Policy WSA6 – Land off Sutton Road, Longwood Lane, Walsall

Showing comments and forms 121 to 150 of 153

Object

Draft Black Country Plan

Representation ID: 19367

Received: 11/10/2021

Respondent: Mrs Doreen Kenyon

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19368

Received: 11/10/2021

Respondent: Angela Pedley

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19369

Received: 11/10/2021

Respondent: Mrs Janet Moram

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19370

Received: 11/10/2021

Respondent: Mr Peter Matthews

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19371

Received: 11/10/2021

Respondent: Mrs Marjorie Gavin

Number of people: 2

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19372

Received: 11/10/2021

Respondent: Vera & Maurice Whitehouse

Number of people: 2

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19373

Received: 11/10/2021

Respondent: Mrs Barbara Morgan

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19374

Received: 11/10/2021

Respondent: Mrs Diana Windsor

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19375

Received: 11/10/2021

Respondent: Mrs Helen Bodley

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19376

Received: 11/10/2021

Respondent: M W Rooney

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19377

Received: 11/10/2021

Respondent: Mrs Josie Hawkes

Representation Summary:

I'm writing in reference to the Black Country Plan of which you should be aware. I would like a response regarding a particular site (WAH231) Sutton Road/Longwood Lane Walsall. I would like to understand why this site is included in the Black Country Plan when it is clearly not suitable for any proposed development on a number of factors. The fact that the current landowners of a significant portion of land where the housing developments are proposed have NOT been consulted and do not support it raises concerns about this and the overall process.
Specifically, to the WAH231-- Sutton Road/Longwood Lane Walsall site, there are various reasons why
the site is unsuitable and I am disappointed to see that time, effort and presumed taxpayer money has gone into proposals which were never suitable for development.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLINC), I cannot understand how it is considered as part of the proposed development sites. Serious loss of wildlife habitat [REDACTED-SENSITIVE] would be a factor. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports (provided through the same process) around various environmental factors all relating to the WAH231 site.
• Loss of green space within the area going against manifesto pledges around drive towards brownfield first approach.
• Serious health risk to Sutton Road/Park Hall/Orchard Hills residents from increased traffic pollution and noise.
• Increased stress to Sutton Road residents with construction work and loss of Green Space.
Town Planning, Infrastructure &Education
• Proposed site has no pedestrian and no cycle access. Also, Longwood Lane has no street lighting.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road. Any Longwood lane access would cause increased traffic congestion which cannot be managed as Sutton Road is a key route connecting surround areas.
• Neighbouring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that this particular space will become the bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Proposed dwellings per hectare (dph) of 35 indicated within the proposal are significantly out of character with local area.
I have listed some of the reason above regarding unsuitability of this particular site (WAH231 - Sutton Road/Longwood Lane). I did want to remind you that within the conservative 2021 Manifesto summary you championed protection of Green Belt, Sites of Local Importance, and a 'Brownfield first approach' to development. A couple of statements and references from that Manifesto.
• Build Thousands of Homes Where They Are Wanted [Pg. 6 • Conservative Manifesto2021-Summary.pdf]. This is clearly not the case here. The drive was to adopt a 'Brownfield first' approach, and work with the local community to fight in protecting the green belt, and green spaces.
• Ensure Everyone has High-Quality Affordable Housing [Pg. 12] -"..continue a policy of 'Brownfield First' housing development." and "...protect the green belt."
I think it is clear from the above that this site is not suitable and goes against manifesto pledges. Who put this land forward when the owners of the land do not support development and were not consulted? Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19378

Received: 11/10/2021

Respondent: Mr Kenneth Peach

Representation Summary:

I am objecting to the site WAH231, being included in the plan for the following reasons:

1) This will create an increase in the traffic in Sutton Road and Longwood Lane as well as worse air pollution and more noise. Traffic congestion in Longwood Lane is already at times horrendous. We have HGVs travelling along Longwood Lane which has open plan front gardens and no safety barrier to protect residents.

2) It will mean serious loss of valuable green space and wildlife, birds insects and flowers. The site is of local
importance for nature conservation (SLINC) and should be protected.

The loss of SLINC/Green Belt goes against conservative, local and combined authority manifesto pledges "brownfield first" approach to housing and "Champion our green belt and green spaces"

Object

Draft Black Country Plan

Representation ID: 19379

Received: 11/10/2021

Respondent: Mr Ken Bodley

Representation Summary:

Why is the site WAH231, Sutton Road/Longwood Lane included in the plan when it is clearly unsuitable?
The current owners of 50% of this site, [REDACTED- GDPR] and a Sutton Road resident, were never consulted about the proposed development and do not support it!

The site is unsuitable because:
Infrastructure
 Sutton Road unable to cope with increased traffic.
 Any Longwood Lane access would cause increased traffic congestion.
 Longwood Lane has no pedestrian/cycle access.
 Longwood Lane has no street lighting.
 Severe traffic congestion at Longwood Lane /Sutton Road Junction.
 No capacity for increase in pupils at local schools.
 Proposed dwellings per hectare (dph) of 35 out of character with local area

Heath and Wellbeing
 Serious health risk to Sutton Road residents from increased traffic pollution and noise.
 Increased stress to Sutton Road residents with construction work and loss of Green Space,

Environment
 Serious loss of wildlife habitat [REDACTED-SENSITIVE] WAH231 is a Site of Local Importance for Nature conservation (SLINC) and should be protected.

Why was this site included in the plan when it is clearly not suitable?

The Sutton Road resident who owns a large part of this site has no intention of allowing any housing on it and was never consulted about its inclusion so why is it included?
Who put forward the site for inclusion in the plan when the landowners of 50% of it do not support its
development?

The loss of SLINC/Green Belt goes against the Conservative local and combined authority manifesto pledge to protect them:
Conservative Manifesto2021-Summary.pdf extracts:
Page 6: BUILD THOUSANDS OF NEW HOMES WHERE THEY ARE WANTED
 Continue to drive a regional “brownfield first” approach to housing.
 Champion our Green Belt and green spaces, working with communities and residents fighting to protect
them.

