Draft Black Country Plan

Object

Representation ID: 12550

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

Summary of key issues:
The Birchills Agenda 21 Group has significant concerns and strongly object to the proposed inclusion of the following urban green space sites within a proposed 'Core Regeneration Area' designation as shown within the Figure 19: ‘Walsall Spatial Strategy Plan’ on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document.
We have concerns in relation to the inclusion of the following public open space sites within the proposed Core Regeneration Area designation:
• • Pouk Hill natural green space area, immediately bordering Pouk Hill Close, located off Bentley Lane, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway network.
• • Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway.
• • Reedswood Town Park public open space.
• • Former Reedswood Golf Course natural green space area.

A large number of sensitive urban green space sites within the Birchills and Reedswood areas of Walsall have been included within this proposed Core Regeneration Area designation within the emerging Black Country Plan (BCP) (Review) (Regulation 18) (2021) public consultation document. To be perfectly clear, by including all of them within a proposed Core Regeneration Area, these highly sensitive urban green space sites are being actively promoted as potential new development sites by Walsall Council for either new build housing or new employment land uses. This aspect is confirmed on the land use key (Core Regeneration Area) of the Figure 19: ‘Walsall Spatial Strategy Plan’.
This proposed spatial planning policy approach will deliver widespread ‘landscape-scale’ ecological habitat damage to the local area, conflicting with central Government (London) national planning guidance as set out in paragraph 179 of Revised National Planning Policy Framework (NPPF) (published July 2021). Paragraph 179 of the Revised NPPF (2021) reinforces the importance of conserving and protecting wildlife corridors and important ecological networks.
It will also conflict with outdoor recreation and green space focused national planning guidance (covering the whole of the United Kingdom) as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021). Paragraph 92 (indent c) confirms that:
“…Planning policies and decisions should aim to achieve healthy, inclusive and safe places which: (indent c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure…”
Paragraph 98 is clear that: “…Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities…”
Walsall Council’s proposed spatial planning policy approach to actively promote the re-development of Reedswood’s and Birchill’s last remaining few sensitive urban green space areas and critically important woodland urban green space lungs alongside the M6 motorway network as potential future development sites for new build housing or new employment land by including all of them directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is promoting inappropriate, damaging and unsustainable patterns of development within the local area.
This proposed planning policy approach is unsound and unreasonable, and we therefore raise strong objections to this proposed spatial planning policy approach being taken within the Walsall Metropolitan Borough within the emerging BCP (Review) (2021).
As a key local stakeholder representing thousands of local residents, the Birchills Agenda 21 Group therefore specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from the above sensitive urban green space sites within the emerging Black Country Plan (BCP) (Review) (2021). All of these sensitive urban green space sites should be given appropriate green space planning policy protection within the emerging BCP (Review).
Both Goldfinch Town Planning Services (West Midlands) and our client Birchills Agenda 21 Group maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach as set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that important areas of urban green space continue to remain protected for the wider benefit of thousands of local residents to enjoy for outdoor recreation purposes, and ensure the protection of important landscape-scale wildlife corridors across Reedswood, consistent with guidance in paragraphs 92 (indent c), 98 and 179 of the Revised NPPF (July 2021).
Pouk Hill public open space, Bentley Lane (located east of the T-junction of Bentley Lane and Birchover Road), Reedswood, Walsall.
The Pouk Hill urban green space area is critically important for the following reasons:
• • It provides an essential woodland urban green lung helping to significantly reduce harmful levels of air pollution from the M6 motorway: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing areas of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of Nitrogen Dioxide (NO2), fine Particulate Matter (PM2.5), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs) or hydrocarbons (HCs) and nitrogen oxides (NOx) harmful toxic air pollution levels from vehicular traffic using the heavily congested nearby M6 motorway network. By helping to filter-out, remove and reduce the above harmful levels of toxic air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a critical role in helping to protect the health of thousands of local residents living within the wider Reedswood area. Including residents living along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive. These local residents have a fundamental Legal Right to be able to breathe clean air under the European Convention on Human Rights (The Human Rights Act) Legislation, which is still in force as legislation despite Britain recently leaving the European Union (EU). By placing local communities within the Reedswood area at increased risk of developing lung disease by exposing them to greater levels of harmful air pollution by actively encouraging the re-development of critically important wooded urban green space lungs alongside Junction 10 of the M6 Motorway network, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is therefore contravening Article 2 of the Human Rights Act Legislation which protects a person’s right to life.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of United Kingdom (UK) wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in
• order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Helps reduce vehicular traffic noise levels from the M6 motorway: It forms a natural green space woodland buffer which helps to protect residential communities in the Reedswood area by reducing the levels of constant traffic noise from the M6 motorway network, which gets worse during rush hour peak commute times and at weekends. Walsall Council’s spatial planning approach within the emerging Black Country Plan (BCP) (Review) is having a harmful impact on the residential amenity of local established residential communities within the Reedswood area by exposing local residents to increased risks of noise pollution from the M6 motorway network by encouraging the re-development of mature woodland buffers alongside the M6. This is contravening our human rights under Article 1 of the First Protocol: ‘Protection of property’ of the Human Rights Act Legislation, which is clear that “every person has a right to the peaceful enjoyment of their property.”
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities within the Reedswood area. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). They are important for helping support physical and mental health well-being benefits. Natural England guidance stresses the importance of protecting these types of publicly accessible natural green space areas located on the doorstep of existing communities.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: The ongoing years 2020 and 2021 severe global coronavirus (COVID-19) pandemic (which represents one of the worst global health pandemic events to affect the United Kingdom (UK) within the last 100 years) has highlighted and placed into very sharp focus the increased relevance, importance and health benefits of conveniently located publicly accessible urban green space areas to local communities, such as the Pouk Hill open space.


• Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.
• • Helping support populations of protected wildlife species by providing an important wildlife habitat worthy of ‘Site of Importance for Nature Conservation’ (SINC) designation: The wider Pouk Hill natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging and roosting habitat for different bat species, which are observed using this green space regularly as a foraging habitat during dusk on warm summer evenings.
• • Important wildlife corridor: The Pouk Hill natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to Reedswood Town Park natural green space area, and other ‘stepping-stone’ natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 179 reinforces the importance of protecting wildlife corridors and important landscape-scale (e.g. serving a large part of the urban area) ecological networks. These areas are also protected in paragraph 174 (indent d) of the Revised NPPF (July 2021).
• • Black Country Urban Forest: The Pouk Hill urban green space forms part of the Black Country Urban Forest. This area of urban green space contained large areas of tree planting has been specifically planted with native broadleaved woodland tree species as part of the original Black Country Urban Forest initiative. This increases this areas sensitivity.
• Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to tackle the urban heat island effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally. The Pouk Hill urban green space site also provides a natural green space basin containing mature trees and dense vegetation. This helps to absorb rainfall during extreme weather pattern events (severe storms) therefore helping to control flash flooding by reducing surface water run-off rates. These weather patterns (higher summer temperatures and severe rainfall events) are increasing in severity due to climate change. The Pouk Hill urban green space therefore helps to make the Reedswood urban area more resilient to future climate change pressures. Rather than ignoring the climate change emergency, Walsall Council should be doing more to tackle the Climate Change
• Emergency within the Walsall Metropolitan Borough. By including all of Reedswood’s last remaining few sensitive urban green space areas within a proposed Core Regeneration Area designation, Walsall Council is damaging the local area by making it less resilient to future climate change pressures. Its proposed planning policy approach on this issue within the emerging Black Country Plan (BCP) (Review) (2021) is therefore considered to be unsound and insufficiently robust, and conflicts with key climate change focused national planning guidance as set out in Section 14 (Meeting the challenge of climate change) of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential communities by providing an area of mature broadleaved woodland, originally planted as part of the Black Country Urban Forest initiative. This natural urban green space area considerably enhances the visual amenity of overlooking established residential occupiers and contributes positively to local landscape character. Walsall Council’s proposed planning policy approach on this issue is introducing widescale landscape damage to the local area by urbanising all of Reedswood’s last remaining urban green space areas.
Core Regeneration Area
The Birchills Agenda 21 Group has significant concerns and strongly object to the inclusion of the Pouk Hill green space within a proposed 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan.
Given this natural green space areas sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from this sensitive public open space area within the emerging Black Country Plan (BCP) (Review) (2021). The position is perfectly clear, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is promoting inappropriate, damaging and unsustainable patterns of development within the Reedswood area of Walsall.
• A large number of sensitive urban green space sites within the Birchills and Reedswood areas of Walsall, including Reedswood Town Park green space, Pouk Hill public open space, and natural green space located immediately north of Churchill Road and the Jane Lane School, have been included within this proposed Core Regeneration Area designation within the emerging Black Country Plan (BCP) (Review) (Regulation 18) (2021) public consultation document. To be perfectly clear, by including all of them within a proposed Core Regeneration Area, these highly sensitive urban green space sites are being actively promoted as potential new development sites by Walsall Council for either new build housing or new employment land uses.
• This proposed planning policy approach is unsound and unreasonable, and we therefore raise strong objections to this proposed spatial planning policy approach within the emerging BCP (Review) (2021). This proposed spatial planning policy approach underlines the failure and incompetence of Walsall Council in relation to urban green space planning policy matters.
• As a key local stakeholder representing thousands of local residents, we therefore have significant concerns that the emerging BCP (Review) (2021) is currently promoting inappropriate, damaging and unsustainable patterns of development within the wider Reedswood and Birchills areas of Walsall by encouraging the wholesale re-development of the last remaining few areas of sensitive urban green space within the Reedswood and Birchills area. We therefore strongly encourage Walsall Council to re-consider its spatial planning policy approach on this issue within the emerging BCP (Review), and remove these sensitive urban green space areas from the proposed 'Core Regeneration Area' designation. Local residents heavily rely on these local urban green space areas for the reasons set out within this Representations Statement.
• ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach being taken by Walsall Council in the relation to the search for new housing and new industrial land sites within the Borough and across the wider Black Country sub-region, within the emerging Black Country Plan (BCP) (Review) (2021). Walsall Council should be aware of the need to promote sustainable patterns of development as this forms the cornerstone of central Government (London) national planning guidance as set out in paragraph 11 of the Revised National Planning Policy Framework (NPPF) (published July 2021).
• When considering ‘Sustainability principles’ as reinforced in paragraphs 7, 8 (indents b and c), 10 and 11 of the Revised NPPF (July 2021), given their high degree of green space planning policy sensitivity, urban green space sites (which provide multiple urban green space benefits as discussed within this Representations Statement document) and Town Parks should be very low down on the list of potential sites. In fact, they should be totally excluded from any site search exercise given their importance to local communities and their high level of urban green space planning policy sensitivity. Other less sensitive site locations should be selected and prioritised first for new development. Walsall Council’s proposed planning policy approach on this issue is both irresponsible, lacks any planning policy credibility and is damaging to the local area.
• This underlines the failings and incompetence of the Council in relation to urban green space planning policy issues.
The urban green space sites that are the subject of this representation statement, have a strong level of planning policy protection within green space and nature conservation focused guidance as set out in Sections 8 (Promoting healthy and safe communities) and 15 (Conserving and enhancing the natural environment) of the Revised NPPF (July 2021). They are also protected by climate change focused guidance as set out in Section 14 of the Revised NPPF (July 2021).
Local Green Space (LGS)
We consider that the Pouk Hill natural green space area (the entire Pouk Hill green space site including its mature and semi-mature woodlands) should be specifically designated as ‘Local Green Space’ (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) (2021), given that the Pouk Hill green space area strongly meets the site-selection and site designation planning policy criteria for Local Green Space (LGS) designation as reinforced within paragraph 102 of central Government (London) national planning guidance set out in the Revised National Planning Policy Framework (NPPF) (published July 2021). For example, guidance in paragraph 102 of the Revised NPPF (July 2021) is perfectly clear that:
“…The Local Green Space designation should only be used where the green space is:
a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
c) local in character and is not an extensive tract of land…”
The evidence is clear, the Pouk Hill urban green space strongly satisfies and performs well against the above Local Green Space (LGS) site-selection and planning policy designation criteria as reinforced in paragraph 102 of the Revised NPPF (2021). On this basis, we maintain our view that there is a robust and credible planning policy case for the Pouk Hill urban green space area (the entire green space site including its woodlands) to be specifically designated as a Local Green Space (LGS) area without delay, and shown as LGS on the main Policies Map of the emerging Black Country Plan (BCP) (Review).
Given that this sensitive urban green space site strongly performs against the Local Green Space (LGS) site-selection and site designation criteria as referred to above, the site in question should also be specifically shown as designated Local Green Space (LGS) on page 499 of the emerging Black Country Plan (Review) (2021) - within the Figure 19: Walsall Spatial Strategy Plan.
• As a key local stakeholder representing thousands of local residents within the wider Reedswood and Birchills areas of Walsall, we consider that designating the Pouk Hill publicly accessible natural green space area as ‘Local Green Space’ (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• It would also help to ensure that an important urban green space area providing multi-functional urban green space benefits to local communities (e.g. air quality enhancement area helping to reduce and mitigate levels of harmful air pollution from the M6 motorway, outdoor recreational green space area, wildlife habitat and important wildlife corridor, landscape enhancement, climate change focused benefits discussed further above) continues to remain protected within the emerging Black Country Plan (BCP) (Review), consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021) discussed below. Walsall Council should be doing a lot more to protect these sensitive multi-functional urban green space areas within the emerging Black Country Plan (Review), not strongly promoting them as potential new housing re-development sites. Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) is damaging the local area.
• Reducing harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) traffic related air pollution and traffic noise impacts from the adjacent M6 motorway network
• The Pouk Hill urban green space area forms a critically important mature woodland urban green lung alongside the M6 motorway network, within very close proximity to Junction 10 of the M6 motorway.
• Vehicular traffic levels at Junction 10 of the M6 motorway (Walsall, West Midlands) have significantly increased over the past 20 years. Vehicle emissions have become the dominant source of air pollution near to this heavily congested section of motorway network, including levels of Nitrogen Dioxide (NO2), fine Particulate Matter (PM2.5), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs) or hydrocarbons (HCs) and nitrogen oxides (NOx).
• Air pollution is anything in the air that could harm people’s health. There are many types, but the main focus are Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) as they are at already very high levels across the United Kingdom (UK) and are extremely harmful to human health.
The increasing severity and duration of traffic congestion has the potential to greatly increase Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) pollution emission levels and to further degrade air quality, particularly near to Junction 10 of the M6 motorway, Walsall. These Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) emissions from huge levels of traffic (at one of the busiest motorway junctions in the whole of Europe) could potentially contribute to increased risks of morbidity and mortality for individuals living near to this busy section of motorway network. As a key local stakeholder, we consider that these key public health issues have been given an insufficient level of planning policy consideration by Walsall Council when considering the re-development of the last remaining few areas of sensitive wooded urban green space buffers left near to Junction 10 of the M6 motorway within the Reedswood area of Walsall. The evidence suggests that the Pouk Hill woodland urban green space lung and the urban green lung located directly opposite on the other side of the M6 motorway network, bordering Churchill Road and the Jane Lane School, should remain strictly protected to safeguard their essential urban green lung public health benefits in helping to clean polluted air from the M6 motorway network, before this heavily polluted air can reach thousands of local residents living within large established residential communities located within the wider Reedswood area.
Air pollution caused mostly by road traffic – is one of the United Kingdom’s (UK’s) biggest killers, and is responsible for 36,000 premature deaths per year across the UK (source: Friends of the Earth (2020)).
Bloxwich Lane (Reedswood, Walsall) located between the M6 motorway network and the western edge of the Pouk Hill urban green space area has been identified as the most heavily polluted street in the Walsall Metropolitan Borough according to Friends of the Earth. Bloxwich Lane had a reading of nitrogen dioxide particles in the air at 41.1 micrograms per cubic metre. It was also the only pollution hotspot located in Walsall. High levels of nitrogen dioxide (NO2) can cause asthma or symptoms like coughing and difficulty breathing to flare up. A main cause of nitrogen dioxide (NO2) pollution is emissions from road traffic (source: Birmingham Mail, March 2019).
The current legal limit for Nitrogen Dioxide (NO2) levels is 40 micrograms per cubic metre. Bloxwich Lane exceeds this legal limit due to its 41.1 micrograms per cubic metre reading.
This matter has not been taken into account, given sufficient material planning weight, and given sufficient planning policy consideration by Walsall Council when actively promoting the disposal of the Pouk Hill critically important urban green space lung (and the urban green space lung located on the opposite side of the M6 motorway network immediately north of Churchill Road and the Jane Lane School) for proposed new build housing or new employment land uses (new industrial units) re-development. By including these critically important ‘urban green lungs’ within a proposed Core Regeneration Area within the emerging Black Country Plan (BCP) (Review) (2021). To perfectly clear, the sole purpose of the Core Regeneration Area designation is to actively promote sites within this designation for new build housing or new employment uses.
This underlines the failure and incompetence of the Council in relation to public health, air quality, and urban green space planning policy issues. More needs to be done to stop Walsall Council from damaging the local area. Walsall Council’s proposed spatial planning policy approach has the potential to cause a future Public Health Emergency.
The Council’s planning policy position on this issue is clearly unsound and conflicts with central Government (London) national planning guidance as set out in paragraph 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 174 (indent e) of the Revised NPPF (2021) confirms that:
“…Planning policies and decisions should contribute to and enhance the natural and local environment by: (indent e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, …”
Junction 10 of the M6 is one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, and will continue to remain so despite the major Junction 10 M6 re-development works with the new fly-over with additional lanes of traffic. The extra road space created by the M6 junction 10 new fly-over with significantly expanded new road space creating additional lanes of traffic, will, in our opinion and the view of many local residents that we have recently consulted, simply place additional levels of vehicular traffic onto the expanded road space, causing increased levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution. The re-development of these critical wooded urban green space green lungs alongside the M6 motorway should therefore be strictly avoided and not encouraged by Walsall Council within the emerging Black Country Plan (BCP) (Review), in order to help avoid a potential future Public Health Emergency.
To encourage the re-development of these sensitive urban green space lungs alongside the M6 would be promoting inappropriate, damaging and unsustainable patterns of development within the Reedswood area contrary to a range of NPPF guidance, and would be placing local residents at increased health risks due to increased exposure to levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) harmful air pollution from vehicular traffic using the congested M6. In particular, it would conflict with guidance in paragraph 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021) as discussed above and would also infringe upon and conflict with the Legal Human Rights of thousands of local residents living within the wider Reedswood area of Walsall to be able to breathe clean air under Article 2 of The Human Rights Act legislation as discussed further below.
As an urban green space lung containing areas of mature and semi-mature broadleaved woodland (originally planted as part of the Black Country Urban Forest initiative – the Council should not be building on these specially planted areas of the Black Country Urban Forest) the Pouk Hill urban green space area therefore helps to mitigate the effects of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of toxic air pollution from vehicular traffic using the adjacent heavily congested M6 motorway network, this urban green space area therefore helps to play a fundamental and critically important public health role, helping to protect the health and well-being of thousands of local residents living within the wider Reedswood area. Including along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive.
Given the above issues and the potentially serious future public health implications being caused by Walsall Council’s proposed spatial planning policy approach being taken within the Figure 19: Walsall Spatial Plan Map on page 499 of the BCP (Review) consultation report (2021), we maintain our view Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 17

