Draft Black Country Plan

Object

Representation ID: 15696

Received: 11/10/2021

Respondent: Natural England

Natural England objects to the above allocations. The above sites are in close proximity to Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve. Sutton Park is one of the most important wildlife site in West Midlands and is known as the green lung of the Black Country. It is a local destination green space for local people in maintaining their connection to nature thus supporting their mental health and wellbeing. A mosaic of habitats including ancient woodland, heathlands and wetland habitat. The wetlands are natural being ground fed but are affected significantly by sewage
and storm water mixing during high intensity rainfall. The wetland habitats here although severely impacted in areas by water pollution, are exceptionally rare in the Midlands and of better quality than those found at Cannock Chase. The topography of the land means that surface water and surface
water drainage which contains pollutants will flow down into the park area consequently compromising the site. It is imperative that any additional housing does not impact upon the wetland environment.

The following issues would need to be addressed for us to be able to remove our objection:

• Water pollution from foul drainage and surface water drainage

The Sutton Park SSSI is currently suffering from significant damage through urban water pollution (e.g. sewage and storm overflow mix during flooding events). The addition of these sites without proper mitigation will worsen an already dire situation.

• Recreational impacts

The SSSI currently suffers from significant recreational pressure. The increased scale of new housing might reasonably be expected to exert excessive pressure on the SSSI through added recreational visits. We advise the councils within the Black Country to review any existing
visitor surveys and commission a new one as necessary in order to identify if there is a threat to the SSSI. Policy in Black Country Local Plan will need to reflect evidence base/any moves to
better understand the situation e.g. alongside Birmingham City Council.

• Air quality. The site is currently exceeding ammonia, nitrogen deposition and acid deposition levels.

The site is highly urbanised in nature and air quality is already an issue for the site.

However these proposal sites also present an opportunity to maintain the vital wildlife corridor (green infrastructure) that links Barr Beacon Local Nature Reserve and existing surrounding green space. There is good green infrastructure connectivity here for bats along the railway corridor which must be maintained to facilitate bats’ movements across the borough. There are good green infrastructure opportunities to enable the Nature Recovery throughout this area.

Object

Representation ID: 15697

Received: 11/10/2021

Respondent: Natural England

WAH250 (GB1) Star Service Station, Queslett Road East

Natural England objects to the above allocations. The above sites are in close proximity to Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve. Sutton Park is one of the most important wildlife site in West Midlands and is known as the green lung of the Black Country. It is a local destination green space for local people in maintaining their connection to nature thus supporting their mental health and wellbeing. A mosaic of habitats including ancient woodland, heathlands and wetland habitat. The wetlands are natural being ground fed but are affected significantly by sewage
and storm water mixing during high intensity rainfall. The wetland habitats here although severely impacted in areas by water pollution, are exceptionally rare in the Midlands and of better quality than those found at Cannock Chase. The topography of the land means that surface water and surface
water drainage which contains pollutants will flow down into the park area consequently compromising the site. It is imperative that any additional housing does not impact upon the wetland environment.

The following issues would need to be addressed for us to be able to remove our objection:

• Water pollution from foul drainage and surface water drainage

The Sutton Park SSSI is currently suffering from significant damage through urban water pollution (e.g. sewage and storm overflow mix during flooding events). The addition of these sites without proper mitigation will worsen an already dire situation.

• Recreational impacts

The SSSI currently suffers from significant recreational pressure. The increased scale of new housing might reasonably be expected to exert excessive pressure on the SSSI through added recreational visits. We advise the councils within the Black Country to review any existing
visitor surveys and commission a new one as necessary in order to identify if there is a threat to the SSSI. Policy in Black Country Local Plan will need to reflect evidence base/any moves to
better understand the situation e.g. alongside Birmingham City Council.

• Air quality. The site is currently exceeding ammonia, nitrogen deposition and acid deposition levels.

The site is highly urbanised in nature and air quality is already an issue for the site.

However these proposal sites also present an opportunity to maintain the vital wildlife corridor (green infrastructure) that links Barr Beacon Local Nature Reserve and existing surrounding green space. There is good green infrastructure connectivity here for bats along the railway corridor which must be maintained to facilitate bats’ movements across the borough. There are good green infrastructure opportunities to enable the Nature Recovery throughout this area.

