Development Allocations

Object

Representation ID: 44819

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH069 Beever Road, Great Bridge - WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• WTBBC understand the allocation is an area of public open space. It is WTBBC’s position that due to the broad range of benefits that these sites provide local communities that no public open space should be allocated for development. Objection on this basis.

Object

Representation ID: 44820

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH070 Land at Horseley heath, Alexandra Road and Lower Church Lane, Tipton
WTBBC have concluded that the Site Assessment process should not have selected site:
• The site is a Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity. WTBBC therefore object to the allocation on this basis.
• A recent Local (wildlife) Site Assessment (LSA) recorded that the northern part of the SLINC had been lost to development. WTBBC are not aware of any LSA having been undertaken to inform the planning decision.

Comment

Representation ID: 44821

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH083 Swan Lane Former Gas Works
It is WTBBC’s position that features within the site should be retained:
• The site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity. It is therefore WTBBC’s position that the SLINC and a suitable buffer between this and the development area be retained, thereby providing an area of high quality accessible natural greenspace.

Comment

Representation ID: 44822

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH086 Former Sunlight Laundry, Stanhope Rd, Smethwick
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.

Object

Representation ID: 44823

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH088 Rattlechain Site, Land to the north of Temple Way, Tividale, Oldbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity.
• The remainder of the site has been identified as Potential Site of Importance (for nature conservation).
• A completed Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process.
• WTBBC object to the allocation on this basis.

Object

Representation ID: 44824

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH091 Land at Friar Park Road, Wednesbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity.
• Much of the remainder of the site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process.
• WTBBC object to the allocation on this basis.

Object

Representation ID: 44825

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH098 Temple Way (Rattlechain), Tividale, Oldbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.

Object

Representation ID: 44826

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH100 Edwin Richards Quarry, Portway Road, Rowley Regis
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity.
• Much of the remainder of the site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process.
• WTBBC object to the allocation on this basis.

Comment

Representation ID: 44827

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH103 The Phoenix Collegiate, Friar Park Road, Wednesbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• Site includes an area of Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity.
• Part of the remainder of the site has been identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process.
WTBBC object to the allocation on this basis.

Object

Representation ID: 44828

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH224 Land off Tanhouse Avenue, Great Barr
WTBBC have concluded that the Site Assessment process should not have selected site:
• The site is a Site of Local Importance for Nature Conservation (SLINC).
• Adjoins a Local Nature Reserve and Site of Importance for Nature Conservation, therefore high potential for detrimental impact.
• Ecological Evaluation of BC Green Belt found site to be of Very High ecological value.
• High potential for Priority species on site.
• WTBBC strongly recommend that alternative development sites are sought in order to prevent loss of green belt.
• Development would have significant negative impact on amenity and aesthetic value of RSPB Sandwell Valley.

Object

Representation ID: 44829

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAH226 Land to north of Painswick Close Sub Station
WTBBC have concluded that the Site Assessment process should not have selected site:
• The site is a Site of Local Importance for Nature Conservation (SLINC). The National Planning Policy Framework (NPPF) states that Local Plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity. WTBBC therefore object to the allocation on this basis.
• High ecological connectivity value (Draft BC Local Nature Recovery Strategy). Site forms part of an important ecological corridor linking Sandwell Valley to the Walsall green belt.

Object

Representation ID: 44831

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

WTBBC have concluded that the Site Assessment process should not have selected site:
• Site identified as Potential Site of Importance (for nature conservation).
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• WTBBC understand the allocation is an area of de facto public open space. It is WTBBC’s position that due to the densely urban local landscape and the broad range of benefits that public open space provides, the formalisation of this use should be pursued.

Comment

Representation ID: 44832

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE246 Whitehall Road, Tipton
WTBBC request that the following is required of the site redevelopment:
• Site adjacent to a canal: Include measures to ensure the development doesn’t have both short and long term detrimental effects on the adjacent canal corridor (please also refer to WTBBC comment under policy ENV7) and, through the implementation of Black Country Plan Policy, support development that not only causes no damage but also delivers enhancements to the Local Nature Recovery Network.

