positive engagement and co-operation of land owners and their
representative bodies can contribute significantly to the success of these
partnerships.
All local sites partnerships need to use clear and locally defined site selection
criteria with measurable thresholds. For example, where a particular habitat is
especially scarce, it may be appropriate to adopt a lower threshold for
selection than would be appropriate for other natural areas so that a suitable
range of sites is protected. Selection criteria need to be developed with
reference to the standard criteria in the following question, with all sites that
meet the relevant criteria (informed by detailed ecological surveys and
expertise) then being selected.
9.3 Paragraph 8-013 of the PPG then sets out the standard selection criteria for Local Wildlife Sites.










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9.4 ture

However, the BCP and the evidence base provides no justification for the identification
of the land south of Bosty Lane, Aldridge as a SLINC. It provides no evidence as to why the
proposed policy approach is suitable for this site, and no assessment against the selection criteria
as required by the PPG.

9.5 As far as we are aware, there has also been absolutely no consultation with the landowner on
the proposed designation
walkover survey work in 2019. On several occasions HIMOR has made requests to Walsall Council
to provide the survey results, but the information has not been provided. It is therefore impossible
to scrutinise the evidence underpinning the proposed designation (if indeed there is any
evidence at all). The approach of the Council is not transparent, and is directly contrary to
paragraph 61-002 of the PPG, which states:

plans and open data when publishing plans and the evidence base which



9.6 HIMOR therefore requests again that the evidence informing the designation is made available
for review and reserves the right to comment further once that evidence is provided.

9.7 Our client has undertaken its own ecological survey works, the findings of which are summarised
in the attached letter and plans provided at Appendix EP4. The letter concludes that certain
features within the land are of ecological value and therefore should be retained and protected.
These comprise the boundaries, linear woodland, scattered trees and the mosaic of wet scrub,
neutral grassland and tall ruderal vegetation to the south of the farm complex. Existing
designations on land to the south of the site (Cuckoo's Nook (SINC) and the Dingle Local Nature
Reserve (SSSI)) are not in dispute. However, the relatively limited proportion of positive features
do not justify the identification of a SLINC which covers a much wider area of land. Most of the
land designated as a SLINC is of low ecological value, comprising improved, species poor
grassland used for farming and grazing horses. This is shown on the Phase 1 Habitat Map and the
Areas of Ecological Value plan which accompany the letter at Appendix EP4. The designation
of the land as a SLINC is not reconcilable with the assessments undertaken and the current use
of the land.










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9.8 We therefore consider that the site is not of any significant nature conservation value and its
designation as a SLINC is erroneous. The site is not worthy of receiving any special protection in
the BCP. The proposed designation is not justified and, in the absence of evidence, is not
consistent with national policy.
Policy approach to SLINCs
9.9 The proposed policy approach is inconsistent with paragraph 175 of the Framework. This requires
plans to distinguish between the hierarchy of international, national and locally designated sites.
However, Policy ENV1 seeks to apply a similar level of protection to locally designated sites as
internationally, nationally and regionally designated nature conservation sites. The protection
afforded through Policy ENV1 should be considered in light of the value of the sites identified.
Moreover, previous Secretary of State decisions have made clear that protection afforded to
non-statutory sites (i.e. both SLINC and SINC sites) must be commensurate with the sites true
ecological value, notwithstanding the designation per-se. For the reasons set out above, the
, and much of the land is
of low ecological value.

9.10 Furthermore, development on SLINCs could achieve ecological benefits. Ecological
enhancements could be delivered, including the management of the features which are of high
ecological value and biodiversity net gains. A blanket restriction on development within SLINCs
would provide no assurances on future management and would likely maintain the status quo of
existing uses on sites, such as agriculture and grazing, which may well be detrimental to any
ecological interests.

9.11 The policy should therefore be reflective of the potential for development. To illustrate the point,
the presence of a SLINC across the entirety of a site has not been a constraint to the proposed
allocation of sites within the BCP, for example Oxley Park Golf Club (ref: WOH261 WTNA) and land
off Sutton Road, Longwood Lane, Walsall (ref: WHA231 / Policy WSA.6). This clearly demonstrates
that development on a SLINC can be acceptable, and therefore the approach needs to be far
more flexible than the current policy wording suggests

