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

Comment

Representation ID: 45352

Received: 04/10/2021

Respondent: Mr Nigel Stockham

All comments for Sutton Road/Longwood Lane. Pheasey Park Farm.
My wife and I and 2 sons have been residence on the Sutton Road for the past 27 years and we are very disturbed to hear that a number of developments are planned for the area. The traffic on the Sutton Road is already very congested and would be unable to take anymore traffic, this would cause major inconvenience and a danger to road users. I would also like to point out that the infrastructure is not in place to cope with these extra dwellings therefore I hope that common sense will prevail and this development will be rejected on these grounds

Object

Representation ID: 45847

Received: 07/09/2021

Respondent: Mr Joseph Horton

I wish to strongly protest against the development at Calderfields, Sutton Road and Longwood Lane and Pheasey Park Farm development. I am deadly opposed to this development as I don't want to see greenbelt development around where I live for as long as I live for my children and grandchildren.

Comment

Representation ID: 46205

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

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

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

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










23

9.4 ture

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

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

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



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

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










24

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

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

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