that Walsall Council is promoting inappropriate, damaging and unsustainable patterns of development within the local area, which will place existing large residential communities at increased health risks (i.e. increased risk of lung disease as a direct result of a planning policy approach which is actively seeking to promote the future re-development for new housing/ employment land of highly sensitive urban green space lungs bordering the M6 motorway network near to Junction 10) and increased vulnerability to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from the heavily congested M6 motorway network.
More needs to be done to stop Walsall Council from damaging the local area.
Within the emerging Black Country Plan (BCP) (Review) (2021), Walsall Council is forcing through a highly damaging and inflexible spatial planning policy approach within the Reedswood area, which will introduce significant levels of urban green space environmental damage and cause increased future public health risks on local populations by taking away essential wooded urban green space lungs alongside the M6 motorway, at one of its most heavily congested junctions. Walsall Council’s proposed spatial planning policy approach within the Reedswood area of Walsall within the emerging BCP (Review) (2021) has the potential to create a future Public Health Emergency.
Conclusion
As such, we contend that the proposed spatial planning policy approach being taken by Walsall Council within proposed ‘Core Regeneration Area’ designation within the Reedswood area of Walsall, as shown within the Figure 19: Walsall Spatial Plan Map (on page 499 of the BCP (Review) consultation report (2021)), is considered to be insufficiently robust, unsound, unjustified and inconsistent with Government planning guidance as set out in paragraphs 7, 8 (indents b and c), 11 (indent a), 16 (indent a), 31 - 32, 35 (indents a and d), 36, 92 (indent c), 93 (indents a and b), 98, 119, 152 - 153, 154 (indent a), 179, 174 (indents a and e), 183 (indent a), 185 and paragraph 186 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The proposed spatial planning policy approach to actively promote the re-development of Reedswood’s last remaining few sensitive urban green space areas and woodland urban green space lungs (bordering the M6) as potential future development sites for new build housing or new employment land by including all of them directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is also conflicting with the planning policy approach (the BCP Reviews (2021) documents actual own policies) as set out within Black Country Plan (BCP) (Review) (2021). Most notably, emerging policies ENV8 (Open Space, Sport and Recreation) (policy indents b, f, i and ii) (located on pages 246 to 249 of the BCP (Review) (2021) Regulation 18 public consultation report); Policy ENV1 (Nature Conservation) (policy indents d and e) (pages 203 to 204); Policy ENV4 Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 18

(Provision, retention of Trees and Hedgerows) (policy indent 3) (pages 218 to 223); Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) (policy indent 3) (pages 230 to 234); Policy CC4 (Air Quality) (policy indent c) (pages 277 to 279); Policy HW1 (Health and Wellbeing) (pages 74 to 76); Policy CC3 (Managing Heat Risk) (pages 273 to 274). Challenges and issues Section (indents e – climate change and protecting and enhancing the environment and indent h – health and wellbeing) (pages 18 to 19). Table 1 – Black Country Plan – Objectives and Strategic Priorities: Objective: Climate Change – Strategic Priorities 1 and 2; Objective: Improving the Health and Wellbeing of residents – Strategic Priorities 5 and 6; and Objective: Enhancing our natural and built environment – Strategic Priority 11 (located on pages 22 to 23 of the BCP (Review) (2021) Regulation 18 public consultation report).
Article 2 of The Human Rights Act Legislation –- The Right to Life - Placing local communities at increased risk of exposure to harmful levels of air pollution (therefore contravening their Right to Life) by actively encouraging the re-development of a critically important woodland urban green space buffer lung which helps to significantly reduce and mitigate harmful levels of air pollution from the M6 motorway network.
By placing thousands of local residents within the Reedswood area of Walsall at increased risk of lung disease due to exposure to greater levels of harmful air pollution from the M6 motorway network by actively encouraging the re-development of the critically important Pouk Hill urban green space woodland (urban green lung), Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is contravening Article 2 of the Human Rights Act Legislation which protects a person’s right to life.
Article 2 of the Human Rights Act protects your right to life.
This means that nobody, including the Government, can try to end your life. It also means the Government should take appropriate measures to safeguard life by making laws to protect you and, in some circumstances, by taking steps to protect you if your life is at risk.
Public authorities should also consider your right to life when making decisions that might put you in danger or that affect your life expectancy.
The hundreds of local residents living along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) legislation and should therefore be identified (by way of a special designated urban green space lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 19

We demand that this fundamental basic Legal Human Right to ‘be able to breathe Clean Air’ continues to be respected by Walsall Council within the emerging Black Country Plan (Review).
When preparing Local Plan Reviews, the need for Local Planning Authorities to carefully consider and take into account the impacts of future development proposals on air quality and the need to protect local communities from being placed at unacceptable risks from both noise and air pollution is reinforced by guidance in paragraph 174 (indent e) of the Revised NPPF (2021) as discussed further below. Walsall Council’s proposed spatial planning policy approach on this issue within the emerging BCP Review (2021) is conflicting with this Revised NPPF (2021) guidance and clear legislation within the Human Rights Act.
To address these fundamental public health concerns Walsall Council, the urban green lungs located on both sides of the M6 motorway network near Junction 10, including the Pouk Hill wooded urban green space area (the entire Pouk Hill green space site), should be specifically removed from the Core Regeneration Area designation. Walsall Council should stop continuing to actively promote these highly sensitive urban green space areas as potential future new development sites for new housing and/ or new employment land within the emerging BCP (Review). To continue to promote these highly sensitive urban green space lungs as potential development sites is promoting a reckless and irresponsible planning policy approach within the emerging BCP (Review).
These highly sensitive urban green space sites should be specifically designated as an “Air Quality Enhancement Urban Green Lung Area” on the main Policies Map of the emerging BCP (Review) to ensure that their critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future.
These sensitive urban green space areas have significant Public Health benefits to thousands of local residents, helping to reduce local resident’s exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the heavily congested M6 motorway network.
As stated further above, the current legal limit for Nitrogen Dioxide (NO2) levels is 40 micrograms per cubic metre. Bloxwich Lane located alongside Pouk Hill urban green space and closely bordering the M6 motorway, already exceeds this legal limit due to its 41.1 micrograms per cubic metre reading.
These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall). This critically important public health issue affecting the lives of thousands of local residents, should be a key material planning policy Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 20

consideration in the Local Plan spatial planning policy shaping exercise, within the emerging BCP (Review).
Goldfinch Town Planning Services (West Midlands) has 20 years of experience previously spent working within the Black Country sub-region, specialising in dealing with complex and very wide-ranging urban green space planning policy work.
As a specialist urban green space town planning consultancy, Goldfinch Town Planning Services (West Midlands) and our clients the Birchills Agenda 21 Group, are both disappointed and very concerned that Walsall Council has failed to recognise the critically important urban green space public health issues described above within the emerging Black Country Plan (Review) (2021). This underlines the failure and incompetence of the Council in relation to public health matters and planning policy matters relating to Local Plan spatial planning, and the important need to promote environmentally sustainable patterns of development.
Article 1 of The Human Rights Act Legislation –- The Right to enjoy your property peacefully - Placing local communities at increased risk of noise pollution from the heavily congested M6 motorway network by encouraging the re-development of a critically important woodland urban green space buffer which significantly mitigates noise levels from the M6 motorway
Article 1 of the First Protocol: ‘Protection of property’, protects your right to enjoy your property peacefully.
By placing thousands of local residents within the Reedswood area of Walsall at increased risk of traffic noise pollution from the M6 motorway network by encouraging comprehensive and wide-scale re-development of the critically important Pouk Hill urban green space semi-mature and mature woodlands (urban green lung) which help significantly reduce noise pollution levels from the M6 motorway network (this also applies to the urban green lung located on the opposite side of the M6 bordering Churchill Road which has potential to be enhanced with new tree planting to expand tree cover in this area), Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is contravening Article 1 of the Human Rights Act Legislation, which protects a person’s right to the ‘peaceful enjoyment of their property’.
Thousands of local residents living within the wider Reedswood area of Walsall, heavily depend on these critically important urban green lungs and their continued on-going planning policy protection for the reasons explained above.
There is a clear, well evidenced and robust planning policy case therefore for these urban green space areas continued protection within the emerging BCP (Review). Given their critical health and well-being benefits, these sensitive urban green space areas within the vicinity of Junction 10 of the M6 motorway should never be re-developed for the reasons explained above.
Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) to encourage the re-development of these sensitive urban green space areas alongside the M6 is damaging the local area and encouraging unsustainable patterns Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 21

of development, contrary to guidance in paragraph 11 of the Revised NPPF (2021). There is also a strong planning policy conflict with guidance in paragraph 174 (indent e) of the Revised NPPF (2021) on noise and air quality protection planning policy grounds. Walsall Council’s planning policy position on this issue is clearly unsound. More needs to be done to stop Walsall Council from damaging the local area.
We maintain our view that protecting these important urban green space areas will help to ensure that the emerging Black Country Plan (BCP) (Review) (2021) responds effectively to the above Human Rights Act Legislation and national planning guidance as set out in paragraphs 11 and 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 174 (indent e) of the Revised NPPF (2021) is perfectly clear that:
“…Planning policies and decisions should contribute to and enhance the natural and local environment by: (indent e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans…”
Insufficient planning policy consideration and an insufficient level of material planning weight has been given to the ongoing coronavirus pandemic (COVID-19) and the importance of publicly accessible urban green space areas in helping to promote more physically active healthy lifestyles, to help reduce rates of adult obesity to help improve the local communities resilience to current and future global health pandemics
The ongoing years 2020 and 2021 severe global coronavirus (COVID-19) pandemic (which represents one of the worst global health pandemic events to affect the United Kingdom (UK) within the last 100 years) across the UK has highlighted and placed into very sharp focus the increased relevance, importance and health benefits of publicly accessible urban green space areas. Particularly, those urban green space sites which are conveniently located on the doorstep of existing residential communities.
These conveniently located publicly accessible urban green space areas help to make local communities more resilient to current and future global health pandemics (such as the coronavirus pandemic (COVID-19)) due to the considerable physical and mental health well-being benefits of urban green space. Publicly accessible urban green space areas such as the Pouk Hill natural green space area in particular (given that it is situated immediately adjacent to large established residential communities) help to support more physically active healthy lifestyles which helps to make local communities more resilient to global health pandemics. For example, by reducing rates of adult obesity by through encouraging increased rates of physical exercise.
As stated further below, the Walsall Metropolitan Borough has an obesity epidemic with some of the worst health data across the whole UK in relation to adult and Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 22

childhood obesity rates. It is quite concerning and disappointing that Walsall Council does not seem to care about this issue by actively promoting the re-development of all of Reedswood’s last remaining few areas of publicly accessible urban green space within the emerging BCP (Review). Which all play an important contribution towards helping to encourage more physically active healthy lifestyles to help tackle the local obesity epidemic health crisis, which Walsall Council appears to have no interest in resolving.
The planning policy approach to actively encourage the re-development of sensitive urban green space areas across the wider Reedswood area of Walsall underlines the failings and incompetence of Walsall Council in relation to public health matters.
These ‘pandemic related factors’ (i.e. the need to improve the local communities resilience to current and future global health pandemics by pursuing a planning policy approach which helps to reduce rates of adult obesity within the local population) do not appear to have been given any material planning weight or sufficient planning policy consideration whatsoever by Walsall Council within the emerging BCP (Review) when considering the proposed spatial planning policy approach being taken within the wider Reedswood and Birchills areas of Walsall.
By encouraging the wholesale re-development of the last remaining few areas of sensitive urban green space left within the Reedswood area of Walsall by including them directly within a proposed ‘Core Regeneration Area’ designation (to encourage their future re-development for either new build housing or new employment land uses), Walsall Council is promoting inappropriate, damaging and unsustainable patterns of development within the local area, and making local communities less resilient to current and future global health pandemics. Walsall Council’s proposed planning policy approach on this issue is clearly unsound and insufficiently robust.
The Core Regeneration Area designation proposals will have a damaging impact on local resident’s health and well-being for a range of reasons. For example, by substantially eroding a critically important urban green lung (which is of critical importance for improving local air quality) on the edge of the M6 motorway network placing local residents at increased health risks from harmful air pollution from the M6. Including this sensitive urban green space area within a proposed ‘Core Regeneration Area’ designation will also encourage the re-development of this sensitive public open space area which will take away a key local green space recreational resource from local residents. This urban green space area is currently heavily used by local residents for outdoor recreation purposes (i.e. as a place to exercise pet dogs close to home, for walking and as a place to relax and to experience the natural environment within an important wildlife habitat – the importance of protecting such areas is reinforced in Natural England ‘Accessible Natural Green Space’ guidance.
The lessons learned from the 16 months of pro-longed lock-down restrictions across the United Kingdom (UK) due to the severe global coronavirus pandemic (COVID-19) has shown how vitally important publicly accessible natural green space areas are to the health and well-being of local communities, and their importance for making local Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 23

