Sandwell Local Plan - Reg 19 Publication

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.
WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.
1 Unsound. Do not support SMBC calculation of 10% net gain due to their failure to independently assess private land in alllocation proposals like SH35 and SH36. Lepus consulting report for BNG is not a credible piece of evidence to base conclusions upon and is seriously flawed in its assessments and calculations of land only in council ownership. Previous faliure to secure 10% gain is noted. https://www.expressandstar.com/news/local-hubs/sandwell/tipton/2023/02/21/wildlife-buffer-zone-to-be-removed-to-make-way-for-industrial-warehouse-in-tipton/

2 a-d In principle sound, but as above, the basis for Sandwell assessing private sites is lost on their failure to already survey them. Their consultant report failed to survey sites properly in terms of habitats, species and different times of year. Only 1 single visit was made to assess their chosen BNG sites which is not acceptable.No apparent correlation/collaboration with Eco record reports, other conservation groups and interested parties, give the impression that this was a rushed bolt on assessment to look credible and a tick box exercise. The report is not credible at all when scrutinised.

3 UNSOUND, REMOVE PARAGRAPH. This will be the actual standard as a result of this policy given the council cannot independently varify any report produced by the applicant. SH35 and SH36 for example are 100% rewillded for the purpose of "private open space". To achive devlopment of proposed 500 plus hoiuses would require ALL of this to be dug up, every tree and plant uprooted and vast swathes of biosdiversity land lost BEFORE any so called "gain" of 10%. In essence the policy is a fraud , not justifed and disingenuous and unsound.
4 In principle sound, but same issues as above.
5 Unsound. Do not possibly see a developer being around for 30 years and the council will not be monitoring any onsite activity as it has no baseline to start with that can be independetly varified.
6 TOTALLY UNSOUND. Not justified given the poor report it has based its chosen sites on, and the weaknesses of the sites in terms of their poor current scores. No reason stated by council in the Lepus report for exclusion of privately owned sites, or sites like existing LNR SINC sites like Sheepwash that do not even appear to have been considered but ARE owned by sandwell council! . Do not agree with the methodology used to choose these sites.
7 Support as sound, but the previous papargraphs in this policy, particularly privately owned land and lack of surveying compromises this strategy and directly threatens it. Only council owned sites appear to be valued.
8 sound
9 sound. We agree that sites like SH35 and SH36 should be retained as extensions to Sheepwash LNR and become a SINC. SH35 area has very rare small blue butterfly and associated kidney vetch so of important scientific interest and protection from development as a local green space. (31)
10 Unsound. Again what assessments will be made that could lead to developers claiming that all of their sites contain invasive species, and therefore cut down everything on site and then increase that by 10% starting from a baseline of nothing!
11 Sound
12 Sound

Real concern that this policy will fail and become an unworkable licence to destroy anything on a private sites, only to claim 10% back using the council land identified by council BNG on their own land. Council may benefit from this but nature does not. Council need to create more local nature reserves and extend others with land allocations SH35 and SH36 to realise connectivity of sites within Sandwell and beyond as a more appropriate strategy. Also relevant and not mentioned in the publication plan is SMBC FULL council meeting
Notice of Motion – 29 October 2024. Animal Welfare

“Council notes that:

Protecting wildlife and natural habitats is crucial for maintaining biodiversity and ecological balance.”
A choice of certain sites for housing allocations like SH35 and SH36 are not consistent with this motion passed by the full council on the date stated.