Policy MIN3 - Preferred Areas for New Mineral Development

Comment

Representation ID: 11336

Received: 30/09/2021

Respondent: Mr Robert Townsend

WAH237
The proposed land for quarrying and building has always been used for the production of crops. When the country is concerned with food security the allocation of productive farm land for building purposes is a disgrace. Especially when there is so much local land that is used only to graze horses
To extract ‘bedrock, sand and gravel’ over a period of years before building, would blight this peaceful neighbourhood and cause extreme distress to the residents for years. It would unfairly reduce the value of the neighbouring houses and the dust and noise pollution would make living conditions intolerable.

Comment

Representation ID: 15515

Received: 11/10/2021

Respondent: Natural England

Policy MIN3 - Preferred Areas for New Mineral Development

MP1: Birch Lane, Aldridge, Walsall.

This site represents a key local site in the area that meets the aspirations of Natural England’s Purple Horizons project (see Annex 1 for more details) to expand and connect up new and existing heathland habitat mosaics. Natural England recognises that mineral operators require new land for mineral extraction but would encourage them to create restoration plans that enable it to revert to heathland mosaic habitat that allows access for local people too. Policies that support new country park creation are an option to make this a reality. Local Nature Recovery Strategies are key to identifying these sites while revealing the big picture scenarios to influence landowners. Supporting local landowners with funding opportunities such as Biodiversity Net Gain and other Natural Capital Investments could make this a reality.

MSwa9 - (MB3) MX3 Sandown Quarry, Stubbers Green Road, Aldridge (Brick Clay)

We note that this site has been removed as a potential waste site and permitted minerals site and has now be allocated as employment land WAE412/GB1. We have concerns about this. This area includes and is in close proximity to the following SSSIs:

• Swan Pool & The Swag SSSI
• Stubbers Green Bog SSSI
• Jockey Fields SSSI

Any proposals would need to ensure that there would not be any direct and indirect impacts and be sensitively designed and should create and enhance the natural environment. Further comments on site allocations can be found below under 13 Sub-Areas and Site Allocations.

We would advise however that we believe that this site provides an excellent opportunity to combine environmental restoration as well as employment, could this site be the heart of a new Walsall
Wetlands Centre in 2050? Along with the Swan Pool & The Swag SSSI, Stubbers Green Bog SSSI and the restored Atlas Quarry as part of a nature-based economic redevelopment of the clay pit industrial
area. Combining Walsall special environmental sites and culture heritage to provide employment and a new tourist site that benefits wildlife and the local people?

Comment

Representation ID: 16322

Received: 11/10/2021

Respondent: Natural England

WAH235, WAH237, WAH248, WAH253, plus MIN3: These site allocations are in close proximity to
Shire Oak Local Nature Reserve (LNR) (GB1)

Natural England is concerned about the added recreational pressure upon the biodiversity value of Shire Oak LNR that these additional housing allocations will bring without additional new biodiversity rich green space being created in this area that can support a greater carrying capacity of people. Natural England also encourages the Black Country Local Planning Authority’s via their Local Nature Recovery Strategy (LNRS) to actively develop cross border cooperation between other Local Planning Authorities (LPA) (for example Lichfield District Council) in coordinating land development projects that impact on local biodiversity sites to ensure that local biodiversity corridors are maintained and link up other local important sites for nature conservation, e.g. Clayhanger Common. An example of this approach relates to land that envelopes WAH235, WAH237 but is in fact in both Lichfield and Walsall. This land area has been identified though Natural Capital Mapping (reference Midlands Heathland Heartland as a bottle-neck constraining existing local nature recovery networks to flow, connect and
link across the wider geographical area. Purple Horizons Nature Recovery Project and Midlands Heathland Heartland (see Annex 1 for further information) has identified significant investment opportunities that will ensure that species and habitats can continue to move freely.

Comment

Representation ID: 22256

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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Comment: Whilst supporting that due to the constraints of the Brownhills Common site, mineral working is not expected to take place during the plan period, we request that constraints including the site’s nature conservation designation and amenity value are outlined in this point.

Support

Representation ID: 22257

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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Support: WTBBC support significant weight being be given to proposals that would allow for the revocation of the existing ‘dormant’ permission at Brownhills Common.

Comment

Representation ID: 22455

Received: 11/10/2021

Respondent: Tarmac Trading Ltd (Sharne Sahajpal)

Agent: Heatons

Policy MIN3 of the emerging Black Country Plan identifies ‘Preferred Areas’ for mineral
development within the Black Country, as informed by the requirements for those minerals
outlined within MIN1 of the BCP, availability of resource and constraints. These ‘Preferred Areas’
for mineral development (remaining permitted reserves, site specific/preferred areas identified


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at Birch Lane and other resource within the MSA’s) are supported in principle within Policy MIN3,
subject to development complying with requirements of Policy MIN4 (managing the effects of
mineral development) and other policies contained within the BCP. ‘Significant weight’ will be
given to the contribution these sites would make towards the sand and gravel supply
requirements identified in Policy MIN1.

The approach within Policy MIN3 to sand and gravel supply suggests that there is no
preference/hierarchy to sites coming forward for mineral extraction – i.e those within MSA’s
hold equal weight to the identified preferred areas, as it is recognised they will be required to
sustain aggregate supply – and this is supported. The justification text for the ‘Preferred Area’
for sand and gravel extraction at Birch Lane (land around the former Aldridge Quarry) states
that “As this site remains unrestored, any new sand and gravel extraction proposals in this area
will be expected to help facilitate the restoration of this site.” This is considered to be overly
onerous on operators, not justified and could ultimately constrain much needed mineral supply
for the both the West Midlands and further afield. Seeing resource come forward within the
authority is extremely important, and only emphasised further by the potential need for the
Black Country to pick up some of the potential shortfall from Solihull as they could see mineral
sterilised by HS2; a point which the Council is clearly aware of as it is referred to within
paragraphs 12.14 through 12.21 of the consultation plan.

The Council needs to be clear on their reasoning for requiring minerals development to
facilitate restoration of another site. It is our view that this approach is not positively prepared
in supporting minerals development to meet identified need. The fact that the site has
remained unrestored does not justify a requirement upon another operator to restore
additional land or previous working areas, this could be viewed as cost prohibitive to new
mineral development coming forward which makes it an ineffective strategy. We question the
justification and soundness of this requirement within the plan as it places a restrictive element
to policy which should be prepared with the objective of contributing to achieving sustainable
development, in line with paragraph 16a of the NPPF.

Comment

Representation ID: 23536

Received: 11/10/2021

Respondent: Historic England

We have concerns about the approach set out in this policy and the potential impacts for the historic environment. For example, what assessment has been undertaken to consider the potential harm to the significance of the historic environment, heritage assets and their setting. Many of the safeguarded areas appear to consider extensions to existing quarry sites,
however, it cannot be assumed that additional development in an existing area will be suitable and without harm for the historic
environment. By listing areas it is difficult for us to assess what the potential implications may be and we require additional information relating to these areas/ potential sites in order to provide detailed advice.

Support

Representation ID: 44910

Received: 10/10/2021

Respondent: Cannock Chase Council

Support the approach to Fireclay and coal working and the revocation of the existing
dormant permission at Brownhills Common.