communities more resilient to current and future global health pandemics. It is quite concerning that Walsall Council feels that it is appropriate to actively encourage the re-development of the Pouk Hill urban green space area which provides a critical outdoor green space recreational resource, serving the outdoor recreational needs of thousands of local residents. This proposed Planning Policy approach is damaging the local area and Reedswood’s key last few remaining green space recreational resources.
The coronavirus pandemic (COVID-19) has highlighted the continued relevance of green space to health. These ‘pandemic-related factors’ have been given no consideration or material planning weight whatsoever by Walsall Council in the proposed spatial planning approach being taken within the Reedswood and Birchills areas of Walsall by placing all of Reedswood’s and Birchills last remaining few sensitive urban green space areas within a proposed ‘Core Regeneration Area’ designation. By doing this, this will encourage highly inappropriate green space re-development proposals to come forward. The Council’s proposed spatial planning policy approach on this issue is therefore clearly unsound, insufficiently robust and conflicts with green space focused national planning guidance as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Paragraph 92 (indent c) confirms that:
“…Planning policies and decisions should aim to achieve healthy, inclusive and safe places which: (indent c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure…”
Paragraph 98 is clear that: “…Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities…”
Tackling the Walsall Metropolitan Borough increasing local obesity epidemic
The Walsall Metropolitan Borough has some of the highest levels of childhood and adult obesity rates within the whole of the United Kingdom (UK). There are also large numbers of cases of Type-2 Diabetes and coronary heart disease in the local population. Walsall Council should therefore be taking a more pro-active planning policy approach towards helping to tackle the worsening local obesity epidemic within the Walsall Metropolitan Borough. Encouraging the wholesale redevelopment of all the last remaining urban green space areas within the Reedswood and Birchills areas of Walsall by placing them all within a proposed Core Regeneration Area within the emerging Black Country Plan (Review) (2021), will therefore make the situation a lot worse. Walsall Council should be seeking to conserve and protect Reedswood’s and Birchill’s urban green space areas in order to help promote more physically active healthy lifestyles to try and help tackle the worsening local obesity epidemic. Walsall Council’s proposed planning policy Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 24

approach on this issue is clearly unsound and damaging the health of its local residents, and will make the obesity epidemic a lot worse, and place local residents at increased risk from harmful levels of air pollution from the M6 motorway network, by destroying critically important urban green space lungs alongside the M6 motorway network. Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) has the potential to create a future Public Health Emergency by increasing rates of obesity and exposing local residents at increased risk of air pollution from the M6 motorway network by re-developing the areas urban green lungs.
This is not promoting sustainable patterns of development. Walsall Council’s proposed planning policy approach on this issue is therefore in conflict with guidance in paragraph 11 of the Revised NPPF (2021) which expects Local Planning Authorities to promote more sustainable patterns of development when preparing Local Plan Reviews. It also strongly conflicts with outdoor recreation and green space focused national planning guidance as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021) discussed above.
Former landfill site
Pouk Hill public open space is located on the site of a former landfill. The site has now been reclaimed to form a high quality natural green space area containing areas of mature native tree species deciduous broadleaved woodland planted as part of the Black Country Urban Forest initiative. As discussed above, this provides a critically important urban green space lung. Due to levels of methane gas within the Pouk Hill open space due to its former landfill use, and potentially areas of contaminated waste below ground, the green space does not form a safe site location to re-develop for new housing or new employment land. To highlight the dangers, within recent times a small front porch extension on Birchover Road (immediately bordering Pouk Hill green space) exploded due to the accumulation of significant concentrations of methane gas within a poorly ventilated small indoor space. There could also potentially be areas of contaminated waste deep under the ground within parts of this former landfill site. Re-developing this green space area for new housing or industrial land could therefore release harmful pollutants into the atmosphere placing the health of nearby local residents at increased risk. The site has been sufficiently capped to make it safe and forms an attractive urban green space area, however for the above reasons, this areas re-development should not be encouraged.
Pouk Hill public open space: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive mature woodland urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 25


• in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Pouk Hill public open space area, including its natural green space woodlands.
• • All references to the highly sensitive Pouk Hill public open space area (and its natural green space woodlands) as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 should be given special recognition on the main Policies Map within the emerging BCP (Review).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Protected Public Open Space’ area (see below).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with central Government (London) national planning guidance set out in paragraph 102 of the Revised National Planning Policy Framework (NPPF) (published July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Importance for Nature Conservation (SINC)’. This is considered necessary as the whole green space site warrants SINC designation status given its ecological sensitivity.
• • The entire Pouk Hill public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). The trees are of landscape merit and require special protection. This protection is also
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 26


• necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with advice in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Reedswood Town Park natural green space area, and other ‘stepping-stone’ natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. This ecological network function needs to be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintains their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised NPPF (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of publicly accessible urban green space is protected for the health, wellbeing and outdoor informal recreation benefits of thousands of local residents to enjoy, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, the above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to environmental infrastructure guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, for their climate change mitigation benefits (i.e. their positive contribution towards urban cooling, air quality enhancement and flood risk reduction benefits), and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected - to help support declining and vulnerable populations of wildlife species, critical for supporting biodiversity. The importance of preserving landscape-scale green infrastructure networks is becoming more important in order to allow wildlife species to move between habitats. This is becoming more important as wildlife species are needing to adapt to the changing climate as a result of climate change. Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 27

Guidance in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021) – The importance of protecting wildlife corridors
Guidance in the Revised NPPF (2021) is a key material planning consideration which Local Planning Authorities should very carefully consider and take into account when they are preparing Local Plan Reviews, such as the emerging Black Country Plan Review, in order to ensure that the Local Plan plan-making approach taken is sufficiently robust, and meets Local Plan ‘tests of Soundness’ as reinforced within paragraph 35 of the Revised NPPF (2021).
Guidance in paragraph 179 of the Revised NPPF (July 2021) is a key material planning consideration when considering the proposed spatial planning policy approach being taken by Walsall Council within the Reedswood and Birchill’s areas of Walsall. Paragraph 179 attaches considerable planning policy importance and attaches considerable planning policy weight, on the need for Local Planning Authorities to protect and conserve ‘landscape-scale’ wildlife corridors (green infrastructure resources) within heavily urbanised areas. Given their critically important role in helping to support populations of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). The various urban green space areas referred to in this Representations Statement within the Reedswood and Birchill’s area form critically important natural green space wildlife corridors and natural green space stepping-stone sites, helping to provide important green infrastructure links connecting through the surrounding heavily urbanised area, linking habitats together.
Paragraph 179 of the Revised NPPF (July 2021) states that:
“…To protect and enhance biodiversity and geodiversity, plans should:
a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and
b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity…”
For reasons already stated in this detailed Representations Statement document, both Goldfinch Town Planning Services (West Midlands) (which is a specialist urban green space planning consultancy) and our clients the Birchills Agenda 21 Group have considerable planning policy concerns that the spatial planning policy approach being proposed within the Reedswood and Birchill’s areas of Walsall by Walsall Council will deliver ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 28

Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall.
The Churchill Road urban green space area is critically important for the following reasons:
• • It provides an essential partly wooded urban green lung helping to significantly reduce harmful levels of air pollution: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing pockets of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of harmful air pollution from the M6 motorway network. It therefore helps to play a critical role in helping to protect the health of thousands of local residents living nearby. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• • Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Noise reduction from the M6 motorway: It forms a natural green space partly wooded buffer which helps to protect nearby residential communities, by reducing the levels of constant traffic noise from the M6 motorway network.
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). See further
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 29


• above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.

• • Helping support populations of protected wildlife species by providing an important wildlife habitat: This natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging habitat for different bat species.
• • Important wildlife corridor: This natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to the Pouk Hill natural green space area (located on the opposite side of the M6) and to the Reedswood Town Park natural green space area. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential areas by providing a large natural green space area with areas of mature broadleaved woodland.

Within the emerging Black Country Plan (BCP) (Review) (Autumn 2021) consultation document, Walsall Council are proposing to allocate part of this sensitive urban green space site (bordering Churchill Road) as an area for new-build industrial uses (new employment land). See the blue shading area on page 499 (Figure 19 - Walsall Spatial Strategy Plan) of the BCP (Review) (2021). We specifically object to this employment land allocation as, in our view it will substantially erode this areas urban green lung benefits, reducing its ability to mitigate harmful levels of air pollution Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 30

from the adjacent M6 motorway network. Re-developing this sensitive urban green space lung for either new employment land or new housing will minimise the extent of a key urban green space lung alongside the M6, potentially placing large communities at increased risk from air pollution. Rather than promoting this site as a potential development area, Walsall Council should be promoting large-scale tree planting across this area of urban green space to help maximise and improve its effectiveness at mitigating air pollution from the M6 and to help strengthen its wildlife corridor function.
The local residents living nearby, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act Legislation) and should therefore be identified (through a designated green lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Additional tree planting measures are required within this urban green space area for reasons explained below.
Public open space located North of Churchill Road and the Jane Lane School: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Churchill Road public open space area, including its pockets of natural green space woodlands
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Churchill Road public open space area should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 31


• help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 motorway should be given special recognition and planning policy protection on the main Policies Map within the emerging BCP (Review).
• • New tree planting should be actively encouraged across this wider urban green space site which is currently dominated by areas of open fields. Additional tree planting (using native tree species to help support biodiversity and therefore deliver net gains for biodiversity) is considered necessary to help strengthen this area’s performance and role as an essential urban green lung to help mitigate the effects of high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6. Expanding tree cover across this largely open urban green space area will help to support the health of nearby residential communities and reduce traffic noise from the M6.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically designated as a ‘Protected Public Open Space’ area.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with guidance in paragraph 102 of the Revised NPPF) (July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Local Importance for Nature Conservation (SLINC)’. This is considered necessary as the whole green space site warrants SLINC designation status given its ecological sensitivity.
• • The entire Churchill Road public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). This protection is necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with guidance in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Pouk Hill natural green space on the opposite side of the M6 motorway network and Reedswood Town Park natural green space area. The Churchill Road natural green space area forms part of the ‘stepping-stone’ natural green space network. This ecological network function needs to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 32


• be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of urban green space is protected for the benefit of thousands of local residents to enjoy for outdoor recreation purposes, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected, to help support biodiversity.
Reedswood Town Park public open space, Bentley Lane, Reedswood, Walsall.
The Reedswood Town Park public open space area is critically important for the following reasons:
• • Public open space (POS): As a designated Town Park, it provides a critically important large area of public open space serving the outdoor recreational needs for thousands of local residents, conveniently located on the doorstep of existing large residential communities within the Reedswood and Birchills areas of Walsall. Town Park remain some of the most highly sensitive green space areas within urban areas, and would normally remain strictly protected on planning policy grounds. This area is not being sufficiently protected within the emerging BCP (Review) due to its inclusion within a Core Regeneration Area designation.
• • High levels of Planning Policy sensitivity: Town Parks form some of the most sensitive green space areas within urban areas and should be strictly protected by Local Planning Authorities (LPA).
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 33


• • Reedswood Town Park is vitally important in helping to support the local communities physical and mental health and well-being. These issues have been placed into very sharp focus during the 16 months of pro-longed lock-down restrictions during the ongoing coronavirus pandemic (COVID-19).
• • Historic connections to the local area: The Town Park green space has important historic connections to the local area and has served the local area as a green space recreational resource for a considerable number of years.
• • Multi-functional urban green space benefits: It contains areas for pitch sports (formal recreation) and informal recreation (walking, as a place to escape the stresses of urban life and to relax and experience the natural environment, as a place to meet friends/ social interaction, and as a place to exercise pet dogs close to home).
• • Wildlife habitats: It contains areas of mature broadleaved woodland which provide an important wildlife habitat supporting protected wildlife species (woodland birds, bats, etc).
• • Wildlife corridors: It contributes positively to the ‘landscape-scale’ green infrastructure network, forming part of a critically important wildlife corridor within the wider Reedswood area.
• • Climate change mitigation benefits: Given that it forms a large area of mature urban woodland, it contributes significantly to minimising the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to store carbon and helping to tackle the Urban Heat Island Effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally.

Conclusion – Reedswood Town Park
Given Reedswood Town Parks public open space and natural green space sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from this highly sensitive public open space area within the emerging Black Country Plan (BCP) (Review) (2021).
The position is perfectly clear, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is promoting inappropriate, damaging and unsustainable patterns of development within the wider Reedswood and Birchill’s areas of Walsall.
This proposed spatial planning policy approach lacks any kind of planning policy credibility, and conflicts with all of the key town planning principles of urban green space planning.
The inclusion of a critically important Town Park urban green space area within a proposed Core Regeneration Area designation to actively promote this large Town Park public open space area as a future development site for new build housing or new employment land underlines the failure and incompetence of the Walsall Council in relation to urban green space planning policy issues. Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 34

More should be done to stop Walsall Council from damaging the local area.
Promoting Reedswood Town Park as a potential development site within the emerging BCP (Review) (2021) is considered to be insufficiently robust, unsound, unjustified, lacks any kind of planning policy credibility, and is inconsistent with Government planning guidance as set out in paragraphs 7, 8 (indents b and c), 11 (indent a), 16 (indent a), 31 - 32, 35 (indents a and d), 36, 92 (indents a and c), 93 (indents a and b), 98, 119, 152 - 153, 154 (indent a), 174 (indents a and e), 179, 185 and paragraph 186 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The proposed spatial planning policy approach to actively promote the re-development of Reedswood Town Park sensitive urban green space area as a potential future development site for new build housing or new employment land by including this Town Park directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is also conflicting with the planning policy approach (the BCP Reviews (2021) documents actual own policies) as set out within Black Country Plan (BCP) (Review) (2021). Most notably, emerging policies ENV8 (Open Space, Sport and Recreation) (policy indents b, f, i and ii) (located on pages 246 to 249 of the BCP (Review) (2021) Regulation 18 public consultation report); Policy ENV1 (Nature Conservation) (policy indents d and e) (pages 203 to 204); Policy ENV4 (Provision, retention of Trees and Hedgerows) (policy indent 3) (pages 218 to 223); Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) (policy indent 3) (pages 230 to 234); Policy CC4 (Air Quality) (policy indent c) (pages 277 to 279); Policy HW1 (Health and Wellbeing) (pages 74 to 76); Policy CC3 (Managing Heat Risk) (pages 273 to 274). Challenges and issues Section (indents e – climate change and protecting and enhancing the environment and indent h – health and wellbeing) (pages 18 to 19). Table 1 – Black Country Plan – Objectives and Strategic Priorities: Objective: Climate Change – Strategic Priorities 1 and 2; Objective: Improving the Health and Wellbeing of residents – Strategic Priorities 5 and 6; and Objective: Enhancing our natural and built environment – Strategic Priority 11 (located on pages 22 to 23 of the BCP (Review) (2021) Regulation 18 public consultation report).
More should be done to stop Walsall Council from delivering ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021).
Reedswood Town Park: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas clear and obvious public open space importance, the entire Reedswood Town Park public open space should be removed from the 'Core
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 35


• Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Reedswood Town Park should be designated as protected Parkland public open space on the main Policies Map of the emerging BCP (Review) (2021).
• • Competent Local Planning Authorities should be aware of the importance of town parks to local communities. We have fundamental planning policy concerns that Reedswood Town Park is being actively promoted as a potential new housing or employment land development site within the emerging BCP (Review) (2021). Reedswood Town Park public open space should not be promoted as a potential new housing or new employment land development site within the emerging BCP (Review). Walsall Council should be aware that Town Parks are not appropriate locations for these types of uses given their high level of green space planning policy sensitivity.
• • Reedswood Town Park should be specifically designated as a key “wildlife corridor” on the main Policies Map of the emerging BCP (Review) given that it forms part of the wider ‘landscape-scale’ green infrastructure network connecting to other wildlife habitats.