Comment

Representation ID: 46276

Received: 03/10/2021

Respondent: Walsall MBC

It was noted by previous Councillors for Birchills-Leamore that the amount of Brown land that existed in the ward made it attractive for development. Local concerns led to the formation of a “Project Reference Group” so that residents could get a handle on how development might be progressed, but in a way that was not piecemeal and that took note of the need for recreational amenity space. As a councillor, I caught the back end of this and the reports producers, Urban Splash, took time to develop a plan which, by and large, was acceptable to all parties. This would have been around 2010-2011.
The plan recognised the need for sympathetic development and amenity space, proposing sympathetic development in corridors along Green Lane (running along the canal) and on the “Metal Casements site”, off Birch St. I understand that the Metal Casements site is in the Black Country plan and I have no objection as it stands to this principle.
The Metafin site is a canal side site that I believe has permissions and as such it fits in with the PRG recommendations. I have no objections to this site being developed in principle.
Another recommendation of the PRG I believe was to consider brown field land (open space) bounded by the canal, Stephenson Avenue, Green Lane and South Staffordshire Water Company building. This may raise some local objection but is preferable to development on other open land and has good transport links via canal to town centre, bus/car to town centre via Green Lane and to the M6 J10.
Birchills-Leamore: Amenity space
Birchills-Leamore ward has a number of areas of amenity space, the jewel of which is Reedswood Park. This is an established park, well used by the local residents (from Pleck and Birchills-Leamore) and some from further afield. It has a mixture of tree lined walks, open space (with a cricket mat), and a BMX/skate area. There is also an outdoor gym. All of these facilities are well used by communities from the Birchills/Reedswood/Beechdale areas. Investment has been made into this park in terms of recognising its value in terms of improving physical and mental health of residents and is fiercely protected by residents from the locale, via the agenda 21 residents group. This group also provides access to cycle hire and maintenance via its “bikelite” project.
Beechdale has a number of open amenity spaces. On the north of the estate, there is Beechdale Park (serving Birchills-Leamore and Bloxwich West), just to the south of the centre of the estate there are Lister Rd Playing fields, with an outdoor gym, basketball cage and children’s play area. To the south of this and off Cavendish Rd we encounter the “Ash track” which in turn links a green area known locally as “the Bayou” (bounded by Cavendish Rd and Reedswood way) , Reedswood park and an area off Reedswood Way known as the “Fishing pools”. This track also runs through what was brown land from the old Power Station site, latterly a golf course and now planted with 2000 trees by Walsall MBC. This Ash track then, links a number of amenity spaces together, but it also provides a cycle route between Beechdale and the canal system to a local primary school at Bentley Drive (Pleck ward) and a secondary school (West Walsall Academy in Pleck ward). This separates children and cars and reduces car journeys.
Leamore has little amenity space available to residents in the Birchills-Leamore ward, other than Odell Road playing fields, a large green area (serving Birchills-Leamore and Bloxwich East) bounded by the railway Odell Road and two schools. Leamore park is in the Blakenall ward and, despite the name, residents and their children from the Birchills-Leamore ward are unlikely to travel to this park as to get there you need to cross the main A34 (Green Lane) and the B4210 (Bloxwich Rd).
Whilst there appears to be quite a lot of open land in the ward, bearing in mind the recent development and the development planned, the need for quality amenity space is going to rise as the population grows. To develop within the ward sympathetically, this should be recognised and be in the Black Country plan. Birchills-Leamore has successfully fulfilled its regeneration objectives up to now and there is potential for more development, but, development of any of the open spaces mentioned above would be detrimental to the health and wellbeing of residents and would not be a balanced regeneration.
Birchills-Leamore: Environmental concerns
Birchills-Leamore is adjacent to the M6 J10, one of the busiest stretches of motorway in Europe. CO2, NOx emissions and PD50 particulates are at high levels and the government has expressed concerns at the levels of pollution around the M6 corridor. The J10 expansion will in the short term relieve some of that pollution, but the J10 development is also aimed at regenerating land around the Black Country Route at Bentley/Darlaston/Willenhall and Pleck. This may also lead to a greater incidence of trips by commercial vehicles. Whilst there is a dash for electric vehicles, it is unlikely that commercial vehicles in the short and medium term will make the move and due to cost and due to terraced housing layout, it may be difficult for many residents in Birchills-Leamore to switch. Green areas then provide some method of offsetting the CO2 emissions and 2000 trees on the old golf course site are desirable, which should be considered as an expansion to Reedswood Park as part of the Ash Track corridor and left alone.
In the 70’s there were a number of tip operations ongoing in the Reedswood area and ground gas may be a problem on these sites, particularly around Pouk Hill. There is a proposal to include land here and to the rear of Bentley Lane, which could disturb pockets of gas, which may blight local residents. Also, trees in this area provide natural sound screening from the M6.
Odell Rd Playing Fields
In recent years we have seen flooding on Beechdale when there has been very heavy rain. This occurred on Edison Walk, Cavendish Rd (Beechdale) and Birchover Rd (Reedswood). On inspection by Walsall MBC the gulley system on the road surfaces were clear. Severn-Trent have performed camera surveys of the drainage system and have declared their system clear. The surface water outfall runs into a canal arm off Bentley Lane and opposite the Alma PH, this belongs to the Canals and Rivers Trust. I do not know what their findings are, but, understand that there is legal discussion on the issue.
Any development in my mind then must consider that the surface water drainage for Beechdale, Leamore Lane industrial estate, Bentley Lane, Birchover Road and surrounding, Pouk Hill, Ragstone Close et al, link to this system. I believe then that it must be a question to ask, “Can any development in Reedswood or Beechdale sustainably be made, if the new development taps into a drainage system that may already be at capacity?”
Birchills-Leamore: Neighbouring considerations
There are many links between communities that straddle the borders of wards and shared facilities of the same. There has also been developments in these wards which would utilise facilities in Birchills-Leamore.
Pleck Ward: A sizeable development at the Harvestime bakery site (brownfield land) will utilise facilities such as school places, GP’s and Reedswood Park.
Blakenall Ward: There is a considerable amount of housing development on Brownfield land in the Goscote corridor, which will potentially have a particular impact on primary school places in the Leamore area, which will have a ripple effect on areas like Beechdale. I also cite GP practice demand.
Baring in mind the above, amenity space will be of prime importance.
Birchills-Leamore: Synopsis
Birchills-Leamore has been very successful in terms of utilising brown land for mixed use regeneration to provide housing, industrial use and amenity space. This development is in “balance”. The is room for more development if the recommendations of the PRG or taken on board, a corridor along Green Lane from the old police station site, up past Metal Casements, past the open land by green lane and the old Metafin site could be utilised to provide quality homes without utilising green belt and open land used for amenity space elsewhere in the ward.
It is my assertion then, that there needs to be a balance. The current amenity and park spaces should be kept and the old golf course should become part of the “Ash Track Green Link” which provides a cycle route and amenity space, where residents can repair mental and physical health and where biodiversity can flourish.
Birchills-Leamore has always risen to the regeneration challenge, it must not become an open season for regeneration and its residents must be given the respect they deserve. Birchills-Leamore must have balance. I expect the Black Country plan to reflect this balance.