Page 12: ENSURING EVERYONE HAS HIGH-QUALITY AFFORDABLE HOUSING:
2021-2024 Take a Brownfield First approach to house building backed by my Green Belt Pledge: Fight
green belt development by working with councils to provide viable alternative Brownfield sites using our
£458 million housing fund, and continue a policy of ‘Brownfield First’ housing development. Call on the
Government to review the National Planning Policy Framework to make sure the rules better protect the
green belt.

We voted for you because this pledge promised protection for our Greenbelt/SLINC .

Can we count on your support for removing this site from the Black Country Plan?

Object

Draft Black Country Plan

Representation ID: 19718

Received: 11/10/2021

Respondent: Kully Mann

Number of people: 2

Representation Summary:

I am writing to inform you of our strong objection to the development proposed for site WAH231, Sutton Road/Longwood Lane which is included in the above plan. We and other current owners consisting of 50% of this site were never consulted about the proposed development and we oppose the proposed development plan.
The site is clearly unsuitable for the planned development due to the following reasons;

Infrastructure issues
 Sutton Road unable to cope with the increased traffic.
 Any Longwood Lane access would cause further increased traffic congestion.
 Longwood Lane has no pedestrian/cycle access.
 Severe traffic congestion at Longwood Lane/Sutton Road Junction.
 No capacity for increase in pupils at existing local schools.
 Proposed dwellings per hectarc (dph) of 35 out of character with local area.

Health and Wellbeing
 Serious health risk to Sutton Road residents from increased traffic pollution and noise.
Especially concerned for my youngest son who has asthma and allergies.
 Increased stress to us and other residents on Sutton Road with the construction work and loss of the Green Space surrounding us.

Environment
 Serious loss of wildlife habitat. WAH231 is a site of local importance for Nature Conservation
and should be protected.

Please can you take our concerns into account and reconsider the development for site WAH231 as it
also goes against the loss of the SLINC/Green Belt goes against the conservative, local and combined
authority pledge to protect them.

We and others voted for you because this pledge promised protection for our Greenbelt/SLINC. We
count on your support for removing this site from the Black Country Plan.

Object

Draft Black Country Plan

Representation ID: 20050

Received: 11/10/2021

Respondent: Rt Hon Valerie Vaz

Representation Summary:

The need in Walsall South is for family homes which are affordable and for social housing.
Currently there is provision for single household dwellings at Tameway Tower a large development in the Town Centre. However, there is no mention of social housing or working with Housing Associations.

The Draft Plan mentions that of the 13,344 new homes required 5,418 will be on land that is currently Green Belt. This means that 40% of the additional homes for Walsall will be built on the Green Belt in Walsall.

This is a huge incursion into the Walsall Green Belt and contravenes current planning law and guidelines.
The plan encourages the unrestricted sprawl of built-up areas, encroachment of countryside abutting the main urban district of Walsall town centre – countryside
which has the biggest social and health benefit and is within walking and cycling distance, proposes inappropriate merging of Pheasey and Streetly, undermines the special setting and characteristics of Walsall Arboretum, and discourages recycling of derelict and other urban land in Walsall and the wider Black Country.

The proposals amount to a continuous erosion of the Green Belt if they become the adopted Policy. There would be no requirement by a developer to provide
evidence that there were very special circumstances for building on the Green Belt.


What the consultation document does not do is shed any light on the ownership of land that is being designated for housing allocation. Much of this is Green Belt land and currently designated agricultural. Designation of this land for housing development massively increases the value of this land at a stroke. The public and other stakeholders should be notified as part of this consultation process about who owns the land subject to such change of use and therefore land value, what connections the landowners may have with councillors, officers, and political parties (such as through donations or membership) in order that the public can draw their own conclusions about such connections if in existence.

It is well known for example that developers land bank Green Belt and agricultural land on the edge of existing built environments in the hope that and even expectation that local planning policy will be changed and their speculative land banking of Green Belt will reap huge dividends for them.

4 Policy

Unlike the other Boroughs’ table of sites which indicate which site is on Green Belt or brownfield, Walsall’s Table 31 Page 506 fails to identify which parcel of land is on Green Belt. This is misleading the public.

The current policy on the Green Belt from the National Planning Policy Framework (NPPF) states:
137 The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

138. Green Belt serves 5 purposes:
(a) to check the unrestricted sprawl of large built-up areas;
(b) to prevent neighbouring towns merging into one another;
(c) to assist in safeguarding the countryside from encroachment;
(d) to preserve the setting and special character of historic towns; and
(e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

To include and redraw the Green Belt in the current draft plan contravenes the NPPF.

The narrative for Walsall does not set out why those tests should be overridden and once they are in the plan, there would therefore be no need to be any justification at the planning permission stage that there are very special circumstances to justify building on the Green Belt.

Moreover the sites that are suggested are either on or near Sites of Local Importance for Nature Conservation SLINC and/or agricultural land. The policy document is silent on more efficient use of this land for local agricultural and community purposes.

Conclusion

For all those reasons, and the fact that many constituents have contacted me with serious concerns and objections, I would submit that the land identified as follows should be removed from the draft plan:

• WAH 231 Land off Sutton Road/Longwood Lane (breaching s138 (a) (c) and (e)

Object

Draft Black Country Plan

Representation ID: 21232

Received: 11/10/2021

Respondent: Vera & Maurice Whitehouse

Representation Summary:

Site Reference - WAH231 - Sutton Road I Longwood Lane. Strategic Allocation - WS.6
Comments below are made in reference to site WAH231 and refer to areas in various sections of the document.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLING) there is a
serious loss of wildlife habitat which will arise as part of this proposed development. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports around various
environmental factors all relating to the WAH231 site.
• Serious health risk to Sutton Road/Orchard Hills residents from increased traffic pollution/noise.
• Increased stress to Sutton Road residents with construction work and loss of green space.

