Environment / Open Space
How will Policy ENV1 (Nature Conservation) of the Black Country Core Strategy be addressed?
Policy ENV1 acts to safeguard nature conservation by ensuring that SLINCS, important habitats and geological features are protected from developments that could negatively impact on them. The Brandhall Village currently has a small SLINC allocation on part of the site. This area would have to be given special consideration as part of any masterplan proposal.
The Brandhall Urban Village site is also a wildlife corridor and policy ENV1 requires that any development proposal does not impede the movement of wildlife through linear habitats. Therefore, any masterplan proposal would have to demonstrate how wildlife can still move through this linear habitat.
Policy ENV1 does acknowledge that; “Where, exceptionally, the strategic benefits of a development clearly outweigh the importance of a local nature conservation site, species, habitat or geological feature, damage must be minimised. Any remaining impacts, including any reduction in area, must be fully mitigated. Compensation will only be accepted in exceptional circumstances. A mitigation strategy must accompany relevant planning applications”.
Strategic benefits in this instance would include the scale of housing need identified for Sandwell compared to the capacity of all available brownfield sites as well as the need to provide replacement education provision.
It is a requirement of the Local Planning Authority that detailed information is submitted as part of any planning application setting out the current ecological condition of the site including both fauna and flora, and that there is evidence that either the impacts of the scheme can be suitably mitigated or the design for the site avoids harming the areas of most significant ecological and biodiversity value.
How will the sites’ suggested designation as a Core Habitat Zone in the Black Country Plan be taken into account?
This is a recent consideration and is part of the Black Country Plan response to the Environment Act, which requires local authorities to identify areas and networks where improvements can be made to habitats and ecology. There will be a statutory obligation for the creation of Local Nature Recovery Strategies.
The plan was produced in draft form by the local Wildlife Trust in April 2021 and indicates Brandhall as an area where habitat and biodiversity can be strengthened, and improvements delivered. To date, this has not been adopted or finalised, but will be an important consideration should the site be considered for development. There is an opportunity to improve and increase the biodiversity and habitat value of the site (also in line with the requirement for a minimum 10% biodiversity net gain required by the Environment Act), and this would need to be addressed in landscaping and ecological proposals in the masterplan or other elements of the design work.
The retained habitats at the site would be protected and managed to enhance their biodiversity potential. The woodland and watercourses will continue facilitate species dispersal across the site between adjacent residential areas and other parts of the River Tame Wildlife Corridor which extends to the north and south.
In including the site as a proposed allocation for housing in the Black Country Plan how has the council considered flooding and ‘open space’ not surplus against current standards (two gateway constraints)?
The Black Country Plan includes a Strategic Flood Risk Assessment (SFRA) which considered all sites that were proposed to be included in the Draft Plan. This did not identify the site as a site that is incapable of development due to the risk of flooding.
Small areas of the site fall with Flood Zones 2 and 3 with only the latter forming a gateway constraint.
The site is not currently allocated as ‘Open Space’ in the adopted Local Plan (the Sandwell Site Allocations & Delivery DPD). Public access to the site has always been restricted to the public footpaths that cross the site. Therefore, there is no loss of public open space to act as a constraint on development.
How will the proposed development take in to account and address the priority habitats protected by The Natural Environment and Rural Communities Act (2006) (NERC) Section 41 legislation?
Lowland mixed deciduous woodland (semi-natural broadleaved woodland) is the only Section 41 habitat of principal importance at the site.
The masterplan would seek to retain and protect as much lowland mixed deciduous woodland importance as possible. Any removal of woodland would be replaced to ensure that there is no net loss of this habitat at the site.
The site falls within an Area of High Historic Landscape Value (AHHLV) in the draft Black Country Plan; how has this been taken into account in the development of the masterplan?
As set out within the Black Country Historic Landscape Characterisation Study,
AHHLV 55 Brandhall Ridge and Furrow contains several areas of surviving ridge and furrow earthworks. These features may date back to the medieval or early post-medieval periods and could be remnants of the medieval open field system. The landscape had been enclosed, via a process of informal enclosure by 1814, when it is depicted on the 1814 Ordnance Surveyors Drawing. In the early 20th century the area was converted into a golf course. Environment Agency LiDAR shows surviving areas of ridge and furrow earthworks within the golf course.
The area of ridge and furrow is visible on aerial and LiDAR imaging, however due to 20th-century tree planting and long grass associated with the golf course it was not visible during site walkovers.
There is potential for previously unrecorded remains dating to the medieval period within the development site, and therefore further archaeological evaluation would need to be undertaken in order to understand the archaeological potential of the site as the masterplan progresses.
To mitigate physical impacts from future development, the areas of these surviving features could be incorporated within open spaces within the site.
The site has a 99-year deed of covenant for the Black Country Urban Forest Millennium Programme, how has this been taken into account?
The Deed of Covenant, relating to the Millennium Forest/Black Country Urban Forest affects part of the proposed site, and if necessary it will be varied by agreement [with the Millennium Commission] to ensure the scheme accommodates adequate replacement planting.
There is a covenant on the site which prevents it being developed.
