Black Country Core Strategy Issue and Option Report

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Object

Black Country Core Strategy Issue and Option Report

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be

Representation ID: 2249

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

It does appear that Key Issue 5 Environmental Considerations are concentrating on national or international designations (eg SACs and SPAs). This should also take account of more 'local' designations.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Object

Black Country Core Strategy Issue and Option Report

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate

Representation ID: 2250

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

Objective 10 represents a particular difficulty for this Company.

'Dormant' Planning permission exists for the extraction of Brick Clay on the Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are a finite natural resource which can only be worked where they are found, and it is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning authorities are therefore required adopt policies to prevent other development from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to maintain brick clay supplies to local brickworks and the potential shortfall which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least of which is the designation of much of the site as an SSSI with the remainder being included within a SLINC. Any application for modern working conditions for this site will be expected to include a significant level of supporting information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a proportion of the SSSI's special features throughout the working phases of the site (now set out in Walsall's submitted Site Allocations Document). Laudable as this requirement is, it must be recognised that the imposition of severe restrictions on working the site could seriously impact upon the viability of the site. As the planning permission pre-dates the SSSI designation the policies ought to acknowledge the potential implications of the viability/loss of value which may result. The conflict which arises - need for the mineral versus retention of valuable ecological features - will make this objective particularly difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for clay extraction. Much of the land is also designated SSSI. Extraction of the clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this would be many years away, following an extended period of extraction and backfill.

In this instance the two elements of Objective 10 are incompatible.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re

Representation ID: 2251

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 12b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).

Representation ID: 2252

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

The permitted clay extraction site at Highfields North (referred to elsewhere) can only be worked at the expense of an SSSI. Protection of the SSSI could render the operation of the site not viable to the serious commercial detriment of this Company.

There is the prospect of securing built development on that part of the permitted clay extraction site which falls outside the SSSI as an alternative to the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the submission document because of the potential conflict with extraction. It is therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the SSSI and the remainder of the local Green Belt designations for the future.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 15a - If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be tak

Representation ID: 2253

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

Subject to the availability of suitable sites, reasonable access to employment and continued inter-relationship with the Black Country

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 15b - Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details.

Representation ID: 2254

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

Telford and Wrekin District. Telford was established as a New Town with the very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households. Significant areas of potential development land exist within the Authority area and excellent communications already exist between the two authorities in the form of rail and the M54.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?

Representation ID: 2255

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

The apparent overriding need to protect and enhance biodiversity doesn't address the conflict which can occur when two incompatible aspirations apply to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning permission (dormant) for brick clay extraction. Any application for modern working conditions for this site will be expected to include a significant level of supporting information including Ecological Assessment and a strategy for minimising loss of the SSSI's special features, together with permanent retention of a proportion of the SSSI's special features throughout the working phases of the site (now set out in Walsall's submitted Site Allocations Document). Laudable as this requirement is, it must be recognised that the imposition of severe restrictions on working the site could seriously impact upon the viability of the site. As the planning permission pre-dates the SSSI designation the policies ought to acknowledge the potential implications of the viability/loss of value which may result.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 112a - Are there any key mineral related infrastructure sites that no longer need to be protected? Yes/No, Please provide details.

Representation ID: 2256

Received: 11/09/2017

Respondent: Parkhill Estates Ltd

Representation Summary:

There is potential for change at the Highfields North Site in Walsall. There arechallenges relating to its future operation - in addition to those set out elsewhere relating to the SSSI. The passage of time since the original permission has introduced other concerns with increased development in the area and associated increased traffic movements (not insurmountable). The balance between conflicting aspirations needs to be considered here and this may be a site which can offer a more appropriate form of development than that currently permitted.

Full text:

Chapter 3 / Page 26 / Question 6.

It does appear that Key Issue 5 Environmental Considerations are
concentrating on national or international designations (eg SACs and SPAs).
This should also take account of more 'local' designations.

Chapter4 / Page35 / Question8 / Paragraph 4.6

Objective 10 represents a particular difficulty for this Company.
'Dormant' Planning permission exists for the extraction of Brick Clay on the
Highfields North Site in Walsall Wood, and this is acknowledged in Walsall's
submitted Site Allocations Document.