Town Planning, Infrastructure, Health & Wellbeing
• Proposed site has no pedestrian and no cycle access. Also lack of any street lighting on
Longwood lane, and pavement.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road with no proposed details of how this would be managed.
• Neighboring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only
compounded by the fact that housing on this particular space will result in creation of a bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible
options for walking to schools which is encouraged across all local authority schools.
• Design Principles around more capacity for schools, and medical facilities are all hypothetical with no evidence in any of the proposals around how this will be achieved.
• Proposed dwellings per hectare (dph) of 35 indicated is out of character with local area.

Landowners for significant portions of the land have NOT been consulted throughout this process, and do NOT support the proposed development. Based on all the above I believe this should be removed from the Black Country Plan.

Object

Draft Black Country Plan

Representation ID: 21392

Received: 11/10/2021

Respondent: Mr Samantha Smith

Representation Summary:

Site Reference -WAH231 - Sutton Road I Longwood Lane. Strategic Allocation - WS.6 Comments below are made in reference to site WAH231 and refer to areas in various sections of the document.

Environment
• As the site is a designated Site of Local Importance for Nature conservation (SLING) there is a serious loss of wildlife habitat which will arise as part of this proposed development. This needs to be protected.
• Various inconsistencies between plan and local site assessment reports around various environmental factors all relating to the WAH231 site.
• Serious health risk to Sutton Road/Orchard Hills residents from increased traffic pollution/noise.
• Increased stress to Sutton Road residents with construction work and loss of green space.

Town Planning, Infrastructure, Health & Wellbeing
• Proposed site has no pedestrian and no cycle access. Also lack of any street lighting on Longwood lane, and pavement.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road with no proposed details of how this would be managed.
• Neighboring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that housing on this particular space will result in creation of a bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.
• Design Principles around more capacity for schools, and medical facilities are all hypothetical with no evidence in any of the proposals around how this will be achieved.
• Proposed dwellings per hectare (dph) of 35 indicated is out of character with local area.

Landowners for significant portions of the land have NOT been consulted throughout this process, and do NOT support the proposed development. Based on all the above I believe this should be removed from the Black Country Plan.

Object

Draft Black Country Plan

Representation ID: 21398

Received: 11/10/2021

Respondent: Mr Sandeep Lalli

Representation Summary:

WAH231 - Sutton Road / Longwood Lane. Strategic Allocation - WS.6
=======

Comments below are made in reference to site WAH231 and refer to areas in various sections of the document.

Please note my objections below.
• Proposed site has no pedestrian and no cycle access. Also lack of any street lighting on Longwood lane, and pavement.
• Sutton Road/Longwood Lane would be unable to cope with increased traffic congestion including access issues into Sutton Road with no proposed details of how this would be managed.
• Neighboring areas such as Orchard Hills, Park Hall will see increased traffic as a result, only compounded by the fact that housing on this particular space will result in creation of a bottleneck within the local area causing disruption not just to residents but schools, and businesses too.
• No capacity for increase in pupils at local schools and increased traffic as there is no feasible options for walking to schools which is encouraged across all local authority schools.

It is also my understanding that the Landowner has not been consulted and does not support the proposed development.

Object

Draft Black Country Plan

Representation ID: 21468

Received: 11/10/2021

Respondent: Mr Stephen Everton

Representation Summary:

I strongly object to the proposed housing allocation at the Sutton Road/Longward Lane (Ref WAH231) site. Whilst I accept that there is a need long term to provide additional housing within the Walsall Borough, the location and the density of the housing proposed here is not appropriate in my view.

This is as Sutton Road is low density in character, comprising large dwellings within spacious plots and long gardens. The boundary between the built-up area and the Green Belt is strong and consistent along the Sutton Road up to the former Three Crowns Pub site. The proposed allocation for 202 dwellings at 35 dph would severely harm the low-density character of the Sutton Road area, which is a unique and sought after area of Walsall due to its semi-rural feel.

Further, Sutton Road serves as one of the main commuter routes in and out of Walsall, and at peak hours within the morning and evening is very congested. The junctions at Longward Lane and Daffodil Road are severely problematic at these times, with traffic along this stretch leading up to and between these two junctions (also the length of the proposed site) at a very slow crawl. I would therefore anticipate that the relatively dense housing development at the proposed Sutton Road site would severely exacerbate this issue, even with any additional traffic management measures.

As such, I would strongly urge the Council to reconsider the proposed siting of housing at the Sutton Road site, as the proposed housing here would clearly harm the semi-rural character of the Sutton Road area and severely exacerbate existing traffic issues.

Object

Draft Black Country Plan

Representation ID: 21931

Received: 11/10/2021

Respondent: Mrs Natalie Stanway

Representation Summary:

I am emailing my comments over objecting to the development on the land WAH231behind Sutton Road.

Reasons below....
1. Major traffic congestion on Longwood Lane and Sutton Road increased.
2. Longwood Lane has no pedestrian access
3. Schools already over capacity (not enough space for
all pupils).
4. Proposed dwellings out of character.
5. Health risks Sutton Road residents due to pollution and noise
6. Serious loss of wildlife. [Redacted] are all frequent visitors and residents in the land.
7. WAH231 a site of local importance for nature conservation (SLINC) and should be protected.
Walsall local authority. WAH231 site.