Former Reedswood Golf Course public open space, Bentley Lane, Reedswood, Walsall.
The Former Reedswood Golf Course public open space area is critically important for the following reasons:
• • Public open space (POS): It provides a critically important large area of relatively undisturbed public open space serving the outdoor informal recreational needs for local residents, conveniently located on the doorstep of existing large residential communities within the Reedswood and Birchills areas of Walsall. This area is not currently being sufficiently protected within the emerging BCP (Review) due to its inclusion within a proposed new housing site allocation (for 95 new build residential dwellings) and due to its inclusion within a proposed Core Regeneration Area designation. It should be removed from these designations given its urban green space importance and sensitivity.
• • The site forms a ‘Greenfield site’. The site does not form an urban brownfield site (previously-developed land). This is supported by defendable, up-to-date and robust photographic evidence within this Representations Statement document, which shows that this urban green space is dominated by semi-mature broadleaved woodland. The site has blended back into the landscape over a long time period and is now greenfield. The site now provides an
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 36


• attractive woodland landscape which is supported by the photographic evidence referred to above.
• • High levels of Planning Policy sensitivity: Urban woodlands form some of the most sensitive green space areas within urban areas and should be strictly protected by Local Planning Authorities (LPA).
• • The Former Reedswood Golf Course is vitally important in helping to support the local communities physical and mental health well-being. These issues have been placed into very sharp focus during the 16 months of pro-longed lock-down restrictions during the ongoing coronavirus pandemic (COVID-19).
• • Multi-functional urban green space benefits: It is dominated by semi-mature broadleaved deciduous woodland which provides multiple urban green space sites, including as a wildlife habitat, area for urban dwellers to experience the natural environment close to home, as an area to promote urban cooling and carbon storage due to its significant tree cover, and as a key landscape-scale wildlife corridor.
• • It introduces a locally rare heavily rural landscape (similar to a country park) within the surrounding heavily urbanised area. In accordance with guidance in paragraph 185 (indent b) of the Revised NPPF (July 2021), this broadleaved woodland area therefore requires special planning policy protection given that it provides a unique tranquil rural landscape. Given the rariety of these types of landscapes within the Reedswood and Birchill’s area this makes this urban green space really important, and worthy of special planning policy protection.
• • Wildlife habitats: It contains areas of semi-mature and mature broadleaved woodland which provide an important wildlife habitat supporting protected wildlife species (woodland birds, bats, etc).
• • Wildlife corridors: It contributes positively to the ‘landscape-scale’ green infrastructure network, forming part of a critically important wildlife corridor connecting into Reedswood Town Park.
• • Climate change mitigation benefits: Given that it forms a large area of semi-mature urban woodland, it contributes significantly to minimising the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to tackle the urban heat island effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally. Trees also have a critically important role in helping to store carbon. Walsall Council should be doing more to tackle the Climate Change Emergency within the Walsall Metropolitan Borough.

Conclusion – Former Reedswood Golf Course
Given this area’s public open space and natural green space sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation and housing site allocation from this highly sensitive natural green space area within the emerging Black Country Plan (BCP) (Review) (2021). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 37

Promoting the development of this sensitive semi-mature woodland as a site for proposed new housing (please refer to photographic evidence within Appendix 1 this Representations Statement document) is promoting ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021).
Re-developing this site for new housing would conflict with the extensive range of NPPF (2021) guidance and emerging BCP Review (2021) policies referred to further above.
Former Reedswood Golf Course: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas clear and obvious public open space importance and natural green space sensitivity, the entire Former Reedswood Golf Course public open space should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).
• • All references to this highly sensitive urban woodland green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • This green space site should be removed from the new housing site allocation as identified on page 510 (Proposed Housing Site Ref: WAH244) of the emerging BCP (Review) (2021). This site is not suitable for new housing development as it forms a very sensitive 'Greenfield' site. The site does not form previously-developed land (urban brownfield land).
• • This urban woodland should be designated as a ‘Site of Importance for Nature Conservation (SINC)’ on the main Policies Map of the emerging BCP (Review).
• • In accordance with guidance in paragraph 185 (indent b) of the Revised NPPF (July 2021), this green space site should be designated as an area for its ‘Green Space Tranquillity’ on the main Policies Map of the emerging BCP (Review). It provides a unique and heavily rural landscape within the surrounding urbanised area. These types of landscapes are very rare locally within the surrounding area and therefore require special planning policy protection.
• • The entire green space site should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging BCP (Review) (2021).
• • The site should be included within Reedswood Town Park boundary and designated as protected Parkland public open space on the main Policies Map of the emerging BCP (Review) (2021).
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 38


• • The Former Reedswood Golf Course site should be specifically designated as a key “wildlife corridor” on the main Policies Map of the emerging BCP (Review) given that it forms part of the wider ‘landscape-scale’ green infrastructure network connecting through Reedswood Town Park to other wildlife habitats.
•

Object

Representation ID: 12766

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall.
Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).

Former Reedswood Golf Course public open space, Bentley Lane, Reedswood, Walsall.
Given this area’s public open space and natural green space sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation and housing site allocation from this highly sensitive natural green space area within the emerging Black Country Plan (BCP) (Review) (2021).

Comment

Representation ID: 12767

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

Summary of key issues:
The Birchills Agenda 21 Group has significant concerns and strongly object to the proposed inclusion of the following urban green space sites within a proposed 'Core Regeneration Area' designation as shown within the Figure 19: ‘Walsall Spatial Strategy Plan’ on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document.
We have concerns in relation to the inclusion of the following public open space sites within the proposed Core Regeneration Area designation:
• • Pouk Hill natural green space area, immediately bordering Pouk Hill Close, located off Bentley Lane, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway network.
• • Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway.
• • Reedswood Town Park public open space.
• • Former Reedswood Golf Course natural green space area.

A large number of sensitive urban green space sites within the Birchills and Reedswood areas of Walsall have been included within this proposed Core Regeneration Area designation within the emerging Black Country Plan (BCP) (Review) (Regulation 18) (2021) public consultation document. To be perfectly clear, by including all of them within a proposed Core Regeneration Area, these highly sensitive urban green space sites are being actively promoted as potential new development sites by Walsall Council for either new build housing or new employment land uses. This aspect is confirmed on the land use key (Core Regeneration Area) of the Figure 19: ‘Walsall Spatial Strategy Plan’.
This proposed spatial planning policy approach will deliver widespread ‘landscape-scale’ ecological habitat damage to the local area, conflicting with central Government (London) national planning guidance as set out in paragraph 179 of Revised National Planning Policy Framework (NPPF) (published July 2021). Paragraph 179 of the Revised NPPF (2021) reinforces the importance of conserving and protecting wildlife corridors and important ecological networks.
It will also conflict with outdoor recreation and green space focused national planning guidance (covering the whole of the United Kingdom) as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021). Paragraph 92 (indent c) confirms that:
“…Planning policies and decisions should aim to achieve healthy, inclusive and safe places which: (indent c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure…”
Paragraph 98 is clear that: “…Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities…”
Walsall Council’s proposed spatial planning policy approach to actively promote the re-development of Reedswood’s and Birchill’s last remaining few sensitive urban green space areas and critically important woodland urban green space lungs alongside the M6 motorway network as potential future development sites for new build housing or new employment land by including all of them directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is promoting inappropriate, damaging and unsustainable patterns of development within the local area.
This proposed planning policy approach is unsound and unreasonable, and we therefore raise strong objections to this proposed spatial planning policy approach being taken within the Walsall Metropolitan Borough within the emerging BCP (Review) (2021).
As a key local stakeholder representing thousands of local residents, the Birchills Agenda 21 Group therefore specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from the above sensitive urban green space sites within the emerging Black Country Plan (BCP) (Review) (2021). All of these sensitive urban green space sites should be given appropriate green space planning policy protection within the emerging BCP (Review).
Both Goldfinch Town Planning Services (West Midlands) and our client Birchills Agenda 21 Group maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach as set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that important areas of urban green space continue to remain protected for the wider benefit of thousands of local residents to enjoy for outdoor recreation purposes, and ensure the protection of important landscape-scale wildlife corridors across Reedswood, consistent with guidance in paragraphs 92 (indent c), 98 and 179 of the Revised NPPF (July 2021).
Pouk Hill public open space, Bentley Lane (located east of the T-junction of Bentley Lane and Birchover Road), Reedswood, Walsall.
The Pouk Hill urban green space area is critically important for the following reasons:
• • It provides an essential woodland urban green lung helping to significantly reduce harmful levels of air pollution from the M6 motorway: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing areas of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of Nitrogen Dioxide (NO2), fine Particulate Matter (PM2.5), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs) or hydrocarbons (HCs) and nitrogen oxides (NOx) harmful toxic air pollution levels from vehicular traffic using the heavily congested nearby M6 motorway network. By helping to filter-out, remove and reduce the above harmful levels of toxic air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a critical role in helping to protect the health of thousands of local residents living within the wider Reedswood area. Including residents living along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive. These local residents have a fundamental Legal Right to be able to breathe clean air under the European Convention on Human Rights (The Human Rights Act) Legislation, which is still in force as legislation despite Britain recently leaving the European Union (EU). By placing local communities within the Reedswood area at increased risk of developing lung disease by exposing them to greater levels of harmful air pollution by actively encouraging the re-development of critically important wooded urban green space lungs alongside Junction 10 of the M6 Motorway network, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is therefore contravening Article 2 of the Human Rights Act Legislation which protects a person’s right to life.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of United Kingdom (UK) wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in
• order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Helps reduce vehicular traffic noise levels from the M6 motorway: It forms a natural green space woodland buffer which helps to protect residential communities in the Reedswood area by reducing the levels of constant traffic noise from the M6 motorway network, which gets worse during rush hour peak commute times and at weekends. Walsall Council’s spatial planning approach within the emerging Black Country Plan (BCP) (Review) is having a harmful impact on the residential amenity of local established residential communities within the Reedswood area by exposing local residents to increased risks of noise pollution from the M6 motorway network by encouraging the re-development of mature woodland buffers alongside the M6. This is contravening our human rights under Article 1 of the First Protocol: ‘Protection of property’ of the Human Rights Act Legislation, which is clear that “every person has a right to the peaceful enjoyment of their property.”
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities within the Reedswood area. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). They are important for helping support physical and mental health well-being benefits. Natural England guidance stresses the importance of protecting these types of publicly accessible natural green space areas located on the doorstep of existing communities.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: The ongoing years 2020 and 2021 severe global coronavirus (COVID-19) pandemic (which represents one of the worst global health pandemic events to affect the United Kingdom (UK) within the last 100 years) has highlighted and placed into very sharp focus the increased relevance, importance and health benefits of conveniently located publicly accessible urban green space areas to local communities, such as the Pouk Hill open space.


• Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.
• • Helping support populations of protected wildlife species by providing an important wildlife habitat worthy of ‘Site of Importance for Nature Conservation’ (SINC) designation: The wider Pouk Hill natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging and roosting habitat for different bat species, which are observed using this green space regularly as a foraging habitat during dusk on warm summer evenings.
• • Important wildlife corridor: The Pouk Hill natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to Reedswood Town Park natural green space area, and other ‘stepping-stone’ natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 179 reinforces the importance of protecting wildlife corridors and important landscape-scale (e.g. serving a large part of the urban area) ecological networks. These areas are also protected in paragraph 174 (indent d) of the Revised NPPF (July 2021).
• • Black Country Urban Forest: The Pouk Hill urban green space forms part of the Black Country Urban Forest. This area of urban green space contained large areas of tree planting has been specifically planted with native broadleaved woodland tree species as part of the original Black Country Urban Forest initiative. This increases this areas sensitivity.
• Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to tackle the urban heat island effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally. The Pouk Hill urban green space site also provides a natural green space basin containing mature trees and dense vegetation. This helps to absorb rainfall during extreme weather pattern events (severe storms) therefore helping to control flash flooding by reducing surface water run-off rates. These weather patterns (higher summer temperatures and severe rainfall events) are increasing in severity due to climate change. The Pouk Hill urban green space therefore helps to make the Reedswood urban area more resilient to future climate change pressures. Rather than ignoring the climate change emergency, Walsall Council should be doing more to tackle the Climate Change
• Emergency within the Walsall Metropolitan Borough. By including all of Reedswood’s last remaining few sensitive urban green space areas within a proposed Core Regeneration Area designation, Walsall Council is damaging the local area by making it less resilient to future climate change pressures. Its proposed planning policy approach on this issue within the emerging Black Country Plan (BCP) (Review) (2021) is therefore considered to be unsound and insufficiently robust, and conflicts with key climate change focused national planning guidance as set out in Section 14 (Meeting the challenge of climate change) of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential communities by providing an area of mature broadleaved woodland, originally planted as part of the Black Country Urban Forest initiative. This natural urban green space area considerably enhances the visual amenity of overlooking established residential occupiers and contributes positively to local landscape character. Walsall Council’s proposed planning policy approach on this issue is introducing widescale landscape damage to the local area by urbanising all of Reedswood’s last remaining urban green space areas.
Core Regeneration Area
The Birchills Agenda 21 Group has significant concerns and strongly object to the inclusion of the Pouk Hill green space within a proposed 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan.
Given this natural green space areas sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from this sensitive public open space area within the emerging Black Country Plan (BCP) (Review) (2021). The position is perfectly clear, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is promoting inappropriate, damaging and unsustainable patterns of development within the Reedswood area of Walsall.
• A large number of sensitive urban green space sites within the Birchills and Reedswood areas of Walsall, including Reedswood Town Park green space, Pouk Hill public open space, and natural green space located immediately north of Churchill Road and the Jane Lane School, have been included within this proposed Core Regeneration Area designation within the emerging Black Country Plan (BCP) (Review) (Regulation 18) (2021) public consultation document. To be perfectly clear, by including all of them within a proposed Core Regeneration Area, these highly sensitive urban green space sites are being actively promoted as potential new development sites by Walsall Council for either new build housing or new employment land uses.
• This proposed planning policy approach is unsound and unreasonable, and we therefore raise strong objections to this proposed spatial planning policy approach within the emerging BCP (Review) (2021). This proposed spatial planning policy approach underlines the failure and incompetence of Walsall Council in relation to urban green space planning policy matters.
• As a key local stakeholder representing thousands of local residents, we therefore have significant concerns that the emerging BCP (Review) (2021) is currently promoting inappropriate, damaging and unsustainable patterns of development within the wider Reedswood and Birchills areas of Walsall by encouraging the wholesale re-development of the last remaining few areas of sensitive urban green space within the Reedswood and Birchills area. We therefore strongly encourage Walsall Council to re-consider its spatial planning policy approach on this issue within the emerging BCP (Review), and remove these sensitive urban green space areas from the proposed 'Core Regeneration Area' designation. Local residents heavily rely on these local urban green space areas for the reasons set out within this Representations Statement.
• ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach being taken by Walsall Council in the relation to the search for new housing and new industrial land sites within the Borough and across the wider Black Country sub-region, within the emerging Black Country Plan (BCP) (Review) (2021). Walsall Council should be aware of the need to promote sustainable patterns of development as this forms the cornerstone of central Government (London) national planning guidance as set out in paragraph 11 of the Revised National Planning Policy Framework (NPPF) (published July 2021).
• When considering ‘Sustainability principles’ as reinforced in paragraphs 7, 8 (indents b and c), 10 and 11 of the Revised NPPF (July 2021), given their high degree of green space planning policy sensitivity, urban green space sites (which provide multiple urban green space benefits as discussed within this Representations Statement document) and Town Parks should be very low down on the list of potential sites. In fact, they should be totally excluded from any site search exercise given their importance to local communities and their high level of urban green space planning policy sensitivity. Other less sensitive site locations should be selected and prioritised first for new development. Walsall Council’s proposed planning policy approach on this issue is both irresponsible, lacks any planning policy credibility and is damaging to the local area.
• This underlines the failings and incompetence of the Council in relation to urban green space planning policy issues.
The urban green space sites that are the subject of this representation statement, have a strong level of planning policy protection within green space and nature conservation focused guidance as set out in Sections 8 (Promoting healthy and safe communities) and 15 (Conserving and enhancing the natural environment) of the Revised NPPF (July 2021). They are also protected by climate change focused guidance as set out in Section 14 of the Revised NPPF (July 2021).
Local Green Space (LGS)
We consider that the Pouk Hill natural green space area (the entire Pouk Hill green space site including its mature and semi-mature woodlands) should be specifically designated as ‘Local Green Space’ (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) (2021), given that the Pouk Hill green space area strongly meets the site-selection and site designation planning policy criteria for Local Green Space (LGS) designation as reinforced within paragraph 102 of central Government (London) national planning guidance set out in the Revised National Planning Policy Framework (NPPF) (published July 2021). For example, guidance in paragraph 102 of the Revised NPPF (July 2021) is perfectly clear that:
“…The Local Green Space designation should only be used where the green space is:
a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
c) local in character and is not an extensive tract of land…”
The evidence is clear, the Pouk Hill urban green space strongly satisfies and performs well against the above Local Green Space (LGS) site-selection and planning policy designation criteria as reinforced in paragraph 102 of the Revised NPPF (2021). On this basis, we maintain our view that there is a robust and credible planning policy case for the Pouk Hill urban green space area (the entire green space site including its woodlands) to be specifically designated as a Local Green Space (LGS) area without delay, and shown as LGS on the main Policies Map of the emerging Black Country Plan (BCP) (Review).
Given that this sensitive urban green space site strongly performs against the Local Green Space (LGS) site-selection and site designation criteria as referred to above, the site in question should also be specifically shown as designated Local Green Space (LGS) on page 499 of the emerging Black Country Plan (Review) (2021) - within the Figure 19: Walsall Spatial Strategy Plan.
• As a key local stakeholder representing thousands of local residents within the wider Reedswood and Birchills areas of Walsall, we consider that designating the Pouk Hill publicly accessible natural green space area as ‘Local Green Space’ (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• It would also help to ensure that an important urban green space area providing multi-functional urban green space benefits to local communities (e.g. air quality enhancement area helping to reduce and mitigate levels of harmful air pollution from the M6 motorway, outdoor recreational green space area, wildlife habitat and important wildlife corridor, landscape enhancement, climate change focused benefits discussed further above) continues to remain protected within the emerging Black Country Plan (BCP) (Review), consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021) discussed below. Walsall Council should be doing a lot more to protect these sensitive multi-functional urban green space areas within the emerging Black Country Plan (Review), not strongly promoting them as potential new housing re-development sites. Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) is damaging the local area.
• Reducing harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) traffic related air pollution and traffic noise impacts from the adjacent M6 motorway network
• The Pouk Hill urban green space area forms a critically important mature woodland urban green lung alongside the M6 motorway network, within very close proximity to Junction 10 of the M6 motorway.
• Vehicular traffic levels at Junction 10 of the M6 motorway (Walsall, West Midlands) have significantly increased over the past 20 years. Vehicle emissions have become the dominant source of air pollution near to this heavily congested section of motorway network, including levels of Nitrogen Dioxide (NO2), fine Particulate Matter (PM2.5), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs) or hydrocarbons (HCs) and nitrogen oxides (NOx).
• Air pollution is anything in the air that could harm people’s health. There are many types, but the main focus are Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) as they are at already very high levels across the United Kingdom (UK) and are extremely harmful to human health.
The increasing severity and duration of traffic congestion has the potential to greatly increase Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) pollution emission levels and to further degrade air quality, particularly near to Junction 10 of the M6 motorway, Walsall. These Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) emissions from huge levels of traffic (at one of the busiest motorway junctions in the whole of Europe) could potentially contribute to increased risks of morbidity and mortality for individuals living near to this busy section of motorway network. As a key local stakeholder, we consider that these key public health issues have been given an insufficient level of planning policy consideration by Walsall Council when considering the re-development of the last remaining few areas of sensitive wooded urban green space buffers left near to Junction 10 of the M6 motorway within the Reedswood area of Walsall. The evidence suggests that the Pouk Hill woodland urban green space lung and the urban green lung located directly opposite on the other side of the M6 motorway network, bordering Churchill Road and the Jane Lane School, should remain strictly protected to safeguard their essential urban green lung public health benefits in helping to clean polluted air from the M6 motorway network, before this heavily polluted air can reach thousands of local residents living within large established residential communities located within the wider Reedswood area.
Air pollution caused mostly by road traffic – is one of the United Kingdom’s (UK’s) biggest killers, and is responsible for 36,000 premature deaths per year across the UK (source: Friends of the Earth (2020)).
Bloxwich Lane (Reedswood, Walsall) located between the M6 motorway network and the western edge of the Pouk Hill urban green space area has been identified as the most heavily polluted street in the Walsall Metropolitan Borough according to Friends of the Earth. Bloxwich Lane had a reading of nitrogen dioxide particles in the air at 41.1 micrograms per cubic metre. It was also the only pollution hotspot located in Walsall. High levels of nitrogen dioxide (NO2) can cause asthma or symptoms like coughing and difficulty breathing to flare up. A main cause of nitrogen dioxide (NO2) pollution is emissions from road traffic (source: Birmingham Mail, March 2019).
The current legal limit for Nitrogen Dioxide (NO2) levels is 40 micrograms per cubic metre. Bloxwich Lane exceeds this legal limit due to its 41.1 micrograms per cubic metre reading.
This matter has not been taken into account, given sufficient material planning weight, and given sufficient planning policy consideration by Walsall Council when actively promoting the disposal of the Pouk Hill critically important urban green space lung (and the urban green space lung located on the opposite side of the M6 motorway network immediately north of Churchill Road and the Jane Lane School) for proposed new build housing or new employment land uses (new industrial units) re-development. By including these critically important ‘urban green lungs’ within a proposed Core Regeneration Area within the emerging Black Country Plan (BCP) (Review) (2021). To perfectly clear, the sole purpose of the Core Regeneration Area designation is to actively promote sites within this designation for new build housing or new employment uses.
This underlines the failure and incompetence of the Council in relation to public health, air quality, and urban green space planning policy issues. More needs to be done to stop Walsall Council from damaging the local area. Walsall Council’s proposed spatial planning policy approach has the potential to cause a future Public Health Emergency.
The Council’s planning policy position on this issue is clearly unsound and conflicts with central Government (London) national planning guidance as set out in paragraph 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 174 (indent e) of the Revised NPPF (2021) confirms that:
“…Planning policies and decisions should contribute to and enhance the natural and local environment by: (indent e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, …”
Junction 10 of the M6 is one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, and will continue to remain so despite the major Junction 10 M6 re-development works with the new fly-over with additional lanes of traffic. The extra road space created by the M6 junction 10 new fly-over with significantly expanded new road space creating additional lanes of traffic, will, in our opinion and the view of many local residents that we have recently consulted, simply place additional levels of vehicular traffic onto the expanded road space, causing increased levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution. The re-development of these critical wooded urban green space green lungs alongside the M6 motorway should therefore be strictly avoided and not encouraged by Walsall Council within the emerging Black Country Plan (BCP) (Review), in order to help avoid a potential future Public Health Emergency.
To encourage the re-development of these sensitive urban green space lungs alongside the M6 would be promoting inappropriate, damaging and unsustainable patterns of development within the Reedswood area contrary to a range of NPPF guidance, and would be placing local residents at increased health risks due to increased exposure to levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) harmful air pollution from vehicular traffic using the congested M6. In particular, it would conflict with guidance in paragraph 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021) as discussed above and would also infringe upon and conflict with the Legal Human Rights of thousands of local residents living within the wider Reedswood area of Walsall to be able to breathe clean air under Article 2 of The Human Rights Act legislation as discussed further below.
As an urban green space lung containing areas of mature and semi-mature broadleaved woodland (originally planted as part of the Black Country Urban Forest initiative – the Council should not be building on these specially planted areas of the Black Country Urban Forest) the Pouk Hill urban green space area therefore helps to mitigate the effects of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of toxic air pollution from vehicular traffic using the adjacent heavily congested M6 motorway network, this urban green space area therefore helps to play a fundamental and critically important public health role, helping to protect the health and well-being of thousands of local residents living within the wider Reedswood area. Including along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive.
Given the above issues and the potentially serious future public health implications being caused by Walsall Council’s proposed spatial planning policy approach being taken within the Figure 19: Walsall Spatial Plan Map on page 499 of the BCP (Review) consultation report (2021), we maintain our view Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 17

that Walsall Council is promoting inappropriate, damaging and unsustainable patterns of development within the local area, which will place existing large residential communities at increased health risks (i.e. increased risk of lung disease as a direct result of a planning policy approach which is actively seeking to promote the future re-development for new housing/ employment land of highly sensitive urban green space lungs bordering the M6 motorway network near to Junction 10) and increased vulnerability to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from the heavily congested M6 motorway network.
More needs to be done to stop Walsall Council from damaging the local area.
Within the emerging Black Country Plan (BCP) (Review) (2021), Walsall Council is forcing through a highly damaging and inflexible spatial planning policy approach within the Reedswood area, which will introduce significant levels of urban green space environmental damage and cause increased future public health risks on local populations by taking away essential wooded urban green space lungs alongside the M6 motorway, at one of its most heavily congested junctions. Walsall Council’s proposed spatial planning policy approach within the Reedswood area of Walsall within the emerging BCP (Review) (2021) has the potential to create a future Public Health Emergency.
Conclusion
As such, we contend that the proposed spatial planning policy approach being taken by Walsall Council within proposed ‘Core Regeneration Area’ designation within the Reedswood area of Walsall, as shown within the Figure 19: Walsall Spatial Plan Map (on page 499 of the BCP (Review) consultation report (2021)), is considered to be insufficiently robust, unsound, unjustified and inconsistent with Government planning guidance as set out in paragraphs 7, 8 (indents b and c), 11 (indent a), 16 (indent a), 31 - 32, 35 (indents a and d), 36, 92 (indent c), 93 (indents a and b), 98, 119, 152 - 153, 154 (indent a), 179, 174 (indents a and e), 183 (indent a), 185 and paragraph 186 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The proposed spatial planning policy approach to actively promote the re-development of Reedswood’s last remaining few sensitive urban green space areas and woodland urban green space lungs (bordering the M6) as potential future development sites for new build housing or new employment land by including all of them directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is also conflicting with the planning policy approach (the BCP Reviews (2021) documents actual own policies) as set out within Black Country Plan (BCP) (Review) (2021). Most notably, emerging policies ENV8 (Open Space, Sport and Recreation) (policy indents b, f, i and ii) (located on pages 246 to 249 of the BCP (Review) (2021) Regulation 18 public consultation report); Policy ENV1 (Nature Conservation) (policy indents d and e) (pages 203 to 204); Policy ENV4 Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 18

(Provision, retention of Trees and Hedgerows) (policy indent 3) (pages 218 to 223); Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) (policy indent 3) (pages 230 to 234); Policy CC4 (Air Quality) (policy indent c) (pages 277 to 279); Policy HW1 (Health and Wellbeing) (pages 74 to 76); Policy CC3 (Managing Heat Risk) (pages 273 to 274). Challenges and issues Section (indents e – climate change and protecting and enhancing the environment and indent h – health and wellbeing) (pages 18 to 19). Table 1 – Black Country Plan – Objectives and Strategic Priorities: Objective: Climate Change – Strategic Priorities 1 and 2; Objective: Improving the Health and Wellbeing of residents – Strategic Priorities 5 and 6; and Objective: Enhancing our natural and built environment – Strategic Priority 11 (located on pages 22 to 23 of the BCP (Review) (2021) Regulation 18 public consultation report).
Article 2 of The Human Rights Act Legislation –- The Right to Life - Placing local communities at increased risk of exposure to harmful levels of air pollution (therefore contravening their Right to Life) by actively encouraging the re-development of a critically important woodland urban green space buffer lung which helps to significantly reduce and mitigate harmful levels of air pollution from the M6 motorway network.
By placing thousands of local residents within the Reedswood area of Walsall at increased risk of lung disease due to exposure to greater levels of harmful air pollution from the M6 motorway network by actively encouraging the re-development of the critically important Pouk Hill urban green space woodland (urban green lung), Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is contravening Article 2 of the Human Rights Act Legislation which protects a person’s right to life.
Article 2 of the Human Rights Act protects your right to life.
This means that nobody, including the Government, can try to end your life. It also means the Government should take appropriate measures to safeguard life by making laws to protect you and, in some circumstances, by taking steps to protect you if your life is at risk.
Public authorities should also consider your right to life when making decisions that might put you in danger or that affect your life expectancy.
The hundreds of local residents living along Pouk Hill Close, Basalt Close, Ragstone Close, Birchover Road, Parkview Crescent and Armstrong Drive, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) legislation and should therefore be identified (by way of a special designated urban green space lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 19

We demand that this fundamental basic Legal Human Right to ‘be able to breathe Clean Air’ continues to be respected by Walsall Council within the emerging Black Country Plan (Review).
When preparing Local Plan Reviews, the need for Local Planning Authorities to carefully consider and take into account the impacts of future development proposals on air quality and the need to protect local communities from being placed at unacceptable risks from both noise and air pollution is reinforced by guidance in paragraph 174 (indent e) of the Revised NPPF (2021) as discussed further below. Walsall Council’s proposed spatial planning policy approach on this issue within the emerging BCP Review (2021) is conflicting with this Revised NPPF (2021) guidance and clear legislation within the Human Rights Act.
To address these fundamental public health concerns Walsall Council, the urban green lungs located on both sides of the M6 motorway network near Junction 10, including the Pouk Hill wooded urban green space area (the entire Pouk Hill green space site), should be specifically removed from the Core Regeneration Area designation. Walsall Council should stop continuing to actively promote these highly sensitive urban green space areas as potential future new development sites for new housing and/ or new employment land within the emerging BCP (Review). To continue to promote these highly sensitive urban green space lungs as potential development sites is promoting a reckless and irresponsible planning policy approach within the emerging BCP (Review).
These highly sensitive urban green space sites should be specifically designated as an “Air Quality Enhancement Urban Green Lung Area” on the main Policies Map of the emerging BCP (Review) to ensure that their critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future.
These sensitive urban green space areas have significant Public Health benefits to thousands of local residents, helping to reduce local resident’s exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the heavily congested M6 motorway network.
As stated further above, the current legal limit for Nitrogen Dioxide (NO2) levels is 40 micrograms per cubic metre. Bloxwich Lane located alongside Pouk Hill urban green space and closely bordering the M6 motorway, already exceeds this legal limit due to its 41.1 micrograms per cubic metre reading.
These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall). This critically important public health issue affecting the lives of thousands of local residents, should be a key material planning policy Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 20

consideration in the Local Plan spatial planning policy shaping exercise, within the emerging BCP (Review).
Goldfinch Town Planning Services (West Midlands) has 20 years of experience previously spent working within the Black Country sub-region, specialising in dealing with complex and very wide-ranging urban green space planning policy work.
As a specialist urban green space town planning consultancy, Goldfinch Town Planning Services (West Midlands) and our clients the Birchills Agenda 21 Group, are both disappointed and very concerned that Walsall Council has failed to recognise the critically important urban green space public health issues described above within the emerging Black Country Plan (Review) (2021). This underlines the failure and incompetence of the Council in relation to public health matters and planning policy matters relating to Local Plan spatial planning, and the important need to promote environmentally sustainable patterns of development.
Article 1 of The Human Rights Act Legislation –- The Right to enjoy your property peacefully - Placing local communities at increased risk of noise pollution from the heavily congested M6 motorway network by encouraging the re-development of a critically important woodland urban green space buffer which significantly mitigates noise levels from the M6 motorway
Article 1 of the First Protocol: ‘Protection of property’, protects your right to enjoy your property peacefully.
By placing thousands of local residents within the Reedswood area of Walsall at increased risk of traffic noise pollution from the M6 motorway network by encouraging comprehensive and wide-scale re-development of the critically important Pouk Hill urban green space semi-mature and mature woodlands (urban green lung) which help significantly reduce noise pollution levels from the M6 motorway network (this also applies to the urban green lung located on the opposite side of the M6 bordering Churchill Road which has potential to be enhanced with new tree planting to expand tree cover in this area), Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is contravening Article 1 of the Human Rights Act Legislation, which protects a person’s right to the ‘peaceful enjoyment of their property’.
Thousands of local residents living within the wider Reedswood area of Walsall, heavily depend on these critically important urban green lungs and their continued on-going planning policy protection for the reasons explained above.
There is a clear, well evidenced and robust planning policy case therefore for these urban green space areas continued protection within the emerging BCP (Review). Given their critical health and well-being benefits, these sensitive urban green space areas within the vicinity of Junction 10 of the M6 motorway should never be re-developed for the reasons explained above.
Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) to encourage the re-development of these sensitive urban green space areas alongside the M6 is damaging the local area and encouraging unsustainable patterns Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 21