Comment

Representation ID: 15698

Received: 11/10/2021

Respondent: Natural England

WAH254 (GB1) Pacific Nurseries, Chester Road, Walsall

Natural England objects to the above allocations. The above sites are in close proximity to Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve. Sutton Park is one of the most important wildlife site in West Midlands and is known as the green lung of the Black Country. It is a local destination green space for local people in maintaining their connection to nature thus supporting their mental health and wellbeing. A mosaic of habitats including ancient woodland, heathlands and wetland habitat. The wetlands are natural being ground fed but are affected significantly by sewage
and storm water mixing during high intensity rainfall. The wetland habitats here although severely impacted in areas by water pollution, are exceptionally rare in the Midlands and of better quality than those found at Cannock Chase. The topography of the land means that surface water and surface
water drainage which contains pollutants will flow down into the park area consequently compromising the site. It is imperative that any additional housing does not impact upon the wetland environment.

The following issues would need to be addressed for us to be able to remove our objection:

• Water pollution from foul drainage and surface water drainage

The Sutton Park SSSI is currently suffering from significant damage through urban water pollution (e.g. sewage and storm overflow mix during flooding events). The addition of these sites without proper mitigation will worsen an already dire situation.

• Recreational impacts

The SSSI currently suffers from significant recreational pressure. The increased scale of new housing might reasonably be expected to exert excessive pressure on the SSSI through added recreational visits. We advise the councils within the Black Country to review any existing
visitor surveys and commission a new one as necessary in order to identify if there is a threat to the SSSI. Policy in Black Country Local Plan will need to reflect evidence base/any moves to
better understand the situation e.g. alongside Birmingham City Council.

• Air quality. The site is currently exceeding ammonia, nitrogen deposition and acid deposition levels.

The site is highly urbanised in nature and air quality is already an issue for the site.

However these proposal sites also present an opportunity to maintain the vital wildlife corridor (green infrastructure) that links Barr Beacon Local Nature Reserve and existing surrounding green space. There is good green infrastructure connectivity here for bats along the railway corridor which must be maintained to facilitate bats’ movements across the borough. There are good green infrastructure opportunities to enable the Nature Recovery throughout this area.

Object

Representation ID: 15699

Received: 11/10/2021

Respondent: Natural England

WAH255 (GB1) Rear of 91 Wood Lane, Streetly

Natural England objects to the above allocations. The above sites are in close proximity to Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve. Sutton Park is one of the most important wildlife site in West Midlands and is known as the green lung of the Black Country. It is a local destination green space for local people in maintaining their connection to nature thus supporting their mental health and wellbeing. A mosaic of habitats including ancient woodland, heathlands and wetland habitat. The wetlands are natural being ground fed but are affected significantly by sewage
and storm water mixing during high intensity rainfall. The wetland habitats here although severely impacted in areas by water pollution, are exceptionally rare in the Midlands and of better quality than those found at Cannock Chase. The topography of the land means that surface water and surface
water drainage which contains pollutants will flow down into the park area consequently compromising the site. It is imperative that any additional housing does not impact upon the wetland environment.

The following issues would need to be addressed for us to be able to remove our objection:

• Water pollution from foul drainage and surface water drainage

The Sutton Park SSSI is currently suffering from significant damage through urban water pollution (e.g. sewage and storm overflow mix during flooding events). The addition of these sites without proper mitigation will worsen an already dire situation.

• Recreational impacts

The SSSI currently suffers from significant recreational pressure. The increased scale of new housing might reasonably be expected to exert excessive pressure on the SSSI through added recreational visits. We advise the councils within the Black Country to review any existing
visitor surveys and commission a new one as necessary in order to identify if there is a threat to the SSSI. Policy in Black Country Local Plan will need to reflect evidence base/any moves to
better understand the situation e.g. alongside Birmingham City Council.

• Air quality. The site is currently exceeding ammonia, nitrogen deposition and acid deposition levels.

The site is highly urbanised in nature and air quality is already an issue for the site.

However these proposal sites also present an opportunity to maintain the vital wildlife corridor (green infrastructure) that links Barr Beacon Local Nature Reserve and existing surrounding green space. There is good green infrastructure connectivity here for bats along the railway corridor which must be maintained to facilitate bats’ movements across the borough. There are good green infrastructure opportunities to enable the Nature Recovery throughout this area.