Object

Draft Black Country Plan

Representation ID: 22065

Received: 08/10/2021

Respondent: Mr Neale Aston

Representation Summary:

My objection is regarding the proposed builds on Queslett Road East and Sutton Road / Longwood Lane.
1. How is the increased traffic provisioned for.
1162 houses = Approx 2000 cars. The road network is not big enough to support the present traffic and any road network extension would mean building on Green Belt land i.e. Barr Beacon. Any increase on current levels of road usage is not sustainable and unworkable.
2. Affect on wildlife - obvious concequences to wildlife bats etc.
3. Increased traffic during proposed build - not workable.
There are already traffic and safety concerns in the area following the increased usage of the Disposal tip on Chester Road. There have been a number of "close calls" regarding heavy duty trucks on Little Hardwick, Chester Road and Beacon Hill. These have been reported

Object

Draft Black Country Plan

Representation ID: 22393

Received: 08/10/2021

Respondent: Inland Waterways Association Lichfield

Representation Summary:

Policy WSA6 - Land off Sutton Road, Longwood Lane, Walsall
This site is an important area of countryside alongside the Rushall Canal. It is part of the West Midlands Green Belt which serves to check the sprawl of built-up areas, to encourage the regeneration of urban land, and to safeguard the countryside. Its proposed removal from the Green Belt would undermine those purposes and damage the setting and economy of the canal. Therefore, IWA objects in principle to its allocation for development. However, if exceptional circumstances can be proven then it is important that the adverse impact of development on the canal is limited and mitigated by sensitive layout, design and landscaping.
The Rushall Canal is a historic waterway and a valuable amenity and recreational corridor, providing leisure boating, walking, angling, cycling and nature conservation benefits to the area. It is part of the national waterway system which attracts millions of visits each year from local people and holidaymakers from home and abroad, and is a major component of the nation’s tourism industry.
The rural environment of the canals plays a vital role in attracting and sustaining the recreation and tourism use of the whole canal system, which contributes to the visitor economy and helps support local businesses. The income from boating activities provides a major part of the funding necessary for the Canal & River Trust to maintain the canals for public use and enjoyment.
Although much of the canal network in the Black Country is urban or suburban in character, the northern parts of the system in Walsall in particular include several attractive countryside sections. Because of their limited extent, these are of particular value to sustaining tourism as well as an important amenity for nearby residents.
However, major built developments in the countryside adjacent to the canal system destroy the rural setting that contributes to their heritage interest, wildlife, amenity value and recreational use. Visually intrusive built development alongside the canals damages their tourism potential and economic benefits.
The Rushall Canal currently enjoys a pleasant open rural outlook across this site that enhances its attractiveness for recreational use. The canal towpath is open to the public and provides an accessible footpath. However, the attractive countryside setting of this section of the canal will be largely lost by this proposed allocation. Whilst the canal corridor will provide an amenity for the new residents, its overall value to the local community and the visitor economy would be diminished if the development is visually intrusive.
It is therefore important that the visual impact of the development on the canal is limited by sensitive design, layout and landscaping through appropriate masterplanning of the site. The canal and the adjacent area is shown as a Site of Local Importance for Nature Conservation (SLINC) on the Strategic Allocation plan. This should be preserved and enhanced by setting back the built development behind a broad buffer zone alongside the canal with only limited built development forming a continuous corridor of open amenity land to help preserve and enhance the canal environment. This corridor could encompass Public Open Space, parkland, woodland, wildflower meadows, sports fields, children’s play areas and informal recreation space.
This will be in line with the aspirations of Policy ENV7 – Canals, that development affecting the canal network should (1) “deliver a high quality environment”, (2e) “protect and enhance its visual amenity, key views and settings”, (3a) “enhance and promote its role in providing opportunities for leisure, recreation and tourism activities”, and (3d) “positively relate to the waterway by promoting high quality design, including providing active frontages onto the canal and by improving the public realm”.

Support

Draft Black Country Plan

Representation ID: 22398

Received: 30/09/2021

Respondent: CT Planning

Representation Summary:

LAND TO R/O 263A SUTTON ROAD, WALSALL

This representation is made on behalf on Friel Homes with respect to land to the rear of 263a Sutton
Road. This site forms part of the proposed strategic housing allocation Site WSA6 Land off Sutton Road,
Longwood Lane.

Support the proposal at Policy HOU1 (Delivering Sustainable Housing Growth) to provide land to
deliver some 47,837 new homes over the period 2020-2039. Particularly support proposed strategic
housing allocation WSA6 Land off Sutton Road, Longwood Lane identified on pages 558-559, Table 31
and the Policies Map to the draft Black Country Plan.

Support the proposed allocation of Land at Sutton Road, Longwood Lane as a strategic housing
allocation. The site is well related in terms of scale and location to the existing pattern of development
including the residential development that adjoins the site to the south and east. The site is located
such that it is within easy walking distance of all services and facilities within Walsall. Everyday
activities can be undertaken from the site, where there is the need to travel there is the opportunity
to do so by sustainable means. The site adjoins Sutton Road a public transport route where regular
bus services provide links to Walsall, Sutton Coldfield and Birmingham.

The site can deliver the required 200 dwellings. Development of the site will provide for a range of
housing in terms of size, type, design and tenure, including affordable housing to serve local needs
and compliant with policy requirements.

The proposed allocation can be served by a single access. A recently submitted Transport Appraisal
demonstrates that a new access can be provided at 263a Sutton Road to serve the site. Furthermore,
development of the site can deliver enhanced provision for pedestrians and cyclists, including
enhanced connectivity to the national cycle route CR012 along the Rushall Canal to the rear of the
site. A scheme which incorporates blue and green ways across the development that combines residential living with a high-quality environment can be delivered on the site with a biodiversity net
gain. There are no known technical constraints to development.

The Site WSA6 Land off Sutton Road, Longwood Lane is available, suitable and achievable for housing.
There are no known technical constraints that would prevent the site from being brought forward for
development. A development of 200 houses in this location would represent a logical extension to
Walsall and would provide for a balanced and sustainable development. The site should be retained
as a proposed Strategic Housing Allocation in the emerging Black Country Plan.

Object

Draft Black Country Plan

Representation ID: 23393

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Representation Summary:

WAM231 (WSA 6) Walsall Sutton Road
This parcel of land forms approximately half the land bounded by the Canal, Longwood Lane and Sutton Road. It is hard to see how there is a strong defensible boundary with the land immediately adjacent to it. The site is low-lying and potentially boggy. It currently has a footpath across it which links the far end of the Arboretum with Aldridge Airfield so it is part of an important leisure network, as well as an important natural site being immediately adjacent to the Canal. The houses would be visible not only to residents of Sutton Road but to the regular walkers and cyclists along the canal towpath and the path that bisects from the Longhorn Pub to the Arboretum. This is considered a sensitive location which should not be developed. The site is also considered inconsistent with Policy ENV8 both directly because of the existing footpaths and indirectly because of its location close to the Canal
Green Belt assessment in Land Use Consultants’ 2019 Green Belt Study - High

Comment

Draft Black Country Plan

Representation ID: 23561

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

1.0 Introduction

1.1 These representations have been prepared by Planning and Design Group (P&DG) on behalf of William Davis Limited (WDL) in response to the Regulation 18 Consultation on the Draft Black Country Plan 2018-2039.