of development, contrary to guidance in paragraph 11 of the Revised NPPF (2021). There is also a strong planning policy conflict with guidance in paragraph 174 (indent e) of the Revised NPPF (2021) on noise and air quality protection planning policy grounds. Walsall Council’s planning policy position on this issue is clearly unsound. More needs to be done to stop Walsall Council from damaging the local area.
We maintain our view that protecting these important urban green space areas will help to ensure that the emerging Black Country Plan (BCP) (Review) (2021) responds effectively to the above Human Rights Act Legislation and national planning guidance as set out in paragraphs 11 and 174 (indent e) of the Revised National Planning Policy Framework (NPPF) (July 2021). Paragraph 174 (indent e) of the Revised NPPF (2021) is perfectly clear that:
“…Planning policies and decisions should contribute to and enhance the natural and local environment by: (indent e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans…”
Insufficient planning policy consideration and an insufficient level of material planning weight has been given to the ongoing coronavirus pandemic (COVID-19) and the importance of publicly accessible urban green space areas in helping to promote more physically active healthy lifestyles, to help reduce rates of adult obesity to help improve the local communities resilience to current and future global health pandemics
The ongoing years 2020 and 2021 severe global coronavirus (COVID-19) pandemic (which represents one of the worst global health pandemic events to affect the United Kingdom (UK) within the last 100 years) across the UK has highlighted and placed into very sharp focus the increased relevance, importance and health benefits of publicly accessible urban green space areas. Particularly, those urban green space sites which are conveniently located on the doorstep of existing residential communities.
These conveniently located publicly accessible urban green space areas help to make local communities more resilient to current and future global health pandemics (such as the coronavirus pandemic (COVID-19)) due to the considerable physical and mental health well-being benefits of urban green space. Publicly accessible urban green space areas such as the Pouk Hill natural green space area in particular (given that it is situated immediately adjacent to large established residential communities) help to support more physically active healthy lifestyles which helps to make local communities more resilient to global health pandemics. For example, by reducing rates of adult obesity by through encouraging increased rates of physical exercise.
As stated further below, the Walsall Metropolitan Borough has an obesity epidemic with some of the worst health data across the whole UK in relation to adult and Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 22

childhood obesity rates. It is quite concerning and disappointing that Walsall Council does not seem to care about this issue by actively promoting the re-development of all of Reedswood’s last remaining few areas of publicly accessible urban green space within the emerging BCP (Review). Which all play an important contribution towards helping to encourage more physically active healthy lifestyles to help tackle the local obesity epidemic health crisis, which Walsall Council appears to have no interest in resolving.
The planning policy approach to actively encourage the re-development of sensitive urban green space areas across the wider Reedswood area of Walsall underlines the failings and incompetence of Walsall Council in relation to public health matters.
These ‘pandemic related factors’ (i.e. the need to improve the local communities resilience to current and future global health pandemics by pursuing a planning policy approach which helps to reduce rates of adult obesity within the local population) do not appear to have been given any material planning weight or sufficient planning policy consideration whatsoever by Walsall Council within the emerging BCP (Review) when considering the proposed spatial planning policy approach being taken within the wider Reedswood and Birchills areas of Walsall.
By encouraging the wholesale re-development of the last remaining few areas of sensitive urban green space left within the Reedswood area of Walsall by including them directly within a proposed ‘Core Regeneration Area’ designation (to encourage their future re-development for either new build housing or new employment land uses), Walsall Council is promoting inappropriate, damaging and unsustainable patterns of development within the local area, and making local communities less resilient to current and future global health pandemics. Walsall Council’s proposed planning policy approach on this issue is clearly unsound and insufficiently robust.
The Core Regeneration Area designation proposals will have a damaging impact on local resident’s health and well-being for a range of reasons. For example, by substantially eroding a critically important urban green lung (which is of critical importance for improving local air quality) on the edge of the M6 motorway network placing local residents at increased health risks from harmful air pollution from the M6. Including this sensitive urban green space area within a proposed ‘Core Regeneration Area’ designation will also encourage the re-development of this sensitive public open space area which will take away a key local green space recreational resource from local residents. This urban green space area is currently heavily used by local residents for outdoor recreation purposes (i.e. as a place to exercise pet dogs close to home, for walking and as a place to relax and to experience the natural environment within an important wildlife habitat – the importance of protecting such areas is reinforced in Natural England ‘Accessible Natural Green Space’ guidance.
The lessons learned from the 16 months of pro-longed lock-down restrictions across the United Kingdom (UK) due to the severe global coronavirus pandemic (COVID-19) has shown how vitally important publicly accessible natural green space areas are to the health and well-being of local communities, and their importance for making local Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 23

communities more resilient to current and future global health pandemics. It is quite concerning that Walsall Council feels that it is appropriate to actively encourage the re-development of the Pouk Hill urban green space area which provides a critical outdoor green space recreational resource, serving the outdoor recreational needs of thousands of local residents. This proposed Planning Policy approach is damaging the local area and Reedswood’s key last few remaining green space recreational resources.
The coronavirus pandemic (COVID-19) has highlighted the continued relevance of green space to health. These ‘pandemic-related factors’ have been given no consideration or material planning weight whatsoever by Walsall Council in the proposed spatial planning approach being taken within the Reedswood and Birchills areas of Walsall by placing all of Reedswood’s and Birchills last remaining few sensitive urban green space areas within a proposed ‘Core Regeneration Area’ designation. By doing this, this will encourage highly inappropriate green space re-development proposals to come forward. The Council’s proposed spatial planning policy approach on this issue is therefore clearly unsound, insufficiently robust and conflicts with green space focused national planning guidance as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Paragraph 92 (indent c) confirms that:
“…Planning policies and decisions should aim to achieve healthy, inclusive and safe places which: (indent c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure…”
Paragraph 98 is clear that: “…Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities…”
Tackling the Walsall Metropolitan Borough increasing local obesity epidemic
The Walsall Metropolitan Borough has some of the highest levels of childhood and adult obesity rates within the whole of the United Kingdom (UK). There are also large numbers of cases of Type-2 Diabetes and coronary heart disease in the local population. Walsall Council should therefore be taking a more pro-active planning policy approach towards helping to tackle the worsening local obesity epidemic within the Walsall Metropolitan Borough. Encouraging the wholesale redevelopment of all the last remaining urban green space areas within the Reedswood and Birchills areas of Walsall by placing them all within a proposed Core Regeneration Area within the emerging Black Country Plan (Review) (2021), will therefore make the situation a lot worse. Walsall Council should be seeking to conserve and protect Reedswood’s and Birchill’s urban green space areas in order to help promote more physically active healthy lifestyles to try and help tackle the worsening local obesity epidemic. Walsall Council’s proposed planning policy Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 24

approach on this issue is clearly unsound and damaging the health of its local residents, and will make the obesity epidemic a lot worse, and place local residents at increased risk from harmful levels of air pollution from the M6 motorway network, by destroying critically important urban green space lungs alongside the M6 motorway network. Walsall Council’s proposed spatial planning policy approach within the emerging BCP (Review) has the potential to create a future Public Health Emergency by increasing rates of obesity and exposing local residents at increased risk of air pollution from the M6 motorway network by re-developing the areas urban green lungs.
This is not promoting sustainable patterns of development. Walsall Council’s proposed planning policy approach on this issue is therefore in conflict with guidance in paragraph 11 of the Revised NPPF (2021) which expects Local Planning Authorities to promote more sustainable patterns of development when preparing Local Plan Reviews. It also strongly conflicts with outdoor recreation and green space focused national planning guidance as set out in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021) discussed above.
Former landfill site
Pouk Hill public open space is located on the site of a former landfill. The site has now been reclaimed to form a high quality natural green space area containing areas of mature native tree species deciduous broadleaved woodland planted as part of the Black Country Urban Forest initiative. As discussed above, this provides a critically important urban green space lung. Due to levels of methane gas within the Pouk Hill open space due to its former landfill use, and potentially areas of contaminated waste below ground, the green space does not form a safe site location to re-develop for new housing or new employment land. To highlight the dangers, within recent times a small front porch extension on Birchover Road (immediately bordering Pouk Hill green space) exploded due to the accumulation of significant concentrations of methane gas within a poorly ventilated small indoor space. There could also potentially be areas of contaminated waste deep under the ground within parts of this former landfill site. Re-developing this green space area for new housing or industrial land could therefore release harmful pollutants into the atmosphere placing the health of nearby local residents at increased risk. The site has been sufficiently capped to make it safe and forms an attractive urban green space area, however for the above reasons, this areas re-development should not be encouraged.
Pouk Hill public open space: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive mature woodland urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 25


• in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Pouk Hill public open space area, including its natural green space woodlands.
• • All references to the highly sensitive Pouk Hill public open space area (and its natural green space woodlands) as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 should be given special recognition on the main Policies Map within the emerging BCP (Review).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Protected Public Open Space’ area (see below).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with central Government (London) national planning guidance set out in paragraph 102 of the Revised National Planning Policy Framework (NPPF) (published July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Importance for Nature Conservation (SINC)’. This is considered necessary as the whole green space site warrants SINC designation status given its ecological sensitivity.
• • The entire Pouk Hill public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). The trees are of landscape merit and require special protection. This protection is also
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 26


• necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with advice in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Reedswood Town Park natural green space area, and other ‘stepping-stone’ natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. This ecological network function needs to be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintains their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced within paragraph 35 of the Revised NPPF (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of publicly accessible urban green space is protected for the health, wellbeing and outdoor informal recreation benefits of thousands of local residents to enjoy, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, the above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to environmental infrastructure guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, for their climate change mitigation benefits (i.e. their positive contribution towards urban cooling, air quality enhancement and flood risk reduction benefits), and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected - to help support declining and vulnerable populations of wildlife species, critical for supporting biodiversity. The importance of preserving landscape-scale green infrastructure networks is becoming more important in order to allow wildlife species to move between habitats. This is becoming more important as wildlife species are needing to adapt to the changing climate as a result of climate change. Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 27

Guidance in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021) – The importance of protecting wildlife corridors
Guidance in the Revised NPPF (2021) is a key material planning consideration which Local Planning Authorities should very carefully consider and take into account when they are preparing Local Plan Reviews, such as the emerging Black Country Plan Review, in order to ensure that the Local Plan plan-making approach taken is sufficiently robust, and meets Local Plan ‘tests of Soundness’ as reinforced within paragraph 35 of the Revised NPPF (2021).
Guidance in paragraph 179 of the Revised NPPF (July 2021) is a key material planning consideration when considering the proposed spatial planning policy approach being taken by Walsall Council within the Reedswood and Birchill’s areas of Walsall. Paragraph 179 attaches considerable planning policy importance and attaches considerable planning policy weight, on the need for Local Planning Authorities to protect and conserve ‘landscape-scale’ wildlife corridors (green infrastructure resources) within heavily urbanised areas. Given their critically important role in helping to support populations of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). The various urban green space areas referred to in this Representations Statement within the Reedswood and Birchill’s area form critically important natural green space wildlife corridors and natural green space stepping-stone sites, helping to provide important green infrastructure links connecting through the surrounding heavily urbanised area, linking habitats together.
Paragraph 179 of the Revised NPPF (July 2021) states that:
“…To protect and enhance biodiversity and geodiversity, plans should:
a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and
b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity…”
For reasons already stated in this detailed Representations Statement document, both Goldfinch Town Planning Services (West Midlands) (which is a specialist urban green space planning consultancy) and our clients the Birchills Agenda 21 Group have considerable planning policy concerns that the spatial planning policy approach being proposed within the Reedswood and Birchill’s areas of Walsall by Walsall Council will deliver ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 28

Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall.
The Churchill Road urban green space area is critically important for the following reasons:
• • It provides an essential partly wooded urban green lung helping to significantly reduce harmful levels of air pollution: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing pockets of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of harmful air pollution from the M6 motorway network. It therefore helps to play a critical role in helping to protect the health of thousands of local residents living nearby. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• • Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Noise reduction from the M6 motorway: It forms a natural green space partly wooded buffer which helps to protect nearby residential communities, by reducing the levels of constant traffic noise from the M6 motorway network.
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). See further
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 29


• above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.

• • Helping support populations of protected wildlife species by providing an important wildlife habitat: This natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging habitat for different bat species.
• • Important wildlife corridor: This natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to the Pouk Hill natural green space area (located on the opposite side of the M6) and to the Reedswood Town Park natural green space area. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential areas by providing a large natural green space area with areas of mature broadleaved woodland.

Within the emerging Black Country Plan (BCP) (Review) (Autumn 2021) consultation document, Walsall Council are proposing to allocate part of this sensitive urban green space site (bordering Churchill Road) as an area for new-build industrial uses (new employment land). See the blue shading area on page 499 (Figure 19 - Walsall Spatial Strategy Plan) of the BCP (Review) (2021). We specifically object to this employment land allocation as, in our view it will substantially erode this areas urban green lung benefits, reducing its ability to mitigate harmful levels of air pollution Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 30

from the adjacent M6 motorway network. Re-developing this sensitive urban green space lung for either new employment land or new housing will minimise the extent of a key urban green space lung alongside the M6, potentially placing large communities at increased risk from air pollution. Rather than promoting this site as a potential development area, Walsall Council should be promoting large-scale tree planting across this area of urban green space to help maximise and improve its effectiveness at mitigating air pollution from the M6 and to help strengthen its wildlife corridor function.
The local residents living nearby, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act Legislation) and should therefore be identified (through a designated green lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Additional tree planting measures are required within this urban green space area for reasons explained below.
Public open space located North of Churchill Road and the Jane Lane School: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Churchill Road public open space area, including its pockets of natural green space woodlands
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Churchill Road public open space area should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 31


• help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 motorway should be given special recognition and planning policy protection on the main Policies Map within the emerging BCP (Review).
• • New tree planting should be actively encouraged across this wider urban green space site which is currently dominated by areas of open fields. Additional tree planting (using native tree species to help support biodiversity and therefore deliver net gains for biodiversity) is considered necessary to help strengthen this area’s performance and role as an essential urban green lung to help mitigate the effects of high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6. Expanding tree cover across this largely open urban green space area will help to support the health of nearby residential communities and reduce traffic noise from the M6.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically designated as a ‘Protected Public Open Space’ area.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with guidance in paragraph 102 of the Revised NPPF) (July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Local Importance for Nature Conservation (SLINC)’. This is considered necessary as the whole green space site warrants SLINC designation status given its ecological sensitivity.
• • The entire Churchill Road public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). This protection is necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with guidance in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Pouk Hill natural green space on the opposite side of the M6 motorway network and Reedswood Town Park natural green space area. The Churchill Road natural green space area forms part of the ‘stepping-stone’ natural green space network. This ecological network function needs to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 32


• be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of urban green space is protected for the benefit of thousands of local residents to enjoy for outdoor recreation purposes, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected, to help support biodiversity.
Reedswood Town Park public open space, Bentley Lane, Reedswood, Walsall.
The Reedswood Town Park public open space area is critically important for the following reasons:
• • Public open space (POS): As a designated Town Park, it provides a critically important large area of public open space serving the outdoor recreational needs for thousands of local residents, conveniently located on the doorstep of existing large residential communities within the Reedswood and Birchills areas of Walsall. Town Park remain some of the most highly sensitive green space areas within urban areas, and would normally remain strictly protected on planning policy grounds. This area is not being sufficiently protected within the emerging BCP (Review) due to its inclusion within a Core Regeneration Area designation.
• • High levels of Planning Policy sensitivity: Town Parks form some of the most sensitive green space areas within urban areas and should be strictly protected by Local Planning Authorities (LPA).
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 33


• • Reedswood Town Park is vitally important in helping to support the local communities physical and mental health and well-being. These issues have been placed into very sharp focus during the 16 months of pro-longed lock-down restrictions during the ongoing coronavirus pandemic (COVID-19).
• • Historic connections to the local area: The Town Park green space has important historic connections to the local area and has served the local area as a green space recreational resource for a considerable number of years.
• • Multi-functional urban green space benefits: It contains areas for pitch sports (formal recreation) and informal recreation (walking, as a place to escape the stresses of urban life and to relax and experience the natural environment, as a place to meet friends/ social interaction, and as a place to exercise pet dogs close to home).
• • Wildlife habitats: It contains areas of mature broadleaved woodland which provide an important wildlife habitat supporting protected wildlife species (woodland birds, bats, etc).
• • Wildlife corridors: It contributes positively to the ‘landscape-scale’ green infrastructure network, forming part of a critically important wildlife corridor within the wider Reedswood area.
• • Climate change mitigation benefits: Given that it forms a large area of mature urban woodland, it contributes significantly to minimising the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to store carbon and helping to tackle the Urban Heat Island Effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally.