Object

Representation ID: 16295

Received: 11/10/2021

Respondent: Natural England

Strategic Allocation Policy WSA.2.- WAH238 (GB1) Land at Vicarage Road / Coronation Road, High
Heath and WAH240 (GB1) Land at Mob Lane, High Heath, Pelsall

The above sites are in close proximity to Jockey Fields SSSI. Jockey Fields lie to the north of Walsall on Etruria Marls (Carboniferous) overlain in part by more recent alluvial deposits. The site consists of a number of low-lying fields in a stream valley. Variation in wetness and management have produced a range of vegetation types including well-grazed damp pasture extensively grazed grasslands and fen and mire, all very unusual in the urban context of the West Midlands. Running through the site are a network of well-vegetated ditches that add to the interest of the area. The site is also important for a variety of bird species. Locally significant numbers of Grey heron use the site as a feeding ground and significant numbers of Snipe (in excess of 80) have been recorded. The variety of habitats found at Jockey Fields, together with its large size, the number of plant species rare in the West Midlands, and the bird interest make it a very significant site in the county.

We have significant concerns about the above allocations impact on the SSSI alone and cumulatively, particularly in regard to the following issues:

• Water pollution from foul drainage and surface water drainage
• Cumulative recreational impacts. Increased visitors and dog walking.

Alternative green space for dog walking will be required. Natural England would welcome further dialogue focused on a strategic ‘call for sites’ for new and improved informal recreation spaces in the plan area. Such sites offer scope to integrate heathland recreation alongside other species rich habitat mosaics, all of which can be accessed and enjoyed by local communities through cycling and walking corridors. The emerging Green Infrastructure Standards are relevant here.

• Air quality. The site is currently exceeding nitrogen deposition levels.

Comment

Representation ID: 16296

Received: 11/10/2021

Respondent: Natural England

WAH240 (GB1) Land at Mob Lane, High Heath, Pelsall


The above sites are in close proximity to Jockey Fields SSSI. Jockey Fields lie to the north of Walsall on Etruria Marls (Carboniferous) overlain in part by more recent alluvial deposits. The site consists of a number of low-lying fields in a stream valley. Variation in wetness and management have produced a range of vegetation types including well-grazed damp pasture extensively grazed grasslands and fen and mire, all very unusual in the urban context of the West Midlands. Running through the site are a network of well-vegetated ditches that add to the interest of the area. The site is also important for a variety of bird species. Locally significant numbers of Grey heron use the site as a feeding ground and significant numbers of Snipe (in excess of 80) have been recorded. The variety of habitats found at Jockey Fields, together with its large size, the number of plant species rare in the West Midlands, and the bird interest make it a very significant site in the county.

We have significant concerns about the above allocations impact on the SSSI alone and cumulatively, particularly in regard to the following issues:

• Water pollution from foul drainage and surface water drainage
• Cumulative recreational impacts. Increased visitors and dog walking.

Alternative green space for dog walking will be required. Natural England would welcome further dialogue focused on a strategic ‘call for sites’ for new and improved informal recreation spaces in the plan area. Such sites offer scope to integrate heathland recreation alongside other species rich habitat mosaics, all of which can be accessed and enjoyed by local communities through cycling and walking corridors. The emerging Green Infrastructure Standards are relevant here.

• Air quality. The site is currently exceeding nitrogen deposition levels.

Object

Representation ID: 16301

Received: 11/10/2021

Respondent: Natural England

WAH256 (GB1) Land to the rear of 114-130 Green Lane, Shelfield

The above sites are in close proximity to Jockey Fields SSSI. Jockey Fields lie to the north of Walsall on Etruria Marls (Carboniferous) overlain in part by more recent alluvial deposits. The site consists of a number of low-lying fields in a stream valley. Variation in wetness and management have produced a range of vegetation types including well-grazed damp pasture extensively grazed grasslands and fen and mire, all very unusual in the urban context of the West Midlands. Running through the site are a network of well-vegetated ditches that add to the interest of the area. The site is also important for a variety of bird species. Locally significant numbers of Grey heron use the site as a feeding ground and significant numbers of Snipe (in excess of 80) have been recorded. The variety of habitats found at Jockey Fields, together with its large size, the number of plant species rare in the West Midlands, and the bird interest make it a very significant site in the county.

We have significant concerns about the above allocations impact on the SSSI alone and cumulatively, particularly in regard to the following issues:

• Water pollution from foul drainage and surface water drainage
• Cumulative recreational impacts. Increased visitors and dog walking.

Alternative green space for dog walking will be required. Natural England would welcome further dialogue focused on a strategic ‘call for sites’ for new and improved informal recreation spaces in the plan area. Such sites offer scope to integrate heathland recreation alongside other species rich habitat mosaics, all of which can be accessed and enjoyed by local communities through cycling and walking corridors. The emerging Green Infrastructure Standards are relevant here.

• Air quality. The site is currently exceeding nitrogen deposition levels.