1.2 These representations are made in the context of seeking to work with the Council to ensure that an effective and deliverable plan for the area is achieved. This document builds on earlier representations made by P&DG as part of previous consultation stages in the Local Plan process.

1.3 Our client has been promoting the land At Sutton Road, Longwood Lane identified as WAS6, a Residential Allocation in the emerging Local Plan. Our representations concern the policies which directly relate to the allocation and deliverability of this site.

2.0 Policy CSP1 - Development Strategy and CPS3 Town and Neighbourhood Areas and the Green Belt
2.1 WDL broadly support the development strategy set out by Policy CSP1 insofar as it increases the scope for sustainability located sites to come forward for development, to meet future growth needs across the Black Country Area.
2.2 The number of new homes to be delivered by the Spatial Strategy in the Local Plan (47,847) is expressed as ‘at least’ which is welcomed as the number of new homes required to meet the housing need is higher than this figure. We address this point in more detail under Policy HOU1 and this point is addressed in full by WDL, in their representation on Housing Need and Supply , a copy of this report by Turley’s is attached as Appendix 1 for reference.
2.3 WDL agree with the approach for sustainable patterns of development and welcomes the identification of Neighbourhood Growth areas including site WAS6. These are sites which are located in highly sustainable locations on the edge of the Urban Area. Site WSA6 fulfils this brief as it is immediately adjacent to the built-up area of Daisy Banks, a neighbourhood of Walsall and will function as an extension to this area with access to all the services facilities of Walsall Strategic Centre.
2.4 Policy CSP3 considers in more detail the areas outside the Strategic Centres, including the Neighbourhood Growth Areas.
2.5 The justification states that the purpose of the Neighbourhood Growth Areas is to support the delivery of a constant supply of new housing development, to be able to bring forward these sites quickly and for several sites to be developed simultaneously. The justification also recommends that such sites regardless of ownership are masterplannned as one site to ensure any new infrastructure is planned for. In the case of WAS6 an initial masterplan has already been produced for the whole site, attached as Appendix 2, it therefore can meet these requirements.
2.6 The reasoned justification states that Neighbourhood Growth areas should provide for at least 250 new homes, however WDL suggest that this figure is reduced to 200 new homes to reflect the ability of the sites to be well designed, reflect the local vernacular and allow for appropriate open space and ecological enhancement as per the proposed development of WAS6.
3.0 Policy GB1 – The Black Country Green Belt
3.1 Government planning policy on Green Belts can be found in the National Planning Policy Framework (NPPF). Paragraph 138 explains that the Green Belt serves five purposes. These are:
“a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”
3.2 The NPPF continues at Paragraph 139 that:

“The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions.”
3.3 Paragraph 140 then states:
“Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non-strategic policies, including neighbourhood plans.”
3.4 WDL note that that Council’s Local Plan evidence base shows that based on land availability ‘Exceptional Circumstances’ do exist to release land from the Green Belt for development and that it has carried out a full ‘Green Belt Assessment’ to find the most appropriate releases.
3.5 Site WSA6 is proposed to be removed from the Green Belt. WLD support that approach.
3.6 Previously P&DG prepared a ‘Call for Sites’ submission for site on behalf of WLD. The submission included our own Green Belt Assessment of site WAS6. We have also responded on behalf of WDL to the Black Country Green Belt Study. In relation to the 5 purposes of Green Belt (NPPF Paragraph 138 above), we made the following comments regarding site WAS6:
Purpose 1 -Check the Unrestricted Sprawl of large built-up areas
3.7 The site is bordered by urban development on the majority of its eastern and southern boundaries and is strongly contained by both this and the landscaped edge of the Rushall Canal to the west. The site is also compartmentalized by integral landscaping and sub-parcels denoting field boundaries, limiting its openness significantly. The site therefore has a predominant relationship with the urban fringe of Walsall as opposed to the countryside.
Purpose 2: Preventing the Merging of Neighbouring Towns
3.8 The development of the site would have a minimal impact in terms of coalescence. The development site lies on the edge of Daisy Bank, an existing part of Walsall. There is consequently no danger of this development leading to the merging with any adjacent separate urban area. The physical housing development will not protrude any further north beyond the existing ribbon development that fronts onto Sutton Road; it will in fact be situated behind it. As a result, there would be no cumulative extension of residential development northwards into the Green Belt that would ordinarily result in a reduction in the gap between Daisy Bank and Aldridge. The development would result in built form extending westwards towards the Rushall Canal but would not diminish the function of the area of Green Belt that extends in from the surrounding countryside towards the Walsall Arboretum.
3.9 This site performs no distinct role in contributing towards the gap between Walsall and Aldridge and the development limits would be contained in parallel with existing development without any further encroachment northwards towards Aldridge.

Purpose 3: Safeguarding the countryside from encroachment

3.10 The site’s eastern and southern boundaries are urbanised by residential development along Sutton Road. On the horizon to the west are notable urban structures forming the settlement of Walsall including urban development, including high rise housing. The sites’ location and surrounding uses can be described as urban fringe. We consider that the location and wider context would suggest that it possesses a stronger physical and visual connection with the existing urban form in Walsall, not limited solely to the neighbourhood of Daisy Bank but also the urban form further afield towards the central part of the town and at the western extent of the Walsall Arboretum.

3.11 It is accepted that the development would result in some encroachment into the defined countryside, but its contribution to this purpose is low as the site has a stronger relationship with the urban area than the countryside.