Object

Representation ID: 44833

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE176 Coneygree, Newcomen Drive, Tipton
WTBBC have concluded that the Site Assessment process should not have selected site:
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• High potential for/evidence of presence of priority habitats and species (namely Open Mosaic Habitats on Previously Developed Land (OMHPDL), rare plants, butterflies and other notable invertebrates/of conservation concern).
• Site forms part of important and well connected area in Draft Local Nature Recovery Strategy.

Object

Representation ID: 44834

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE200 Land adjacent to Asda, Wolverhampton Road, Oldbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• Site is adjacent to River Tame and forms part of the wider Tame Valley Wildlife Corridor. Development of this site would significantly narrow the corridor at this point.
• High potential for/evidence of presence of priority habitats and species.
• Site forms part of important and well connected area in Draft Local Nature Recovery Strategy.

Object

Representation ID: 44835

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE158 Severn Trent land off Roway Lane, Oldbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• High potential for/evidence of the presence of priority habitats and species (namely Open Mosaic Habitats on Previously Developed Land (OMHPDL), rare plants, butterflies and other notable invertebrates/of conservation concern).
• Site forms part of important and well connected area in Draft Local Nature Recovery Strategy.

Object

Representation ID: 44836

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE253 Rounds Green Road / Shidas Lane, Oldbury
WTBBC have concluded that the Site Assessment process should not have selected site:
• A Local (wildlife) Site Assessment is required to provide evidence to inform the BCP Site Assessment process. This has not been undertaken and therefore WTBBC object to the allocation on this basis.
• Site forms part of important and well connected area in Draft Local Nature Recovery Strategy.

Comment

Representation ID: 44837

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

SAE256 Site off Bilport Lane, Wednesbury
It is WTBBC’s position that the following needs to be considered:
• Site, including stream banks, should be subject to a Local (wildlife) Site Assessment.
• Opportunity exists to retain significant buffer to River Tame, create high-quality accessible natural greenspace and undertake in-channel river enhancements.
• High potential for/evidence of the presence of priority habitats and species (namely Open Mosaic Habitats on Previously Developed Land (OMHPDL)).
• Site forms part of important and well connected area in Draft Local Nature Recovery Strategy with evidence of the presence of statutory protected species.

Object

Representation ID: 45832

Received: 12/03/2022

Respondent: Nicola Richards

Number of people: 1067

Charlemont Community Centre (SAH225)

• The existing Charlemont Community Centre has been allocated as a housing site, albeit only for a single unit. It is unclear if this unit would be related to a single residential development or a development of flatted residential units.
• A flatted development would add additional strain to public services. Those exact services may be
reduced to the loss of potential outreach services that could be based at the community centre.
• The centre is situated within a wider housing estate with a high concentration of families and individuals with complex needs. Targeted community intervention in areas such as Charlemont are of deep importance to residents.
• This centre is currently dramatically underused. Sandwell Council should focus its efforts on
maximising the usage of this location to provide vital services to improve people' s quality of life, rather than unnecessari1y add to the strain on public services in this area.

• Please find enclosed a petition of 311 signatures requesting the removal of Charlemont Community
Centre from the Draft Plan.

Object

Representation ID: 45833

Received: 12/03/2022

Respondent: Nicola Richards

Number of people: 1067

Painswick Close, Yew Tree (SAH226)

• The proposals for 140 new homes in this location would represent an unacceptable harm to existing green belt boundaries, encroaching on green belt that separates Walsall and Great Barr. The reduced space between the two settlements will affect the respective identities of each community.
• The site also has a SLINC designation on the woodland area that would be affected by its allocation for housing.
• The wider Yew Tree area does not have sufficient public services and facilities to serve an additional 140 households. There are existing traffic congestion issues and a lack of services in the area, such a postal services and access to cash.

• Yew Tree Primary School is an example of a public service which is already at capacity. The development of 140 properties in this area would add further strain to this facility.
• Please find enclosed a petition of 501 signatures requesting the removal of Painswick Close, Yew
Tree from the Draft Plan.

