Draft Black Country Plan

Object

Representation ID: 16857

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

The Plan does not include a target for reaching net-zero carbon emissions.
This should be included in a Strategic Climate Change Policy which is one of
the strategic CSP policies and the location of all developments in the plan
should be tested against that target. We consider that while CC1 and the
subsequent policies on Climate Change are welcome in general terms the
urgent need to reduce emissions is relegated in the plan against other goals,
notably housing and economic targets. Unless climate change is central to the
plan, we do not believe it fulfils its role in assisting to meet the urgent
national and international need to reduce emissions so as to avoid
catastrophic climate change.

Object

Representation ID: 16858

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

The plan includes a number of housing developments in locations we consider
to be unsustainable in terms of carbon emissions and damaging to the both
the ecological biodiversity and the access to the countryside and nature
within Walsall, as well as in other locations in the Black Country. We are
particularly concerned that nine significant sites are designated to be
removed from the Green Belt, including two, the Arboretum site and the
Sutton Road site, which would directly impact on the very important natural
and amenity value of the Arboretum and its surrounding area. This
undermines the good efforts of the Council and others to plant trees and
renature areas around the Arboretum and to gain the benefit of the canal
network as it passes under Longwood Lane and behind the Sutton Road.

See table in attachments

Object

Representation ID: 16859

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

We also strongly object to the loss of sites around the former Power-station at
Reedswood Park (WAH 125, 244). This is an important area of wildlife close to
the town centre, which benefits from a network of ecological habitats,
including woodland and several pools. It is also an enormous leisure asset for
those who live nearby. We believe both these sites should be removed from
the plan. Moreover, we strongly support the view (expressed by the Bentley
Agenda 21 Group), that the whole of the Reedswood Town Park and the Pouk
Hill Green Space should be excluded from the ‘Core Regeneration Area’
designation. Both sites provide vital biodiversity and leisure benefits which
need to be strongly protected against future speculative development.

Comment

Representation ID: 16860

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

And while Walsall FoE is not in a position to analyse in detail the overall
housing need and supply numbers, we are aware of other environmental
groups, such as CPRE, which are in a better position to do so and we share
their concern that the Council is relying on out-of-date housing forecasts from
the ONS.
We would urge the council, along with the other three authorities, to review
the availability of brownfield land and to assess new sources, such as
redundant industrial land and excess retail accommodation, especially in our
existing centres. We believe the council should be seeking more mixed use
and housing development close to and within centres to make them more
viable and reduce travel.
This should allow the council to reduce, or preferably remove the need for
additional housing on the edge of the conurbation in the Green Belt and on
high ecological value sites within the Borough.

Comment

Representation ID: 16861

Received: 10/10/2021

Respondent: Friends of the Earth

Agent: Gerald Kells

We welcome the emphasis on supporting public transport but we are
concerned that the plan still includes support for significant additional road
funding, including (TRAN1) Motorway Junction Improvements which will only
increase the pressure on local roads and a new link road between the M6Toll
and the M54. We would argue that it is far more important to fund local
public transport improvements.
We also remain dubious of the benefits of the A34 Sprint, especially if it
simply replaces services such as the X51. What is needed is much more
significant investment and prioritisation of Public Transport.
We are also concerned that the ambition for sustainable modes, such as
walking and cycling are not high enough. Policies TRAN 3 and 5 should
positively prioritise those modes over car travel and should seek to break
down barriers which prevent use of sustainable modes such as unsafe road
crossings.