Purposes 4 is not applicable to this site

Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

3.12 The release of Green Belt in this location would place no harm upon the premise that is held in the development plan to allocate brownfield sites on a preferential basis, since from all of the evidence available there is simply not enough suitable brownfield land, either in the Green Belt or not, to meet the required housing needs across Walsall. As such, it is an acknowledged reality, that derelict urban land will not meet housing requirements and is not a significant element of the land supply.
3.13 The above analysis ratifies the Council’s decision to remove site WSA6 from the Green Belt, and this is fully supported by WDL.
3.14 In respect of the requirements set out in Policy GB1, criterion 2) a. requires the design of the development to include physical features that define the new Green Belt boundary in a readily recognisable and permanent way. WDL confirm that WSA6 can be developed in such a way. The canal already defines the boundary to the west and existing housing forms a boundary to the south and east. Therefore, it is only the northern boundary that will require consideration.
3.15 WDL does not support criterion 2) b. which requires compensatory improvements to the environmental quality, biodiversity and accessibility of remaining Green Belt to offset the impact of removing the land from the Green Belt. Compensatory improvements to environmental quality and biodiversity are covered by other policies within the Plan. Moreover, Green Belt is a planning designation and not one that is based on a site’s ecological value. It is also unclear how compensatory improvements to remaining Green Belt would be delivered. WDL therefore recommend this criterion should be removed from the policy.
4.0 Policy HOU1 – Delivering Sustainable Housing Growth
4.1 The Plan identifies an overall need for 4,004 dwellings per annum over the plan period (2020-39) – or 76,076 homes in total. While not specified, it is assumed that this has been calculated using the ‘standard method’ for determining ‘the minimum number of homes needed’, as is required in all but ‘exceptional circumstances’ according to the NPPF (Paragraph 61).
4.2 However, the Plan intends to only make provision through Policy HOU1 for 2,518 homes each year, or 47,837 homes in total. The justification for this policy clearly identifies that this will only accommodate 63% of current Local Housing Need up to 2039 within the Black Country. We assume, as it is not stated, that the Council will expect the shortfall of circa 28,198 homes to be met by the neighbouring authorities.
4.3 WDL have significant concerns that despite these housing figures only meeting the minimum need required, as they are not based on the most up to date emerging evidence, the figures underestimate both need and deliverability leading to a significant shortfall. We do not in these representations seek to interrogate the housing numbers or the approach taken by the Council in relation to the level of housing accommodated in the Plan (WDL has done this through a joint submission with other developers prepared by Turleys attached as Appendix 1). However, what this does highlight is the need for the allocated sites to be fully supported by the Council to enable them to be carried forward through the Plan process and any barriers to development or restrictions on deliverability minimised.
4.4 WDL also note that in addition to the sites already allocated in the Plan, there may be a need to identify additional sites to supplement these figures and to ensure that the Plan is prepared positively. It appears that currently the Plan cannot be found sound on the basis that the Council’s full level of housing need is not being met in its Plan.
4.5 Policy HOU1 provides the total number of houses to be delivered in the Plan period but does not specifically identify any individual housing sites. The proposed housing allocations are shown on ‘Figure 4 – Housing Key Diagram’, and Section 13 of the Plan contains a table setting out the allocations in each area. However, as neither the tables are worded as ‘policy’, nor the individual site descriptions in Section 13 within Policy HOU1 or that the individual site allocations are worded as a separate policy. This will ensure that the Plan is clear, and the individual allocations are accorded the appropriate weight.
5.0 Policy ENV1 Nature Conservation
5.1 WDL strongly object to the designation in the emerging Local Plan of Allocated Site WAS6 as a Site of Local Importance for Nature Conservation.
5.2 Prior to the publication of the consultation draft Plan, the site did not fall within the designation boundary of any site of international, national, or regionally important site for nature conservation. The area immediately adjoining the canal was covered by ‘Non -Statutory local designation – Wood End Farm Site of Local Importance for Nature Conservation (SLINC)’ and our submissions to date have been on this basis.
5.3 Previous submissions included a ‘Phase I Ecology Survey’. We attach this as Appendix 3. It concludes that the current habitats forming the site are generally of low ecological value with most of the site formed by grazed poor semi-improved grassland, with boundaries formed predominantly by native hedgerows and scrub with the domestic gardens of residential units along Sutton Road forming the eastern boundary. Other habitats present include dense bramble scrub, willow scrub, tall ruderal, waterbodies and flush habitat. It is important to note our survey included a walkover of the site.
5.4 The emerging Plan now covers the entire site allocation area with the Wood End Farm SLINC designation. Given our findings within the survey above, WDL does not believe the designation to be justified and it has not been clearly and fully evidenced as part of the Plan preparation.
5.5 The evidence relating to this designation is ‘An Ecological evaluation of the Black Country Green Belt’ (Evaluation) October 2019, produced by EcoRecord. This was a desk-based exercise.

5.6 WDL has a number of concerns with this evidence. In simple terms, the evaluation report maps the whole of the Black Country Green Belt and then assigns land parcels a rating based on the use they are currently in, what use they are next to, if there are water features nearby and if they are next to designated sites. It then provides a final ranking figure for each parcel of land.
5.7 In the case of WAS6 this forms part of a much wider parcel which includes Grange Park and the Walsall Arboretum to the West and the designated SLINC sites to the north. It is therefore washed over with a ‘very high’ ecological score.
5.8 WLD strongly object to the site being included as a SLINC on the basis of this report. It contradicts WLD’s own findings which were based on site specific data and a walkover of the site.
5.9 The NPPF at Paragraph 16 states that Plans should:
“d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;”
5.10 WDL is of the view that this poorly thought-out designation renders the WAS6 allocation ambiguous. On one hand the site is suitable for allocation, but on the other it has ecological value which would hinder development. Housing allocations need to be clear and robust, particularly to get local support. This designation will also confuse environmental stakeholders who offer advice to the Council.
5.11 As this designation is new and not based on rigorous on-site assessment (as was the WDL survey), WDL respectfully request the Council to remove it and as such, provide certainty on the Council’s behalf, that the site is deliverable.
5.12 Notwithstanding WDL’s objection to the designation, it would further object to the wording of Policy ENV1 which deals with such sites. It states:
1. Development within the Black Country will safeguard nature conservation, inside and outside its boundaries by ensuring that:
c) locally designated nature conservation sites (Sites of Local Importance for Nature Conservation), important habitats and geological features are protected from development proposals that could negatively impact them;
5.13 Part 1 of the policy shows no real differentiation between Internationally designated to locally designated sites as although worded slightly differently, the policy still seeks to preclude any development on these sites with no reference to any mitigation or compensation.
5.14 The policy does go on to state at Part 2 that adequate information must be submitted with planning applications that affect designated sites to ensure the likely impacts of the proposal can be fully assessed.
5.15 Although seemingly acknowledging the need for appropriate assessments this again does not mention mitigation or compensation and does not allow for development to take place, it merely requests information on the impacts.
5.16 Part 3 of the policy does allow development on nature conservation sites but states;