This accords with National planning policy which recognises that minerals are
a finite natural resource which can only be worked where they are found, and it
is necessary to make best use of these resources, to ensure there will continue
to be sufficient supplies remaining for future generations. Mineral planning
authorities are therefore required adopt policies to prevent other development
from needlessly compromising (sterilising) future exploitation of these
resources. This is emphasised as the Walsall Plan recognises the need to
maintain brick clay supplies to local brickworks and the potential shortfall
which is likely to occur.

It is acknowledged that this particular site offers various challenges, not least
of which is the designation of much of the site as an SSSI with the remainder
being included within a SLINC. Any application for modern working conditions
for this site will be expected to include a significant level of supporting
information including Ecological Assessment and a strategy for minimising
loss of the SSSI's special features, together with permanent retention of a
proportion of the SSSI's special features throughout the working phases of the
site (now set out in Walsall's submitted Site Allocations Document). Laudable
as this requirement is, it must be recognised that the imposition of severe
restrictions on working the site could seriously impact upon the viability of the
site. As the planning permission pre-dates the SSSI designation the policies
ought to acknowledge the potential implications of the viability/loss of value
which may result. The conflict which arises - need for the mineral versus
retention of valuable ecological features - will make this objective particularly
difficult to achieve.

Summary

This Company owns a site which has the benefit of planning permission for
clay extraction. Much of the land is also designated SSSI. Extraction of the
clays will totally destroy the area of the SSSI. Even if it were possible to
recreate the features of interest on restoration, which has to be doubtful, this
would be many years away, following an extended period of extraction and
backfill.

In this instance the two elements of Objective 10 are incompatible

Chapter4 / Page43 / Question 12a /

This would appear to offer the most flexible approach. Specifying rigid criteria
may not be the most appropriate way to achieve this - as every situation will be
different and ought to be treated on its merits. The need to ensure that
defensible boundaries remain is nonetheless considered to be of significant
importance.

Chapter 4 / Page 44 / Question 12b

The permitted clay extraction site at Highfields North (referred to elsewhere)
can only be worked at the expense of an SSSI. Protection of the SSSI could
render the operation of the site not viable to the serious commercial detriment
of this Company.
There is the prospect of securing built development on that part of the
permitted clay extraction site which falls outside the SSSI as an alternative to
the extraction operations. Land immediately adjoining was included in the
Walsall Local Plan SAD as a housing site but was removed from the
submission document because of the potential conflict with extraction. It is
therefore clearly considered an appropriate location for housing in other
respects.

Such development of this land as an alternative to extraction would secure the
SSSI and the remainder of the local Green Belt designations for the future.

Chapter 4/ Page 46/ Question 15a

Subject to the availability of suitable sites, reasonable access to employment
and continued inter-relationship with the Black Country

Chapter 4 / Page 46/ Question 15b

Telford and Wrekin District. Telford was established as a New Town with the
very intention of taking 'overspill' from the Black Country. It has never achieved
the targets originally envisaged in terms of population and households.
Significant areas of potential development land exist within the Authority area
and excellent communications already exist between the two authorities in the
form of rail and the M54.


Chapter 6/ Page 98/ Question 96

The apparent overriding need to protect and enhance biodiversity doesn't
address the conflict which can occur when two incompatible aspirations apply
to a single site, as at Highfields North in Walsall.

Here, an SSSI has been designated on land already with the benefit of planning
permission (dormant) for brick clay extraction. Any application for modern
working conditions for this site will be expected to include a significant level of
supporting information including Ecological Assessment and a strategy for
minimising loss of the SSSI's special features, together with permanent
retention of a proportion of the SSSI's special features throughout the working
phases of the site (now set out in Walsall's submitted Site Allocations
Document). Laudable as this requirement is, it must be recognised that the
imposition of severe restrictions on working the site could seriously impact
upon the viability of the site. As the planning permission pre-dates the SSSI
designation the policies ought to acknowledge the potential implications of the
viability/loss of value which may result.

Chapter 6/ Page 109/ Question 112a

There is potential for change at the Highfields North Site in Walsall. There are
challenges relating to its future operation - in addition to those set out
elsewhere relating to the SSSI. The passage of time since the original
permission has introduced other concerns with increased development in the
area and associated increased traffic movements (not insurmountable). The
balance between conflicting aspirations needs to be considered here and this
may be a site which can offer a more appropriate form of development than that
currently permitted.


Attachments:

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