Conclusion – Reedswood Town Park
Given Reedswood Town Parks public open space and natural green space sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation from this highly sensitive public open space area within the emerging Black Country Plan (BCP) (Review) (2021).
The position is perfectly clear, Walsall Council’s proposed spatial planning policy approach within the emerging Black Country Plan (BCP) (Review) (2021) is promoting inappropriate, damaging and unsustainable patterns of development within the wider Reedswood and Birchill’s areas of Walsall.
This proposed spatial planning policy approach lacks any kind of planning policy credibility, and conflicts with all of the key town planning principles of urban green space planning.
The inclusion of a critically important Town Park urban green space area within a proposed Core Regeneration Area designation to actively promote this large Town Park public open space area as a future development site for new build housing or new employment land underlines the failure and incompetence of the Walsall Council in relation to urban green space planning policy issues. Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 34

More should be done to stop Walsall Council from damaging the local area.
Promoting Reedswood Town Park as a potential development site within the emerging BCP (Review) (2021) is considered to be insufficiently robust, unsound, unjustified, lacks any kind of planning policy credibility, and is inconsistent with Government planning guidance as set out in paragraphs 7, 8 (indents b and c), 11 (indent a), 16 (indent a), 31 - 32, 35 (indents a and d), 36, 92 (indents a and c), 93 (indents a and b), 98, 119, 152 - 153, 154 (indent a), 174 (indents a and e), 179, 185 and paragraph 186 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The proposed spatial planning policy approach to actively promote the re-development of Reedswood Town Park sensitive urban green space area as a potential future development site for new build housing or new employment land by including this Town Park directly within a proposed ‘Core Regeneration Area’ designation within the Figure 19: Walsall Spatial Plan Map (on page 499), is also conflicting with the planning policy approach (the BCP Reviews (2021) documents actual own policies) as set out within Black Country Plan (BCP) (Review) (2021). Most notably, emerging policies ENV8 (Open Space, Sport and Recreation) (policy indents b, f, i and ii) (located on pages 246 to 249 of the BCP (Review) (2021) Regulation 18 public consultation report); Policy ENV1 (Nature Conservation) (policy indents d and e) (pages 203 to 204); Policy ENV4 (Provision, retention of Trees and Hedgerows) (policy indent 3) (pages 218 to 223); Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) (policy indent 3) (pages 230 to 234); Policy CC4 (Air Quality) (policy indent c) (pages 277 to 279); Policy HW1 (Health and Wellbeing) (pages 74 to 76); Policy CC3 (Managing Heat Risk) (pages 273 to 274). Challenges and issues Section (indents e – climate change and protecting and enhancing the environment and indent h – health and wellbeing) (pages 18 to 19). Table 1 – Black Country Plan – Objectives and Strategic Priorities: Objective: Climate Change – Strategic Priorities 1 and 2; Objective: Improving the Health and Wellbeing of residents – Strategic Priorities 5 and 6; and Objective: Enhancing our natural and built environment – Strategic Priority 11 (located on pages 22 to 23 of the BCP (Review) (2021) Regulation 18 public consultation report).
More should be done to stop Walsall Council from delivering ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021).
Reedswood Town Park: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas clear and obvious public open space importance, the entire Reedswood Town Park public open space should be removed from the 'Core
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 35


• Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Reedswood Town Park should be designated as protected Parkland public open space on the main Policies Map of the emerging BCP (Review) (2021).
• • Competent Local Planning Authorities should be aware of the importance of town parks to local communities. We have fundamental planning policy concerns that Reedswood Town Park is being actively promoted as a potential new housing or employment land development site within the emerging BCP (Review) (2021). Reedswood Town Park public open space should not be promoted as a potential new housing or new employment land development site within the emerging BCP (Review). Walsall Council should be aware that Town Parks are not appropriate locations for these types of uses given their high level of green space planning policy sensitivity.
• • Reedswood Town Park should be specifically designated as a key “wildlife corridor” on the main Policies Map of the emerging BCP (Review) given that it forms part of the wider ‘landscape-scale’ green infrastructure network connecting to other wildlife habitats.

Former Reedswood Golf Course public open space, Bentley Lane, Reedswood, Walsall.
The Former Reedswood Golf Course public open space area is critically important for the following reasons:
• • Public open space (POS): It provides a critically important large area of relatively undisturbed public open space serving the outdoor informal recreational needs for local residents, conveniently located on the doorstep of existing large residential communities within the Reedswood and Birchills areas of Walsall. This area is not currently being sufficiently protected within the emerging BCP (Review) due to its inclusion within a proposed new housing site allocation (for 95 new build residential dwellings) and due to its inclusion within a proposed Core Regeneration Area designation. It should be removed from these designations given its urban green space importance and sensitivity.
• • The site forms a ‘Greenfield site’. The site does not form an urban brownfield site (previously-developed land). This is supported by defendable, up-to-date and robust photographic evidence within this Representations Statement document, which shows that this urban green space is dominated by semi-mature broadleaved woodland. The site has blended back into the landscape over a long time period and is now greenfield. The site now provides an
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 36


• attractive woodland landscape which is supported by the photographic evidence referred to above.
• • High levels of Planning Policy sensitivity: Urban woodlands form some of the most sensitive green space areas within urban areas and should be strictly protected by Local Planning Authorities (LPA).
• • The Former Reedswood Golf Course is vitally important in helping to support the local communities physical and mental health well-being. These issues have been placed into very sharp focus during the 16 months of pro-longed lock-down restrictions during the ongoing coronavirus pandemic (COVID-19).
• • Multi-functional urban green space benefits: It is dominated by semi-mature broadleaved deciduous woodland which provides multiple urban green space sites, including as a wildlife habitat, area for urban dwellers to experience the natural environment close to home, as an area to promote urban cooling and carbon storage due to its significant tree cover, and as a key landscape-scale wildlife corridor.
• • It introduces a locally rare heavily rural landscape (similar to a country park) within the surrounding heavily urbanised area. In accordance with guidance in paragraph 185 (indent b) of the Revised NPPF (July 2021), this broadleaved woodland area therefore requires special planning policy protection given that it provides a unique tranquil rural landscape. Given the rariety of these types of landscapes within the Reedswood and Birchill’s area this makes this urban green space really important, and worthy of special planning policy protection.
• • Wildlife habitats: It contains areas of semi-mature and mature broadleaved woodland which provide an important wildlife habitat supporting protected wildlife species (woodland birds, bats, etc).
• • Wildlife corridors: It contributes positively to the ‘landscape-scale’ green infrastructure network, forming part of a critically important wildlife corridor connecting into Reedswood Town Park.
• • Climate change mitigation benefits: Given that it forms a large area of semi-mature urban woodland, it contributes significantly to minimising the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. Woodland green space areas play a key role in helping to tackle the urban heat island effect within heavily urbanised areas by helping to cool areas naturally. Trees release moisture into the atmosphere from their leaves therefore helping to regulate temperatures and cool areas naturally. Trees also have a critically important role in helping to store carbon. Walsall Council should be doing more to tackle the Climate Change Emergency within the Walsall Metropolitan Borough.

Conclusion – Former Reedswood Golf Course
Given this area’s public open space and natural green space sensitivity, we specifically request that Walsall Council removes the ‘Core Regeneration Area’ designation and housing site allocation from this highly sensitive natural green space area within the emerging Black Country Plan (BCP) (Review) (2021). Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 37

Promoting the development of this sensitive semi-mature woodland as a site for proposed new housing (please refer to photographic evidence within Appendix 1 this Representations Statement document) is promoting ‘landscape-scale’ ecological habitat damage to the local area, contrary to guidance in paragraph 179 of the Revised NPPF (2021).
Re-developing this site for new housing would conflict with the extensive range of NPPF (2021) guidance and emerging BCP Review (2021) policies referred to further above.
Former Reedswood Golf Course: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas clear and obvious public open space importance and natural green space sensitivity, the entire Former Reedswood Golf Course public open space should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).
• • All references to this highly sensitive urban woodland green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • This green space site should be removed from the new housing site allocation as identified on page 510 (Proposed Housing Site Ref: WAH244) of the emerging BCP (Review) (2021). This site is not suitable for new housing development as it forms a very sensitive 'Greenfield' site. The site does not form previously-developed land (urban brownfield land).
• • This urban woodland should be designated as a ‘Site of Importance for Nature Conservation (SINC)’ on the main Policies Map of the emerging BCP (Review).
• • In accordance with guidance in paragraph 185 (indent b) of the Revised NPPF (July 2021), this green space site should be designated as an area for its ‘Green Space Tranquillity’ on the main Policies Map of the emerging BCP (Review). It provides a unique and heavily rural landscape within the surrounding urbanised area. These types of landscapes are very rare locally within the surrounding area and therefore require special planning policy protection.
• • The entire green space site should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging BCP (Review) (2021).
• • The site should be included within Reedswood Town Park boundary and designated as protected Parkland public open space on the main Policies Map of the emerging BCP (Review) (2021).
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 38


• • The Former Reedswood Golf Course site should be specifically designated as a key “wildlife corridor” on the main Policies Map of the emerging BCP (Review) given that it forms part of the wider ‘landscape-scale’ green infrastructure network connecting through Reedswood Town Park to other wildlife habitats.
•

Object

Representation ID: 12821

Received: 10/10/2021

Respondent: Birchills Agenda 21 Group

Agent: Goldfinch Town Planning Services (West Midlands)

We have concerns in relation to the inclusion of the following public open space sites within the proposed Core Regeneration Area designation
Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall. Closely bordering Junction 10 of the M6 motorway.

The Churchill Road urban green space area is critically important for the following reasons:
• • It provides an essential partly wooded urban green lung helping to significantly reduce harmful levels of air pollution: It forms an absolutely critical urban green lung alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6. As an urban green space ‘green lung’ containing pockets of mature and semi-mature broadleaved woodland it therefore helps to mitigate the effects of harmful air pollution from the M6 motorway network. It therefore helps to play a critical role in helping to protect the health of thousands of local residents living nearby. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • These critically important urban green space buffers (urban green lungs) located on both sides of the M6 motorway network are critically important to the long-term health and well-being of thousands of local residents. These urban green space lungs are some of the most critically important urban green space lungs within the whole of the West Midlands Region (and potentially of UK wide importance), given the fact that they are located immediately alongside one of the most heavily congested sections of motorway networks within the whole of the United Kingdom, Junction 10 of the M6 (Walsall).
• • Given the above issues, it forms a critically important urban green space area that helps to prevent a future Public Health Emergency, by helping to prevent exposure to polluted air from the M6 motorway. This is considered important in order to help reduce cases of lung disease within nearby heavily populated residential areas by reducing their exposure to high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6.
• • Noise reduction from the M6 motorway: It forms a natural green space partly wooded buffer which helps to protect nearby residential communities, by reducing the levels of constant traffic noise from the M6 motorway network.
• • Public open space (POS): It provides an important public open space (POS) area for thousands of local residents, conveniently located on the doorstep of large residential communities. These Local Green Space (LGS) areas are important for the local communities health and well-being.
• • Natural green space area: It provides a local natural green space area which helps local residents re-connect with the natural environment close-to-home and help escape the stresses of urban life. These natural green space areas located on the doorstep of existing residential communities have become of critical importance during the pro-longed 16 months of lock-down restrictions during the years 2020 and 2021 coronavirus pandemic (Covid-19). See further
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 29


• above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Outdoor recreation benefits: It provides an outdoor informal recreational resource (e.g. for walking, place to exercise pet dogs close to home, place to relax within a natural green space environment). It therefore helps support more physically active healthy lifestyles, important for both physical and mental health well-being.
• • Improving the local communities resilience to current and future global health pandemics: See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Natural green space shortage locally: There is an increasing shortage of these types (local natural green space areas) of publicly accessible natural green space sites within the wider Reedswood area due to built development encroachment pressures affecting other green space areas. This is starting to create an increasing shortage of these types of local natural green space sites.

• • Helping support populations of protected wildlife species by providing an important wildlife habitat: This natural green space site provides an important wildlife habitat for a number of protected wildlife species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging habitat for different bat species.
• • Important wildlife corridor: This natural green space site forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider surrounding heavily urbanised Reedswood area. Providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to the Pouk Hill natural green space area (located on the opposite side of the M6) and to the Reedswood Town Park natural green space area. The importance of protecting such areas is reinforced in paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021).
• • Climate change mitigation role: It helps to minimise the ‘Urban Heat Island Effect’ by helping reduce local air temperatures. See further above comments. This aspect is covered under the Pouk Hill public open space site comments.
• • Landscape enhancement: It enhances the local landscape quality, setting, character and local distinctiveness of nearby residential areas by providing a large natural green space area with areas of mature broadleaved woodland.

