Support

Representation ID: 1710

Received: 17/03/2026

Respondent: Rattlechain Redevelopments Ltd

Agent: Ms Altine Elias

We support the allocation of the Rattlechain site as a Strategic Housing allocation. We would however welcome the revision of para 16.12 - whilst the site does not meet the NPPF definition of PDL, it is undoubtedly land which has been the subject of significant development in the past and as such is not predominantly green field. The green appearance of the site is due to self seeding scrub, trees and plants not due to it being green field in character.

Comment

Representation ID: 1728

Received: 26/03/2026

Respondent: National Grid

Agent: Fisher German

NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.

With the above in mind, NGET would like to provide its strong support for inclusion of wording at Policies SSM1 (b) and SSH3 (g) (Main Modifications 91 and 81 respectively) and their explicit recognition of the presence of NGET assets within the sites, and specifically a requirement of the policy for a strategy to be produced which responds to those assets and demonstrates how the NGET Design Guide and Principles have been applied at the master planning stage and how the impact of the assets has been reduced through good design.

Without this acknowledgement and requirement, policies SSM1 and SSH3 would not be effective as they could not be delivered as proposed; unencumbered by the constraints posed by the presence of NGET infrastructure.

Object

Representation ID: 1750

Received: 27/03/2026

Respondent: Mrs Sara Lovell

Legally compliant? Yes

Sound? No

We reiterate previous comments made and maintain that there is sufficient evidence that the biodiversity value of this site/area is substantial/should be safeguarded. An appropriate local site assessment should be required to appropriately inform the local plan allocation. This site has long been identified as a Potential Site of Importance (PSI) and is part of a well connected network through a heavily urbanised landscape. Collectively, the wider area supports several important habitats and notable/protected species. It is our view that there is sufficient evidence to suggest the site comprises highly valuable (brownfield) habitat and therefore an assessment must be required.

Object

Representation ID: 1755

Received: 27/03/2026

Respondent: Mrs Sara Lovell

Legally compliant? No

Sound? No

We reiterate previous comments made and maintain that there is sufficient evidence that the biodiversity value of this site/area is substantial/should be safeguarded. An appropriate local site assessment should be required to appropriately inform the local plan allocation. This site has long been identified as a Potential Site of Importance (PSI) and is part of a well connected network through a heavily urbanised landscape. Collectively, the area supports several important habitats and notable/protected species. It is our view that there is sufficient evidence to suggest the site comprises highly valuable (brownfield) habitat and a local site assessment must be required.

Object

Representation ID: 1756

Received: 30/03/2026

Respondent: Friends of Sheepwash Local Nature Reserve

Legally compliant? No

Sound? No

We wish to underline our opposition to this proposed site now considered a "strategic site", formerly SH35 and SH36 which we believe to be fundamentally flawed and unsound and also not legally compliant.

Representations have been made by us and on behalf of local residents of Temple Way estate at every part of this process and that opposition expressed as a petition, continues with this proposed MM81 and policy SSH3. The rattlechain lagoon is still subject to environmental permitting under The Environmental Permitting (England & Wales) Regulations 2016 , a legal constraint, that has not been assessed or commented upon by
the environment agency or the current site owners, it is not subject to compulsory purchase and yet Sandwell council have ignored this throughout, making this policy ridiculous and also their plan which hinges upon housing figures being delivered by 2041 unsound and not justified and not effective . We have outlined the real constraints of this policy in the attached document "rattlechain site constraints, theory vs reality."
The council appear to have shifted from their erroneous position of this site being "brownfield" which it is irrefutably not, now calling it "greenfield".

The council failed to address why this site had not been considered as strategic open space or what appraisal had dismissed this. The policy has not addressed key statements and concerns that were made during the hearing sessions , and nor is it consistent with NPPF Dec 23 paragraphs 191,
2024 NPPF removes the 4-year carve-out language present in 2023. Additional 20% buffer introduced post-2026.
Implication:
If strategic sites stall, speculative development exposure increases.
Issues:
• No revisiting of SSH3 alternatives at Main Mods stage.
• Corridor-level cumulative ecological assessment not evident.
• “Appears predominantly greenfield” language may indicate narrative reframing without comparative.
Test:
Were reasonable alternatives genuinely and comparatively assessed at each stage of modification?
Given: the plan states
• 14,449 housing shortfall
• 185ha employment shortfall
• Reliance on cross-boundary cooperation
• NPPF 2024 strengthened expectation to meet need in full
Question:
Is this policy in the plan effective under NPPF paragraph 35?

The policy has not retreated from environmentally sensitive allocations.
It has:
• Formalised them.
• Strengthened narrative defensibility.
• Embedded more detailed constraint description.
• Retained scale.
It has not:
• Inserted explicit ecological buffers.
• Embedded corridor-scale cumulative safeguards.
• Eliminated reliance on viability caveats.
• Resolved structural housing or employment shortfall.
This is a Plan using this site which has hardened procedurally — not recalibrated strategically.

Policy and sustainability assessment makes no reference to named protected species on this site, including the small blue and associated unique habitat. The peculiar circumstances at Rattlechain make it impossible to consider compensatory offset as this could not be recreated elsewhere. A priority species under the UK Post-2010 Biodiversity Framework, also appearing on the GB Red List (2022): Near Threatened. Additional red
list flora found on this site for vascular plants Nov 2025 have now appeared since the hearing sessions, kidney vetch, tower mustard and Narrow-leaved everlasting pea.

See attached document confirming this. DEC 2023 NPPF P185- the council have not adequately addressed this.

Object

Representation ID: 1762

Received: 30/03/2026

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

This site is highly contaminated, and we are concerned that with the site's unusual characteristics and history of waste deposits (including the phosphorus waste lagoons) that this may prove costly and technically unfeasible to remediate, potentially leaving the Council with a site that is unable to deliver. We would recommend the Council withdraws the allocation or pauses until further investigation work determines its potential for redevelopment.