Object

Representation ID: 16302

Received: 11/10/2021

Respondent: Natural England

WAH144 & WAH147 Former Select Windows, Walsall Road, Walsall Wood, Motor City, 117b Walsall Road, Walsall Wood, Former Autocraft, Walsall Road, Walsall Wood, Jubilee House, Walsall Road, Walsall Wood.

The above sites are in close proximity to Jockey Fields SSSI. Jockey Fields lie to the north of Walsall on Etruria Marls (Carboniferous) overlain in part by more recent alluvial deposits. The site consists of a number of low-lying fields in a stream valley. Variation in wetness and management have produced a range of vegetation types including well-grazed damp pasture extensively grazed grasslands and fen and mire, all very unusual in the urban context of the West Midlands. Running through the site are a network of well-vegetated ditches that add to the interest of the area. The site is also important for a variety of bird species. Locally significant numbers of Grey heron use the site as a feeding ground and significant numbers of Snipe (in excess of 80) have been recorded. The variety of habitats found at Jockey Fields, together with its large size, the number of plant species rare in the West Midlands, and the bird interest make it a very significant site in the county.

We have significant concerns about the above allocations impact on the SSSI alone and cumulatively, particularly in regard to the following issues:

• Water pollution from foul drainage and surface water drainage
• Cumulative recreational impacts. Increased visitors and dog walking.

Alternative green space for dog walking will be required. Natural England would welcome further dialogue focused on a strategic ‘call for sites’ for new and improved informal recreation spaces in the plan area. Such sites offer scope to integrate heathland recreation alongside other species rich habitat mosaics, all of which can be accessed and enjoyed by local communities through cycling and walking corridors. The emerging Green Infrastructure Standards are relevant here.

• Air quality. The site is currently exceeding nitrogen deposition levels.

Object

Representation ID: 16305

Received: 11/10/2021

Respondent: Natural England

WAH169 Land off Coronation Road. (We note that the WAH144, 147 & WAH169 are on the allocations map but not within the Plan document.)

The above sites are in close proximity to Jockey Fields SSSI. Jockey Fields lie to the north of Walsall on Etruria Marls (Carboniferous) overlain in part by more recent alluvial deposits. The site consists of a number of low-lying fields in a stream valley. Variation in wetness and management have produced a range of vegetation types including well-grazed damp pasture extensively grazed grasslands and fen and mire, all very unusual in the urban context of the West Midlands. Running through the site are a network of well-vegetated ditches that add to the interest of the area. The site is also important for a variety of bird species. Locally significant numbers of Grey heron use the site as a feeding ground and significant numbers of Snipe (in excess of 80) have been recorded. The variety of habitats found at Jockey Fields, together with its large size, the number of plant species rare in the West Midlands, and the bird interest make it a very significant site in the county.

We have significant concerns about the above allocations impact on the SSSI alone and cumulatively, particularly in regard to the following issues:

• Water pollution from foul drainage and surface water drainage
• Cumulative recreational impacts. Increased visitors and dog walking.

Alternative green space for dog walking will be required. Natural England would welcome further dialogue focused on a strategic ‘call for sites’ for new and improved informal recreation spaces in the plan area. Such sites offer scope to integrate heathland recreation alongside other species rich habitat mosaics, all of which can be accessed and enjoyed by local communities through cycling and walking corridors. The emerging Green Infrastructure Standards are relevant here.

• Air quality. The site is currently exceeding nitrogen deposition levels.

Comment

Representation ID: 16318

Received: 11/10/2021

Respondent: Natural England

WAH235, These site allocations are in close proximity to
Shire Oak Local Nature Reserve (LNR) (GB1)

Natural England is concerned about the added recreational pressure upon the biodiversity value of Shire Oak LNR that these additional housing allocations will bring without additional new biodiversity rich green space being created in this area that can support a greater carrying capacity of people. Natural England also encourages the Black Country Local Planning Authority’s via their Local Nature Recovery Strategy (LNRS) to actively develop cross border cooperation between other Local Planning Authorities (LPA) (for example Lichfield District Council) in coordinating land development projects that impact on local biodiversity sites to ensure that local biodiversity corridors are maintained and link up other local important sites for nature conservation, e.g. Clayhanger Common. An example of this approach relates to land that envelopes WAH235, WAH237 but is in fact in both Lichfield and Walsall. This land area has been identified though Natural Capital Mapping (reference Midlands Heathland Heartland as a bottle-neck constraining existing local nature recovery networks to flow, connect and
link across the wider geographical area. Purple Horizons Nature Recovery Project and Midlands Heathland Heartland (see Annex 1 for further information) has identified significant investment opportunities that will ensure that species and habitats can continue to move freely.