Draft Black Country Plan

Object

Representation ID: 14777

Received: 11/10/2021

Respondent: Finchfield and Castlecroft Community Association

I write as Chairman of the Finchfield and Castlecroft Community Association, which represents hundreds of residents in these areas of Wolverhampton. My comments reflect the views of the committee and the great majority of residents in Finchfield and Castlecroft.

Our objection to the draft Black Country Plan specifically relates to site WOH274, the former Wolverhampton Environment Centre on Westacre Crescent in Finchfield, where it is proposed to build 14 properties. The community association, and hundreds of local residents as well as the local councillors, object to this proposal in the strongest possible terms.

The site sits at the heart of the Smestow Valley Nature Reserve, and is currently green open space that is enjoyed by many people, some of whom travel a considerable distance just to enjoy the nature and the beauty of the land. The value of having this green open space was particularly felt during the recent pandemic, when getting out and enjoying nature was one of the few pleasures that people could take part in when large parts of the country were closed.

The community association has previously held meetings with council officers to discuss their plans to build on the site. We note that the council's planning permission lapsed earlier this year without any development taking place. We would argue that the council is fully aware of local opposition to their proposals, and they had the chance to build on the land but didn't. They should not be given a second chance.

We work closely with the 'Friends of the WEC' group, a social media forum which currently has over 1,000 members, to oppose any development on the site and instead to preserve it for the local community to enjoy. The site is a hotbed of nature and wild animals, and any housing on the land could only be of detrimental effect to them. The land also absords water from the nearby Smestow Brook when that overflows, acting as a shallow wetland which benefits the environment and nature. If houses were built on the land, this would cause drainage problems and the overspill would have to go elsewhere.

The site is also specifically protected in the Tettenhall Neighbourhood Plan (Policy TNP6) where it states the land is designated as agricultural and the preferred option is to retain the land for community use. The Neighbourhood Plan also states that the site should be fully integrated into the Nature Reserve, and indeed designated as a SINC. Wolverhampton Council have disregarded the Neighbourhood Plan when drawing up their proposals to build on the site.

As part of the development of the Tettenhall Neighbourhood Plan, a public survey was conducted in which 78% of respondents objected to any housing development on the site. This further strengthens our objections on behalf of the local community.

To conclude, as a Community Association representing hundreds of local residents in Finchfield and Castlecroft, who would be greatly affected by development of the former WEC site, we object to the inclusion of this site in the Black Country Plan and request that it is removed. It is our strong belief that Wolverhampton Council can find more appropriate space elsewhere in the city for 14 properties to be built, including via increasing numbers at existing brownfield sites where development is planned.

Object

Representation ID: 44861

Received: 11/10/2021

Respondent: Finchfield and Castlecroft Community Association

Objection to Site Allocation WHO 274 WTNA
(page 608 of Draft Black Country Plan)

Finchfield Waterside Care (Keep Britain Tidy) is a group of local volunteers that looks after Finchfield Brook and its environs where it flows through the Smestow Valley Local Nature Reserve (LNR)

We believe it is a serious mistake to include the former Wolverhampton Environment Centre (the WEC) in the Black Country Plan. Residential or commercial development on the WEC will have a deleterious effect on the wildlife and people who use the Local Nature Reserve.

Houses bring traffic. [CC4 - Air Quality page 277]
- Traffic pollutes the air. [HW1 p.74…… BCP aims to ‘create an environment that protects and improves the physical, social and mental health and wellbeing of its residents, employees and visitors and reduces health inequalities’] The proposed houses on the WEC will be
occupied 24/7. At the moment we volunteers leave our cars at [redacted]. We walk to the Brook and enjoy exercise in fresh air.

- Traffic harms wildlife and people. [ENV1 - Nature Conservation, p201……’ development is not permitted where it would harm nationally (Sites of Special Scientific Interest and National Nature Reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites’ ] To get to the WECs traffic will enter the Local Nature Reserve, it will cross a greenway.

[Protected Species] inhabit the wetlands around the WEC. Crushed bodies, ‘road kill’, should not be a feature of a nature reserve. [ENV1 d) ‘the movement of wildlife within the Black Country and its adjoining areas, through both linear habitats (e.g. wildlife corridors) and the wider urban matrix (e.g. stepping-stone sites) is not impeded by development’]

Houses and traffic pollute water courses. [CC6 – Sustainable Drainage and Surface Water Management p.288]
- Since October 2018 Waterside Care has reported to the Environment Agency seventeen cases of pollution in the Brook. Most of the causes of pollution are household effluence but one case involved the dumping of engine oil in the water. The Brook flows into the canal and the Smestow Brook and then the Stour. [Protected species] are returning to Staffs-Worcester Canal. The BBC Wildlife Trust is promoting ‘Salmon in the Stour’, a campaign for clean water. Housing on the WEC will not help the aim of Waterside Care to create a healthy stream for the benefit of people and wildlife.

Housing will contribute to flooding. [CC5 – Flood Risk p. 282] Houses, access roads, and hard driveways prevent rain water from seeping into the soil to replenish aquifers. The water will instead be directed into drains which flow into the Finchfield Brook.

- Flood-water from the Brook regularly makes the public footpath to Wightwick Mill Lock impassable after heavy rain. Each month Waterside Care volunteers dredge silt from the Brook to alleviate flooding. Fourteen houses in the catchment area of the Brook will add to the problem of flooding.

- The 0.45 ha site in the WEC allocated in the BCP for 14 houses is developing into a shallow wetland. This wetland will absorb water that would otherwise find its way into the Brook.

- The developing wetland will provide an aqua habitat, of which there are too few in the LNR

- The developing wetland will extend the area suitable for the endangered species, the existing [protected species]

Houses and traffic bring……
- Lights and noise pollution to disturb the foraging and breeding habits of wildlife.
- Domestic cats, deadly for birds and small mammals
- Litter. Waterside Care is justly proud of its success in clearing litter from the Railway Walk, Turner’s Field and Finchfield Brook every month. Each year we prevent several kilos of plastic, foil and cans from entering the canal and the Smestow Brook.

The WEC is in the Green Belt. It is in the Local Nature Reserve. It is a place of peace and tranquillity.
- We, volunteers with Waterside Care, appreciate the benefits that the Smestow Valley Local Nature Reserve has brought to us, especially during the recent pandemic. Houses on the WEC will undermine values underpinning care for the environment, values which are essential to combating climate change.

Creating a stronger, prosperous and sustainable Black Country
Waterside Care spreads the message of ‘Care for the Environment’
- To allow houses to be built on the WEC, in the Green Belt in the middle of the city’s only Local Nature Reserve will send a contrary message that Wolverhampton does not care for the challenge of climate change nor for the natural environment which will help to meet that challenge.

Therefore we, the undersigned volunteers with Waterside Care, strongly oppose the inclusion of any part of the Wolverhampton Environment Centre as a site for potential development in the Black Country Plan.