where exceptionally the strategic benefits of a development clearly outweigh the importance of a nature conservation site damage must be minimised and impacts fully mitigated against. (our emphasis)
5.17 Therefore, this policy as currently worded only allows development on designated nature conservation sites (including non-statutory SLINC’s) in exceptional circumstances where the strategic benefits clearly outweigh the conservation importance.
5.18 WDL does not think this is the intention of the policy, in fact it states in the evidence base ‘Site Assessment Appendix C Walsall’ in respect of site WAS6;
Some constraints could impact on the developable area, the existing pattern of development and arboricultural features could be used to mitigate any significant harm. A strategy for impact on the SLINC would need to consider mitigation and or compensation. Residential uses compatible with existing character.
5.19 It is therefore clear that although designating the entirety of the site as a SLINC the Council does consider that the site is developable, and the impacts can be mitigated and/or compensated for.
5.20 This was also the finding of WDL’s Phase I Ecology Survey which concluded that;
Any loss of grassland habitat will be mitigated for within the landscaping scheme via the creation of smaller areas of more species-diverse native grassland within the retained green corridor along the western boundary. A network of residential garden and tree and shrub planting within the site green infrastructure will provide further ecological enhancements and the implementation of such mitigation would ensure no net loss to biodiversity as required by NPPF
5.21 WDL therefore requests that if the designation as discussed above is retained, the wording is amended at Part 1 criterion b) to state:
development is not permitted where it would harm Local Nature Reserves and Sites of Importance for Nature Conservation unless it can be demonstrated that the need for the development outweighs any harm caused by the development and that adequate mitigation or compensatory measures are put in place.
6.0 Policy ENV5 Historic Character and Local Distinctiveness of the Black Country
6.1 Whilst in principle WDL does not have any objection to the wording of this policy, it does strongly object to the extension of the Grange Country Park Area of High Historic Landscape Value (AHHLV) boundary to cover the majority of site WAS6.
6.2 The evidence base which links to this policy is the Black Country Historic Landscape Characterisation Study. This is a desk-based study and from reading no site visits appear to have been undertaken to inform the recommendations.
6.3 Grange Country Park is identified as AHHLV 13, reading the description of this AHHLV it firstly gives no explanation as to why the boundary of the AHHLV was extended or even makes reference to the boundary having been extended. It is not clear, what, if any, assessment was made on site WAS6 and there is no clear justification for its inclusion.

6.4 The Study states that the importance of the AHHLV13 is in the main in relation to Ridge and Furrow features on site. WDL undertook an Archaeological Desk Based Assessment, (which includes a site walkover). This is attached as Appendix 4. The report identifies that extensive and well-preserved earthwork remains of ridge and furrow are to be found to the west of the site in the area of Walsall Arboretum. However, in regard to site WAS6, although there are intermittent areas of truncated and poorly preserved ridge and furrow on the site’s western and northern sides, they are of no more than local significance. The findings of this report reflect the previous boundary of AHHLV13 and WDL can see no justification for extending the boundary to cover the entirety of site WAS6.
6.5 The description also refers to the ‘potential to contain historic hedgerows’. Whilst WDL acknowledge that the site does contain hedgerows, these are afforded protection under policies ENV1, ENV3 and ENV9 and more specifically ENV 4 of the Plan and would not on their own constitute a reason for designating the site as an AHHLV.
6.6 WDL therefore object to the widening of AHHLV13 boundary to include site WSA6 as this has not been properly evidenced and is therefore not justifiable.
7.0 Strategic Allocation WSA6
7.1 WDL welcome and support the strategic allocation of WSA 6 for housing development.
7.2 Through successive submissions to the Council, WDL have demonstrated that the site can be removed from the Green Belt and allocated for residential development, in line with Government planning policy.
7.3 WDL has undertaken a Landscape and Visual Impact Assessment (LVIA), attached as Appendix 5, which identifies that there are only a limited number of constraints or issues in landscape and visual terms that reduce the site’s capacity to accommodate development. The assessment concluded that the opportunities to provide mitigation would ensure that the impacts of any development on the landscape can be minimised.
7.4 An Archaeological Desk Based Assessment has been undertaken which demonstrates that the site can be developed for residential development without causing any harm to designated or non-designated heritage assets. The potentially ‘important’ hedgerows can be retained as part of the proposals and any impact on earthworks can be mitigated through appropriate design and/or a staged programme of archaeological surveys.
7.5 A Phase I Ecology Survey was carried out on site which demonstrated that the current habitats forming the site are generally of low ecological value. Any loss of grassland habitat could be mitigated within the landscaping scheme via the creation of smaller areas of more species-diverse native grassland within the retained green corridor along the western boundary. A network of residential garden and tree and shrub planting within the site green infrastructure would provide further ecological enhancements and the implementation of such mitigation would ensure no net loss to biodiversity as required by the NPPF.
7.6 Again, as part of the ‘Call for Sites’ exercise, WDL submitted a ‘Vision Document’ to demonstrate how the site could be developed to respond directly to the site’s context with the potential to generate a positive sustainable community. It is clear from WLD’s initial work that WAS6 offers unequivocal opportunities to deliver a sustainable and quality residential development.

