Draft Black Country Plan

Comment

Representation ID: 16319

Received: 11/10/2021

Respondent: Natural England

WAH237, 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.

Comment

Representation ID: 16320

Received: 11/10/2021

Respondent: Natural England

WAH248, 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.

Comment

Representation ID: 16321

Received: 11/10/2021

Respondent: Natural England

WAH253, 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.

Comment

Representation ID: 16322

Received: 11/10/2021

Respondent: Natural England

WAH235, WAH237, WAH248, WAH253, plus MIN3: 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.

Comment

Representation ID: 16323

Received: 11/10/2021

Respondent: Natural England

Strategic Allocation Policy WSA.4. -WAH232 (GB1) Yieldsfield Farm (sometimes recorded as
Yieldfields farm), Stafford Road, Bloxwich.

This large allocation of 600 houses is likely to impact upon a known identified core habitat zone (Local Nature Recovery Mapping and Natural Capital Maps 2021). This represents potentially significant impacts on key local biodiversity rich sites such as Pelsall Common through likely increased recreational impacts. Natural England would be keen to explore mitigation measures here such as creating new biodiversity rich green open spaces such as a country park with heathland recreation therein to also be interlinked by biodiversity rich multiuser green infrastructure corridors.

Comment

Representation ID: 16326

Received: 11/10/2021

Respondent: Natural England

Employment sites

Walsall

WAE412 (GB1) Sandown Quarry, Stubbers Green Road, Aldridge

This site includes part of the Swan Pool & The Swag SSSI, which is notified for non breeding bird populations of Swallow, Hirundo rustica. Swan Pool & The Swag are two pools lying on an impermeable layer of Etruria Marl (of the Upper Carboniferous Coal Measures). Three sides of Swan Pool and the north-western end of The Swag are dominated by swamp and tall fen vegetation that holds a post-breeding roost of swallows and martins during the autumn migration. Peak populations of around 10,000 birds have been recorded. The two sites provide a roost for a significant proportion (at least 1%) of the total British swallow population.

We have the following concerns about this site:

• Bird disturbance
• Loss of habitat- on and off site.
• Impacts on water quantity and quality.

Please also see our comments about MSwa9 under Policy MIN3 - Preferred Areas for New Mineral
Development.

Comment

Representation ID: 16329

Received: 11/10/2021

Respondent: Natural England

Mineral sites

MSwa5 (MP4) Branton Hill Quarry and extension, Branton Hill Lane, Walsall (sand)

This site is located along a strategic wildlife corridor. We would welcome dialogue with the Local Planning Authority and the owner/operator to ensure that the restoration maximises natural capital and ecosystem services provision to local people and wildlife.

Comment

Representation ID: 16330

Received: 11/10/2021

Respondent: Natural England

MSwa6/ MXA2 (MX4) Highfields North, Walsall Road, Walsall Brick (Clay (dormant permitted minerals site))

We would advise that reference is made to Walsall’s adopted Site Allocation document Policy M8: Brick
Clay Extraction – Other Areas – paragraph MP9: Highfields North – Permitted Minerals Site (see annex
3) either within the policy or the jurisdiction

Object

Representation ID: 16668

Received: 11/10/2021

Respondent: Natural England

Strategic Allocation WSA.1-WAH236 (GB1) Land at Yorks Bridge, Lichfield Road, Pelsall

In addition to the above, for site WAH 236. Natural England object to any housing development in this area because this is part of a Core Habitat Zone (see Local Nature Recovery Strategy (LNRS) Mapping
- Ecorecord) and is essentially a hot spot of biodiversity across the northern part of the borough.

Additional housing will clearly add to increased recreational impacts on Pelsall North Common LNR
and potentially Clayhanger SSSI, which is notified for its grasslands and wetland habitats.

The adjacent Pelsall North Common LNR is an important wildlife site and potential addition to the Chasewater SSSI complex, and provides a biodiversity north and south connection for species as well as providing connectivity between Cannock Chase SAC/SSSI and Sutton Park SSSI.

It offers key biodiversity corridors linking Pelsall, Brownhills and Chasewater. Pelsall North Common is a sister site to Brownhills Common, which forms part of Chasewater and The Southern Staffordshire Coalfield Heaths SSSI, having an existing important lowland heathland which is almost as large as Brownhills Common and is one of most important old heathlands remaining in the area. This site lying close to Pelsall North Common with its acid grassland and relict heathland plays a part in a key wildlife corridor linking Cannock Chase down into the centre of Walsall. As such it is another
important wildlife site in the Birmingham and Black Country Nature Improvement Area. This site is within the core habitat zone identified by the Ecorecord Natural Capital Mapping and Local Nature Recovery Strategy 2021. There are exceptional opportunities to link this site with Brownhills to the north east that represent significant wildlife habitat gain and community enjoyment and access for the area.

In addition the site is in close proximity to Cannock Extension Canal SAC/ Cannock Extension Canal
SSSI which is notified for Luronium natans, Floating Water-plantain. This site allocation is likely to
have an adverse impact on the site through water and air pollution. Habitats Regulation Assessment of the site will be required.

Comment

Representation ID: 16760

Received: 11/10/2021

Respondent: Natural England

Policy ENV1 – Nature Conservation

We welcome this policy, however that the following site allocations are likely to impact upon the effectiveness of policy ENV1 (1b,1c,1d, 3):

• DUH203- Land at Ketley Quarry, Kingswinford
Impacts on Ketley Claypit Site of Special Scientific Interest (SSSI) and potentially priority habitats- deciduous woodland.

Please see 13 Sub-Areas and Site Allocations for further details of our concerns.

We would advise that the Plan should identify land where development would be inappropriate, for instance because of its environmental significance.

Natural England welcome the creation and designation of new Local Nature Reserves as additional assets to the Local Nature Reserve suite currently in place, especially were they offer additional access to local people for recreation and education.