Object

Representation ID: 45834

Received: 12/03/2022

Respondent: Nicola Richards

Number of people: 1067

Tanhouse Avenue, Newton (SAH224)

• This location is a reclaimed green space which sits between residential areas in Newton and Sandwell Valley RSPB and Sandwell Valley reserves. The allocation of this site essentially encroaches onto the natural area around Sandwell Valley, its vital wildlife corridors, and
conservation areas.
• I dispute the findings in the Site Assessment Summary that there would be no impact on the wider Green Belt. The adjacent RSPB reserve is a haven for birds and other species that may indeed be endangered. Encroachment by development onto this site would narrow the boundaries of the wider natural area and damage bio diversity and existing habitats.

• There is an existing, small access road for the RSPB site. Any development would see the need for road infr astructure improvement which may negative ly impact on this important conservation site. Increased road traffic could impact on the species that can be found in the area.
• Please find enclosed a petition of 255 signatures requesting the removal of Tanhouse Avenue, Newton from the Draft Plan.

Comment

Representation ID: 46064

Received: 26/09/2021

Respondent: Mr ANDREW FROST

Are the drafters of the BCP aware that the land proposed for housing development known as Brandhall UrbanVillage is the subject of a legally binding Covenant between Sandwell MBC (landlord)and Sandwell Leisure Trust (tenant) that runs from
2004until 2034 and protects the land from housing development in that period? FOI request has been made to require the Covenant text to be in the public domain

Object

Representation ID: 46070

Received: 11/10/2021

Respondent: Mrs Rachel Bolger

Summary: Object to proposed housing allocation at Brandhall Golf Course - contrary to England Trees Action Plan, Forestry Commission Guidance, Sandwell's Green Space Audit, Sandwell's Urban Tree Policy, National BNG objectives, local biodiversity objectives conatined within the adopted local plan and the Black Country AQMA

Changes to plan: Agreed that housing delivery and meeting housing need is imperative across the Black country but not at the detriment of Community Green Lungs. GB release is inevitable and provided this is sustainable and on edge of settlement boundaries, this is a preferable option to the redevelopment of green spaces within heavily built up urban areas which the surrounding community benefit from. Brandhall Golf Course has been left to re-wild since its closure, consistent with the governments approach to 'rewilding Britain'. Tree planting is also on the governments agenda via England Trees Action Plan to increase tree coverage within coming years. There is no way that this site can be developed and the trees retained given the existing levels and groundwork involved. The UK is also one of the worst performing countries in terms of its biodiversity value https://www.endsreport.com/article/1716204/uk-worst-nature-protection-among-g7 and losing this site is contrary to increasing biodiversity across the Black Country and will not accord with the forthcoming environment plan. Brandhall golf course performs not only an ecological and aesthetic function for the surrounding, largely deprived, areas of housing but also performs as an area of recreation and provides and escape for nearby residents assisting with mental well-being. Development of this site does not accord with the Government's BROWNFIELD FIRST POLICY nor many of the adopted policies within the current Black Country Core Strategy

Support

Representation ID: 46204

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The inclusion of Brades Road, Oldbury as a proposed site allocation (site reference: SAH229) is fully supported Vulcan Property II Limited for the reasons set out in the 4 August 2020 call for sites submission.

Vulcan Property II Limited also fully supports the inclusion of adjoining land on Dudley Road East (site reference: SAH227) for the same reasons.

There is potential for Brades Road to come forward earlier in the plan period than 2032-2033 and justification for it being identified for delivery earlier in the housing trajectory. The significant shortfall in housing provision over the plan period and the uncertainty over housing numbers to be provided out of area through ‘Duty to Co-operate’ suggests very strongly that sites that are suitable and available should be identified as coming forward earlier in the housing trajectory, where there is potential for this to happen. There is good reason to expect that delivery out of area will be skewed to the latter stages of the Black Country Plan period, given that those neighbouring authorities will justifiably prioritise meeting their own housing requirements. This suggests that there is good reason to front-load the proportion of new homes delivered within the Black Country Plan area, where there is evidence that sites are available and deliverable.

Brades Road is potentially available in the shorter-term, and earlier delivery than 2032-2033 is possible.