7.7 WDL therefore fully support the Council’s approach to allocating the site for residential development and is confident that the site is fully deliverable.
7.8 With respect to allocation WSA6, WDL would suggest that this is drafted as a policy, rather than a series of statements. This would provide more weight and certainty to its status and deliverability.
7.9 WDL generally support the objectives of the design principles relating to WAS6 but would recommend the following amendment to the wording to ensure that the policies are clearly written and unambiguous as per the NPPF guidance;
Improvements to local facilities which are proportionate to the amount of development proposed.
This change would ensure that any improvements requested as part of an application relate only to the potential impacts that the development may have.
7.10 WDL do strongly object to the following wording;
a Transport Strategy that includes single access onto Sutton Road.
7.11 This is unnecessarily prescriptive and premature when the transport work has yet to be undertaken and options explored. It is not yet known if an access from Sutton Road is the best solution and if insisted upon this could prevent the development from being delivered.
7.12 WDL have undertaken some initial work on the access onto both Longwood Lane and Sutton Road to explore both options. We include as Appendix 6 the engineering drawings. Restricting the access through policy wording, at this point to Sutton Road is unnecessary, and all options need to be further explored. Therefore, at this stage we request that the prescriptive wording is removed or amended to include;
A Transport Strategy that delivers a safe and suitable access.
8.0 Conclusions
8.1 WDL note that that Council’s Local Plan evidence base shows that based on land availability ‘Exceptional Circumstances’ do exist to release land from the Green Belt for development and that it has carried out a full ‘Green Belt Assessment’ to find the most appropriate releases.
8.2 WDL support the removal of site WSA6 from the Green Belt and its allocation for residential development and believe that the Council has followed Government planning policy in arriving at the allocation.
8.3 WDL do object to the new landscape and conservation allocations on site WSA6 and not believe these have been clearly and justifiably evidenced. WDL is of the view that these poorly thought-out designations render the WAS6 allocation ambiguous. On one hand the site is suitable for allocation, but on the other it has ecological value and landscape value which would hinder development. Housing allocations need to be clear and robust.
8.4 As these designations are new and not based on rigorous on-site assessment (as was the WDL survey), WDL respectfully request the Council to remove them and as such, provide certainty on the Council’s behalf, that the site is deliverable.

Comment

Draft Black Country Plan

Representation ID: 23587

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

Paragraph 4.3 - Because of the shortfall of housing "need for the allocated sites to be fully supported by the Council to enable them to be carried forward through the Plan process and any barriers to development or restrictions on deliverability minimised."

Support

Draft Black Country Plan

Representation ID: 23596

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

7.0 Strategic Allocation WSA6
7.1 WDL welcome and support the strategic allocation of WSA 6 for housing development.
7.2 Through successive submissions to the Council, WDL have demonstrated that the site can be removed from the Green Belt and allocated for residential development, in line with Government planning policy.
7.3 WDL has undertaken a Landscape and Visual Impact Assessment (LVIA), attached as Appendix 5, which identifies that there are only a limited number of constraints or issues in landscape and visual terms that reduce the site’s capacity to accommodate development. The assessment concluded that the opportunities to provide mitigation would ensure that the impacts of any development on the landscape can be minimised.
7.4 An Archaeological Desk Based Assessment has been undertaken which demonstrates that the site can be developed for residential development without causing any harm to designated or non-designated heritage assets. The potentially ‘important’ hedgerows can be retained as part of the proposals and any impact on earthworks can be mitigated through appropriate design and/or a staged programme of archaeological surveys.
7.5 A Phase I Ecology Survey was carried out on site which demonstrated that the current habitats forming the site are generally of low ecological value. Any loss of grassland habitat could be mitigated within the landscaping scheme via the creation of smaller areas of more species-diverse native grassland within the retained green corridor along the western boundary. A network of residential garden and tree and shrub planting within the site green infrastructure would provide further ecological enhancements and the implementation of such mitigation would ensure no net loss to biodiversity as required by the NPPF.
7.6 Again, as part of the ‘Call for Sites’ exercise, WDL submitted a ‘Vision Document’ to demonstrate how the site could be developed to respond directly to the site’s context with the potential to generate a positive sustainable community. It is clear from WLD’s initial work that WAS6 offers unequivocal opportunities to deliver a sustainable and quality residential development.

7.7 WDL therefore fully support the Council’s approach to allocating the site for residential development and is confident that the site is fully deliverable.

Comment

Draft Black Country Plan

Representation ID: 23604

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

Paragraph 7.8 - "With respect to allocation WSA6, suggest that this is drafted as a policy, rather than a series of statements. This would provide more weight and certainty to its status and deliverability."

Object

Draft Black Country Plan

Representation ID: 23605

Received: 11/10/2021

Respondent: William Davis Ltd

Agent: Planning & Design Group (UK) Limited

Representation Summary:

7.10 WDL do strongly object to the following wording;
a Transport Strategy that includes single access onto Sutton Road.
7.11 This is unnecessarily prescriptive and premature when the transport work has yet to be undertaken and options explored. It is not yet known if an access from Sutton Road is the best solution and if insisted upon this could prevent the development from being delivered.
7.12 WDL have undertaken some initial work on the access onto both Longwood Lane and Sutton Road to explore both options. We include as Appendix 6 the engineering drawings. Restricting the access through policy wording, at this point to Sutton Road is unnecessary, and all options need to be further explored. Therefore, at this stage we request that the prescriptive wording is removed or amended to include;
A Transport Strategy that delivers a safe and suitable access.

Object

Draft Black Country Plan

Representation ID: 43833

Received: 11/10/2021

Respondent: Mrs Val Rutter

Representation Summary:

Grange County Park (Walsall) is a popular area for dog walkers and with the canal forms a green corridor and lung for all sorts of animals, birds and flowers. Development up to the canal would gravely affect this. I would strongly oppose the suggestion for housing development.