Draft Black Country Plan

Object

Representation ID: 13547

Received: 20/08/2021

Respondent: Class Q Ltd

It is considered that the proposed allocations within the Walsall borough do not go far enough to meet the necessary housing provision over the plan period.

Some of the proposed Strategic Allocations are questionable. WAH231 (Policy WSA6) is constrained by its access for a proposed development of 202 houses. The site has just recently been allocated as a SLINC. Developing at the proposed housing density will unequivally destroy the site's capability to act as a nature conservation. The validity of SLINCs will also be compromised if this site is developed for residential purposes. It is surprising to see the local authority simultaenously designate land for nature conservation and large-scale residential development.

There are undoubtedly sites better suited to residential development within the immediate vicinity of WAH231. One of these is Call for Sites submission 10215 - Land to the East of Longwood Lane, I act as agent for this site. We provided a masterplan to demonstrate how the site could accomodate 95 dwellings (sent to on 28th April 2021).

10215 benefits from far better access than WAH231 and is not designated as a SLINC, it is unclear why, and on what basis, WAH231 was selected ahead of 10215.

Should WAH231 be retained, it is entirely logical that 10215 would also be allocated for residential development as it fills a gap betwen WAH231 and WAH252 and is deliverable within 5 years.

I would kindly ask that WAH231 is looked at again and 10215 is considered as either: an alternate allocation to WAH231, an allocation in addition to WAH231, or a reserve allocation.

Object

Representation ID: 21322

Received: 11/10/2021

Respondent: Class Q Ltd

I write as Agent for land identified as SA-0050-WAL in the Black Country Site Assessment Report and seek to make representation to the Regulation 18 Consultation to outline that this site is an appropriate location for housing development for approximately 93 dwellings instead of, or as well as, WAH231 which lies immediately to the west and proposes 202 dwellings.

The basis for discounting SA-0050-WAL as a potential allocation was based on the findings of the Black Country Site Assessment Report that found deficiencies in terms of harm to the Green Belt, harm to landscape, highways and ecology.

As a result of this assessment, further work has been undertaken to demonstrate that the conclusions reached in the Assessment are incorrect and that the site should be considered favourably as an allocation.

To demonstrate this, each matter is addressed in turn below.

Development of the site is considered to result in a high level of harm to the Green Belt and The landscape is
considered to have a “moderate-high overall sensitivity to residential development”

The assessment made the following comments “The sub-parcel makes a strong contribution to preventing the sprawl of the West Midlands conurbation, maintaining the separation of Walsall, Aldridge and Streetly (adjoining Sutton Coldfield) and preventing encroachment on the countryside. However, release of land on the urban fringes of the subparcel that have less significant boundaries between settlement and countryside would result in slightly less harm than release of the core area between towns”.

To address these concerns a Landscape and Green Belt Assessment has been prepared to consider and assess the potential effect on: site context and features; landscape and visual receptors; designations; and the Green Belt.

The Assessment should be read in full as part of this representation, however, it concludes that the proposal would cause less harm to the Green Belt and landscape receptors, and potentially visual receptors, than either Strategic Allocation Sites WAH231 and WAH242 and that it would provide a more appropriate release from the Green Belt, either in addition or as an alternative, and that it should accordingly be allocated for residential development.

Upgrades to the local highway would be required

The assessment, regarding highways access and transportation states that “The impact of 81 homes here would require a transport assessment to understand what mitigation would be required and whether that could have any significant impact on viability. Works may be required to Longwood Lane which currently has no footpath and to mitigate the additional impact on the junction from Longwood Lane to Sutton Road. The existing highway infrastructure here would not be sufficient to support an employment use”.

To address these concerns a Highways Advocacy Document has been prepared to review the highways feasibility and deliverability of a proposed allocation on the site.

The Highways Advocacy Document should be read in full as part of this representation, however, it concludes that, based on the quantum of residential development proposed for allocation on this site, it is considered that the impact of the proposals would result in a negligible impact on the capacity of the highway network and would have no adverse impact on highways safety.

The site was also cited as having importance for the retention of trees and hedges and concerns were raised about the potential impact on ecology

However, regarding trees the assessment states that “There are no protected trees or hedges, however there are established trees and hedges which may be worthy of retention. A tree survey is required to determine the quality of trees and whether they must be retained. Much of the site is open and the retention of trees and hedges would not significantly reduce the potential for redevelopment of the site”.

“The site is in close proximity to Hay Head SSSI to the East and any changes to established hedges or trees would require an Ecology assessment. The ecological valuation of the Black Country Green Belt is based on a set of assumptions that formed the basis for developing a set of criteria which allowed EcoRecord to attribute a relative value to individual land parcels within the Green Belt. A Valuation Matrix was used based on the following attributes to calculate a final ecological value score for each Landscape Unit: Land Use Calculated Value, Habitat Features, Nature Conservation Designation Value, Adjacency to SSSIs or Ancient Woodland, Historic Landscape Characterisation (HLC) Type Value, Twinspan Axiophyte Value (TAV) and Breeding Farmland Birds Value. The higher the score the higher the ecological value. Predominant Ecological Valuation of the Black Country Green Belt Score = 4 The site falls within a Nature Recovery Network Core Habitat Zone”. The site was therefore scored red meaning that its “Capacity significantly limited unless harm is caused to habitat of SINC / SLINC value, which cannot be wholly mitigated”.

To address these concerns, a Preliminary Ecological Assessment has been prepared and is attached with these representations.

The Preliminary Ecological Assessment should be read in full as part of this representation, however, it concludes that there are no ecological issues that would prevent the site from being developed, subject to addressing certain matters set out in the Assessment.

Other Matters
In addition to the above concerns that “The North East part of the site may be within an area of untreated Limestone, anything within this identified area is not safe to build on and would have a minor reduction to the developable area”.

Having reviewed the Environment Agency website for historic landfill/quarry workings whilst there is an old landfill a short way down the road; there is nothing below the site. The bedrock below the site is Coalbrookdale Formation, which is a Mudstone. Therefore, the Council have incorrectly assessed the site on this matter.

Conclusions
The Council’s decision to not allocate the land at Longwood Lane was based on the omission of the information now submitted as part of these representations.

The information provided clearly demonstrates that the land is an appropriate location for a residential development that can be achieved without undue harm relating to highway safety, landscape and Green Belt harm and ecological harm.

On this basis, the Council is requested to review the land again with a view to including it as a further residential allocation in the emerging Black Country Plan 2039.