Within the emerging Black Country Plan (BCP) (Review) (Autumn 2021) consultation document, Walsall Council are proposing to allocate part of this sensitive urban green space site (bordering Churchill Road) as an area for new-build industrial uses (new employment land). See the blue shading area on page 499 (Figure 19 - Walsall Spatial Strategy Plan) of the BCP (Review) (2021). We specifically object to this employment land allocation as, in our view it will substantially erode this areas urban green lung benefits, reducing its ability to mitigate harmful levels of air pollution Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 30

from the adjacent M6 motorway network. Re-developing this sensitive urban green space lung for either new employment land or new housing will minimise the extent of a key urban green space lung alongside the M6, potentially placing large communities at increased risk from air pollution. Rather than promoting this site as a potential development area, Walsall Council should be promoting large-scale tree planting across this area of urban green space to help maximise and improve its effectiveness at mitigating air pollution from the M6 and to help strengthen its wildlife corridor function.
The local residents living nearby, have a clear, justified, and fundamental Legal right to ‘be able to breathe Clean Air’. This fundamental Legal Right is supported within the European Convention on Human Rights (The Human Rights Act Legislation) and should therefore be identified (through a designated green lung buffer on the BCP (Review) main Policies Map) and fully respected within the emerging Black Country Plan (Review). Additional tree planting measures are required within this urban green space area for reasons explained below.
Public open space located North of Churchill Road and the Jane Lane School: Summary of measures required to overcome our objections:
The following measures are required in order for the Birchills Agenda 21 Group to withdraw their objection:
• • Given this areas very sensitive urban green lung role, critical for helping to prevent a future Public Health Emergency due to its critical role in helping to reduce exposure to harmful levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) highly toxic air pollution from the heavily congested M6 motorway network, the 'Core Regeneration Area' designation (as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document, within the ‘Figure 19: Walsall Spatial Strategy Plan’) should be fully removed from all parts of the Churchill Road public open space area, including its pockets of natural green space woodlands
• • All references to this highly sensitive urban green space area as falling within a proposed ‘Core Regeneration Area’ should be fully deleted from all parts of the emerging Black Country Plan (2021) (Review) (Regulation 18) public consultation document.
• • Given its green space and air pollution mitigation urban green lung benefits, this sensitive urban green lung (critical for helping to prevent a future Public Health Emergency) natural green space area should be removed from the employment land allocation within the emerging BCP (Review) (2021).
• • On the main Policies Map of the emerging Black Country Plan (BCP) (Review), the entire Churchill Road public open space area should be identified and specifically designated as a critically important ‘Air Quality Enhancement Urban Green Lung Area’ bordering the M6 motorway network. This special ‘green lung air quality enhancement designation’ should be clearly shown on the main Polices Map of the emerging Black Country Plan (BCP) (Review) to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 31


• help ensure that its critical role in helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain protected long into the future. This sensitive urban green space area has substantial Public Health benefits.
• • In order to help promote more sustainable patterns of development by conserving critically important areas of urban green space which have a key air pollution reduction role, these important urban green space buffers (urban green lungs helping to mitigate levels of harmful air pollution) on both sides of the M6 motorway should be given special recognition and planning policy protection on the main Policies Map within the emerging BCP (Review).
• • New tree planting should be actively encouraged across this wider urban green space site which is currently dominated by areas of open fields. Additional tree planting (using native tree species to help support biodiversity and therefore deliver net gains for biodiversity) is considered necessary to help strengthen this area’s performance and role as an essential urban green lung to help mitigate the effects of high levels of Nitrogen Dioxide (NO2) and fine Particulate Matter (PM2.5) air pollution from vehicular traffic using the M6. Expanding tree cover across this largely open urban green space area will help to support the health of nearby residential communities and reduce traffic noise from the M6.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically designated as a ‘Protected Public Open Space’ area.
• • On the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area (including its natural green space woodlands) should be specifically designated as a ‘Local Green Space’ (LGS) area in accordance with guidance in paragraph 102 of the Revised NPPF) (July 2021).
• • On the main Policies Map of the emerging BCP (Review), the entire Pouk Hill public open space area (including its natural green space woodlands) should be specifically designated as a ‘Site of Local Importance for Nature Conservation (SLINC)’. This is considered necessary as the whole green space site warrants SLINC designation status given its ecological sensitivity.
• • The entire Churchill Road public open space area should be covered and protected by a ‘blanket Tree Preservation Order (TPO)’ (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021). This protection is necessary to help protect this areas continued urban woodland green lung function.
• • In accordance with guidance in paragraph 179 of the Revised NPPF (July 2021), on the main Policies Map of the emerging BCP (Review), the entire Churchill Road public open space area should be specifically identified as a key wildlife corridor helping to form part of a wider key stepping-stone natural green space area, linking to Pouk Hill natural green space on the opposite side of the M6 motorway network and Reedswood Town Park natural green space area. The Churchill Road natural green space area forms part of the ‘stepping-stone’ natural green space network. This ecological network function needs to
Goldfinch Town Planning Services (West Midlands) October 2021
Representations by Birchills Agenda 21 Group (Walsall) to the emerging Black Country Plan (BCP) (Review) (Regulation 18) Draft Public Consultation Report (August 2021) – Walsall MBC specific representations 32


• be recognised on the main Policies Map of the emerging Black Country Plan (BCP) Review.

Both Goldfinch Town Planning Services (West Midlands) and our client maintain their view that the above measures will help the Black Country Councill’s to deliver a ‘More Effective, Positively Prepared and Justified Plan, consistent with national policy’, in accordance with Local Plan ‘tests of soundness’ as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).
The above measures will also help the Black Country Plan (BCP) (Review) (2021) to promote a more environmentally sustainable pattern of development, consistent with the expected planning policy approach set out in paragraph 11 of the Revised NPPF (July 2021) which reinforces the importance of promoting sustainable development. It will also help to ensure that an important area of urban green space is protected for the benefit of thousands of local residents to enjoy for outdoor recreation purposes, consistent with guidance in paragraphs 92 (indent c) and 98 of the Revised NPPF (July 2021).
Finally, above measures will also help the Black Country Plan (BCP) (Review) (2021) to respond more effectively to guidance in paragraph 179 of the Revised NPPF (July 2021) which expects Local Planning Authorities to identify, conserve and protect ‘landscape-scale’ green infrastructure networks within heavily urbanised areas for the health and well-being benefits of local communities, and to ensure that their function and habitat quality as key wildlife corridors is sufficiently protected, to help support biodiversity.

Comment

Representation ID: 23465

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Dear Sir/Madam

I am writing to you to raise my concerns in relation to the Black Country Plan (Review). In particular, I have concerns that Walsall Council is proposing to include
the Pouk Hill urban green space area within a proposed designated "Core Regeneration Area" within figure 19: Walsall Spatial Plan Map on page 499 of the Black Country Plan (BCP) Regulation 18 public consultation document.

The Pouk Hill open space area forms a very important green space resource which I have used for many years as a place to exercise my dog and as a natural environment urban green area in which to relax. The urban area has increasing shortage of these important open space sites. Walsall Council does not appear to
have any credible evidence to back up and support its planning policy approach for this site. For example, the Council does not have an up to date and robust Green
Infrastructure Study. The Council's position on this issue is not based on credible or accurate information or robust evidence. The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.


On this basis, there is a compelling and robust case to designate the Pouk Hill green space as LGS on the main 'Policies Map' of the emerging Black Country Plan
(Review). This designation should be brought forward as a matter of urgency. I request the urgent removal of the Pouk Hill green space areas from the proposed
Core Regeneration Area'.

This is a signed residents petition by local residents who live on Pouk Hill Close, Reedswood, Walsall. As local residents living within Pouk Hill Close immediately
adjacent to the Pouk Hill natural green space area, we specifically request that:

1) Given its high level of green space sensitivity, the Pouk Hill Close green space site off Bentley Lane, Reedswood, Walsall should be fully removed from the 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan (and other parts of the emerging Black Country Plan which identify this site as a Core Regeneration Area. Within the Figure 19 Plan (Walsall Spatial Strategy Plan) and on the main Policies Map of the emerging Black Country Plan
(BCP) (Review), the entire Pouk Hill green space area should be specifically designated as a 'Protected Public Open Space area' (see below).

Comment

Representation ID: 23468

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.

The Walsall Metropolitan Borough has some of the worst health data within the whole of the United Kingdom. Such as high numbers of childhood and adult obesity cases, a prevalence of Type 2 Diabetes, strokes etc. Walsall Council's planning approach within the Reedswood area of Walsall will make the situation a lot worse.

The situation is concerning and very alarming.

The green space provides an accessible natural green space area located on the doorstep of residential communities within the Reedswood area. It forms a critically important public open space area.

The Coronavirus (Covid-19) global pandemic has shown how important these local nearby natural green space areas are to the health and wellbeing of local communities as they help to support more physically active healthy lifestyles, and tackle the obesity pandemic currently affecting the Walsall area. The Coronavirus
pandemic has highlighted the increased relevance of green space to health.

In my opinion, these "pandemic-related factors" have been given an insufficient level of material planning weight by Walsall Council in its approach to spatial town
planning taken within the wider Reedswood area of Walsall. The Council's position is insufficiently robust and unsound.

5) In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

Comment

Representation ID: 23469

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Paragraph 185 of the Revised NPPF (July 2021) states that planning policies should take into account the likely effects of pollution on health. This is relevant given that
Walsall Council is encouraging the re-development of critically important "urban green space lungs" on the edge of the M6 motorway network. Notably, Pouk Hill
woodland green space and the urban green space bordering Churchill Road.

In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

Comment

Representation ID: 23470

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Dear Sir/Madam

I am writing to you to raise my concerns in relation to the Black Country Plan (Review). In particular, I have concerns that Walsall Council is proposing to include
the Pouk Hill urban green space area within a proposed designated "Core Regeneration Area" within figure 19: Walsall Spatial Plan Map on page 499 of the Black Country Plan (BCP) Regulation 18 public consultation document.

The Pouk Hill open space area forms a very important green space resource which I have used for many years as a place to exercise my dog and as a natural environment urban green area in which to relax. The urban area has increasing shortage of these important open space sites. Walsall Council does not appear to
have any credible evidence to back up and support its planning policy approach for this site. For example, the Council does not have an up to date and robust Green
Infrastructure Study. The Council's position on this issue is not based on credible or accurate information or robust evidence. The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.

The Walsall Metropolitan Borough has some of the worst health data within the whole of the United Kingdom. Such as high numbers of childhood and adult obesity cases, a prevalence of Type 2 Diabetes, strokes etc. Walsall Council's planning approach within the Reedswood area of Walsall will make the situation a lot worse.

The situation is concerning and very alarming. Walsall Council should be doing more to protect the Pouk Hill public open space. This important green space area forms part of an important wildlife corridor, the southern woodland within Pouk Hill space is designated as a 'Site of Importance for Nature Conservation' (SINC) habitat.
The green space provides an accessible natural green space area located on the doorstep of residential communities within the Reedswood area. It forms a critically important public open space area.

The Coronavirus (Covid-19) global pandemic has shown how important these local nearby natural green space areas are to the health and wellbeing of local communities as they help to support more physically active healthy lifestyles, and tackle the obesity pandemic currently affecting the Walsall area. The Coronavirus
pandemic has highlighted the increased relevance of green space to health.

In my opinion, these "pandemic-related factors" have been given an insufficient level of material planning weight by Walsall Council in its approach to spatial town
planning taken within the wider Reedswood area of Walsall. The Council's position is insufficiently robust and unsound.

Given my knowledge of the Pouk Hill green space areas, having lived very near to this site for many years, the green space site clearly meets "Local Green Space"
(LGS) designation criteria as set out in paragraph 102 of Central Government (London) National Planning Guidance in the Revised National Planning Policy
Framework (NPPF) (July 2021). The green space site in question strongly performs against the Local Green Space (LGS) planning policy designation criteria in
paragraph 102.

On this basis, there is a compelling and robust case to designate the Pouk Hill green space as LGS on the main 'Policies Map' of the emerging Black Country Plan
(Review). This designation should be brought forward as a matter of urgency. I request the urgent removal of the Pouk Hill green space areas from the proposed
Core Regeneration Area'.

Please stop Walsall Council from damaging the local area.

Walsall Council's proposed approach being taken within the Black Country Plan (BCP) (Review) conflicts with the following national planning guidance set out in the
Revised National Planning Policy Framework (NPPF) (July 2021) paragraphs 92 (indent C), 98, and paragraph 179. All these parts of the NPPF stress the importance of protecting important urban green space area.

Paragraph 185 of the Revised NPPF (July 2021) states that planning policies should take into account the likely effects of pollution on health. This is relevant given that
Walsall Council is encouraging the re-development of critically important "urban green space lungs" on the edge of the M6 motorway network. Notably, Pouk Hill
woodland green space and the urban green space bordering Churchill Road.

Pouk Hill Close Reeds wood Walsall- Residents Petition in relation to the emerging Black Country Plan (BCP) (Review) (2021) (Regulation 18) public consultation which runs up until 5pm on Monday, 11th October
2021

This is a signed residents petition by local residents who live on Pouk Hill Close, Reedswood, Walsall. As local residents living within Pouk Hill Close immediately
adjacent to the Pouk Hill natural green space area, we specifically request that:

1) Given its high level of green space sensitivity, the Pouk Hill Close green space site off Bentley Lane, Reedswood, Walsall should be fully removed from the 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan (and other parts of the emerging Black Country Plan which identify this site as a Core Regeneration Area. Within the Figure 19 Plan (Walsall Spatial Strategy Plan) and on the main Policies Map of the emerging Black Country Plan
(BCP) (Review), the entire Pouk Hill green space area should be specifically designated as a 'Protected Public Open Space area' (see below).

2) Pouk Hill natural green space area (the entire green space site) should be specifically designated as 'Local Green Space' (LGS) given that the Pouk Hill green space area strongly meets the site-selection and site designation planning policy criteria for Local Green Space (LGS) designation as reinforced within paragraph 102 of central Government (London) national planning
guidance set out in the Revised National Planning Policy Framework (NPPF) (published July 2021). Given that this sensitive green space site strongly performs against the Local Green Space (LGS) site-selection and site
designation criteria as set out in paragraph 102 of the Revised National Planning Policy Framework (NPPF) (July 2021), the Pouk Hill natural green space area should therefore be specifically designated as Local Green Space (LGS) and shown as LGS on the main Policies Map of the emerging Black Country Plan (BCP) (Review) (2021). And also specifically shown as Local
Green Space (LGS) within the Figure 19: Walsall Spatial Strategy Plan, referred to above. As local residents living along Pouk Hill Close, we consider that designating the Pouk Hill publicly accessible natural green space area as
'Local Green Space' (LGS) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council's to deliver a 'More Effective, Positively Prepared and Justified Plan, consistent with national policy', in accordance with Local Plan 'tests of soundness' as reinforced in paragraph 35 of the Revised National Planning Policy Framework (NPPF) (July 2021).

3) The existing 'Site of Importance for Nature Conservation (SINC)' designation within the mature deciduous woodland located within the southern tip of the
Pouk Hill natural green space area (bordering Junction 10 of the M6) should be retained and carried forward within the emerging Black Country Plan (Review) (2021 ). This existing 'Site of Importance for Nature Conservation' (SINC) designation should also be fully extended across
the remainder/ across the entire Pouk Hill natural green space site. This is considered necessary as the whole green space site warrants SINC designation status, given that as residents we have robust, up-to-date and
credible evidence to suggest that the wider Pouk Hill natural green space site provides an habitat for different
important wildlife habitat for a number of protected wildlife
species as identified in the Birmingham and Black Country Biodiversity Action Plan (BAP). Most notably, the green space site provides an important foraging and [Redacted- Sensitive information] for different [Redacted- Sensitive information species. The Pouk Hill natural green space site also forms an integral part of the important 'landscape-scale' green infrastructure connecting network within the wider heavily urbanised
Reedswood area, providing a critically important natural urban green space stepping-stone site (forming part of a critical wildlife corridor) connecting to Reedswood Town Park natural green space area, and other 'stepping-stone'
natural green space areas located on the opposite side of the M6 motorway network, bordering Churchill Road. The importance of protecting 'landscape­ scale green infrastructure' is specifically reinforced within paragraph 179 of the Revised National Planning Policy Framework (NPPF) (July 2021). The wider sites designation as a proposed SINC would therefore have a strong level of planning policy support within paragraph 179 of the Revised NPPF (2021). As local residents living along Pouk Hill Close, we consider that designating the entire Pouk Hill publicly accessible natural green space area
as a 'Site of Importance for Nature Conservation' (SINC) on the main Policies Map of the emerging Black Country Plan (BCP) (Review) as suggested, would help the Black Country Council's to deliver a 'More Effective, Positively
Prepared and Justified Plan, consistent with national policy', in accordance with Local Plan 'tests of soundness' as reinforced in paragraph 35 of the
Revised NPPF (July 2021).

4) The entire Pouk Hill public open space area should be covered by a 'blanket Tree Preservation Order (TPO)' (a blanket TPO) designation within the emerging Black Country Plan (BCP) (Review) (2021) to help protect the green space landscape enhancement benefits of this natural green space area containing areas of native tree species broadleaved woodland, to ensure that this areas wildlife habitats are sufficiently protected, and to help ensure that its key function as a woodland urban green lung helping to reduce harmful levels of air pollution from the adjacent M6 motorway network continues to remain
protected into the future, by receiving the necessary and justified planning policy protection within the emerging Black Country Plan (BCP) (Review).

5) In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

As local residents, we have signed this petition to ensure that the emerging Black Country Plan (BCP) (Review) (2021) takes on board these critically important issues.
The above issues will help to ensure that the emerging BCP (Review) promotes a much more sustainable spatial planning approach, in accordance with Government
guidance set out in paragraph 11 of the Revised NPPF (July 2021).