Comment

Representation ID: 47045

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Birmingham Road, Great Barr (site ref: SA- 0003-SAN) site assessment

HIMOR is promoting land at Birmingham Road, Great Barr for residential development. The site provides an opportunity to create a sustainable and high quality new community, delivering a wide range of new family and affordable homes in a highly accessible and sustainable location, which is fully supported by a robust site specific evidence base which we have discussed and introduced at section 2 of these representations.

Our evidence base does not support the Council’s site assessment of the above site, which is then followed through to the SA, as evidenced by our critique at Appendix 9. Indeed the site should score much more positively, which reflects the pressing need for sites of this nature in Sandwell given the deficiencies in its proposed housing land supply, the scale of the shortfall, and its chronic under supply of affordable housing. We summarise the key findings from the critique below:

• The Councils’ Green Belt Review assesses the entirety of HIMOR’s land ownership scoring it ‘High’ harm. When a reduced area is assessed based on the actual proposed development area (based on either options 1 and 2), development at the site scores a much reduced ‘Low-Medium’ harm.

• As demonstrated by the Ecology Solutions Biodiversity Technical Note (Appendix
5) and its associated documents, it is clear the biodiversity value of the site has been overplayed and is not justified. Firstly the process for making the designation is not transparent and has not been subject to appropriate public consultation or independent scrutiny. Also the status of the designation is not clear as it has not been formalised in any Policies Map. The designations validity is therefore questionable, as is how much weight, if any, can be given to it. Secondly, the assessment of the site undertaken by the Wildlife Trust is seriously flawed, it significantly overplays the site’s ecological value. Its findings on the site’s ecological value are not evidenced, it over values the grassland habitat, its assessment of naturalness is inaccurate, and it over scores species rarity. We contend that the site’s value is lower than that stated in the Assessment and accordingly would not meet the criteria for it being made a SINC. Notwithstanding this, our proposals are capable of preserving the key features of the proposed SINC and existing SLINC, including through the retention and bolstering of existing hedgerows within the site, as well as achieving a net gain in biodiversity. The site should therefore score ‘Green’ for ecology.

• Any non-designated archaeological remains at the site will be undeveloped and maintained as part of any development proposals for the site. The historic field pattern will be incorporated into both proposed development options. This would preserve the features which are proposed as justification for designating the site as an Area of High Historic Landscape Value. There is no evidence that there are remains greater than local importance. The site should therefore score ‘Green’ for heritage.

• PJA’s Transport Technical Note demonstrates that the site is in a much more accessible location than the Site Assessment indicates, for instance the site is located adjacent to the Q3 Academy which is much closer than the Site Assessment acknowledges. There is also the opportunity to provide a health centre.

• At the moment the site is completely inaccessible to the public. Our proposals would deliver significant area of public open space, such as through the provision of a new country park in a location which is not currently accessible to the public. This is a significant benefit.

4.3 Notwithstanding the above, there is also concern with the application of the site selection methodology. Section 3 of the methodology for Green Belt sites states the criteria for filtering our sites include where development would cause ‘Very High’ harm to the Green Belt and ‘Moderate-High’ harm to landscape sensitivity, and where there is one or more significant planning constraint which cannot be mitigated.

4.4 As set out above, there is clear evidence that Green Belt and landscape sensitivity has been overstated for HIMOR’s site at Birmingham Road, Great Barr, largely because the Councils’ assessments have assessed a wider area of land than is proposed for development.

4.5 The methodology has been applied inconsistently, there are examples where sites which have scored ‘Very High’ Green Belt harm and ‘Moderate-High’ landscape harm have been proposed for allocation – land at Stonnall Road, Aldridge in Walsall Borough (site ref: SA-0309-WAL).

4.6 The Council has also over valued the site’s biodiversity and its proposed SINC designation is not justified.

4.7 In summary, our evidence demonstrates that the role the site would play in delivering new homes sustainably in Sandwell has been underplayed by the Site Assessment and SA, and this has followed through to the Councils’ approach to site selection. It should therefore be a proposed allocation in the plan, not least because of its range of benefits, including the provision of extensive public open space and the contribution it will make to Sandwell’s chronic affordable housing shortfall.