The council’s legal team has investigated the title to the site, and that all the covenants that affect the site have been considered, and would need to be taken into account throughout the development planning process.
Given the site is an important wildlife corridor how will the proposed redevelopment protect and enhance biodiversity and what would any mitigations look like?
The retained habitats at the site would be protected and managed to enhance their biodiversity potential. The woodland and watercourses will continue to facilitate species dispersal across the site between adjacent residential areas and other parts of the River Tame Wildlife Corridor which extends to the north and south.
The woodland could be enhanced by selective thinning/coppicing and planting of hazel and hawthorn to enhance structural diversity and to increase their biodiversity value. The retained woodland belts (that are orientated NE-SW and N-S) could be extended to the southern boundary hedgerow to facilitate species dispersal across the site to the other parts of the River Tame Wildlife Corridor.
The culverted sections of watercourse could be removed to form open channels. Any watercourse diversions would have a sinuous alignment, soft banks with shelves stocked with plant species characteristic of the local area and large side pools. Swamp vegetation and silt could also be removed from retained pools to create more open water and increase the biodiversity value.
How will Climate Change be taken in to account in the masterplan and in any final development proposal. How will the loss of natural resources impact on Sandwell’s Carbon Neutral Policies and what mitigation if any will there be?
One of the principles in our vision for Brandhall Village is to reduce the impact on our climate and instil a number of key objectives within the masterplan which would continue to be developed as the masterplan progresses:
- Reduce embodied carbon – consideration of resource efficiency would be key in driving down the embodied carbon emissions at Brandhall Village. As we move to a net zero future, embodied carbon will become more prevalent as a total of a building’s emissions. Designing in circular economy principals such
- as designing for deconstruction or reuse will be vital for the reduction of raw material demands.
- Reduce operational energy demands and CO2 emissions to a minimum – through consideration of form, insulation, air tightness, thermal bridging, glazing, ventilation, heat recovery and utilisation of renewable energy sources as designs move to detailed stages.
- Reduce reliance on fossil fuels – by requiring no new natural gas infrastructure and instead promoting the use of electric heat pumps; and promoting more sustainable forms of transport based on a hierarchy of walking, cycling, public transport and finally private ULEV (e.g. facilitating the switch to electric vehicles).
- Maximise renewable energy generation – through the orientation of buildings and providing sufficient space to incorporate renewable technologies.
- Build in resilience to the projected impact of climate change – through the provision of green spaces, retaining as many trees as possible and through replacement planting for natural shading, utilising natural sustainable drainage systems, utilising native plant species and increasing bio-diversity net gain.
- Encourage sustainable travel – through the provision of attractive cycle paths and footways which provide convenient links to local amenities and wider public transport infrastructure.
How will the impact of the development and the loss of non-renewal tree and soil resources impact on the air quality in Sandwell and what will be the mitigation if any?
An air quality assessment has not yet been undertaken. Should it identify any adverse effects, mitigation measures would need to be identified.
How will the council ensure the loss of the green-space and the provision of new housing will not lead to more flash flooding downstream, particularly as part of the site is in Flood Zone 3?
Any future planning application would be required to provide a full Flood Risk Assessment which would be required to identify and assess all forms of flooding to and from the site and demonstrate how these flood risks would be managed, taking into account the vulnerability of the site and the potential impact of climate change. In addition, an outline surface water and foul drainage strategy would be prepared which aims to ensure that there are no significant increases in flood risk.
Additionally, evidence of suitable mitigation measures for not only the site but to ensure nothing downstream is affected by the proposals would have to be provided. Any development would also need to embed from the start the principals of sustainable drainage design.
How will the masterplan address the loss of non-renewable resources including soil resources, natural habitats and the connectivity of the wider green infrastructure of the region?
The masterplan would look to retain and protect natural habitats at the site, including the semi-natural broadleaved woodland and watercourses. Opportunities would also be sought to strip and temporarily store topsoil from areas of woodland loss and used for establishing new woodland to be planted with native trees and shrubs that are characteristic to the local area.
The retained woodland could be enhanced by selective thinning/coppicing and planting of hazel and hawthorn to enhance its structural diversity and to increase their biodiversity value.
The culverted sections of watercourse could be removed to form open channels. Any watercourse diversions could have a sinuous alignment, soft banks with shelves stocked with plant species characteristic of the local area and large side pools. Swamp vegetation and silt could be removed from retained pools to create more open water and increase the biodiversity value. Connectivity with the wider green infrastructure of the region would be achieved by enhancing the woodland and watercourse habitats to further facilitate species dispersal across the site, adjacent residential areas and other parts of the River Tame Wildlife Corridor to the north and south.
What is Sandwell Council doing to bring empty homes back into use?
The council is currently reviewing our policy and processes for bringing empty homes back into use; we deploy a number of interventions from education and advice to enforcement. We will also consider purchasing empties to become part of our council housing stock. We are currently recruiting a dedicated and specialist Empty Property Officer who will lead on the development of our policy and practice in this area of work to maximise the number of empty homes brought back into use.
Why can't the whole site become a park?
We are aware of suggestions that the entire site should become an open space. Currently, the site is not fully accessible to the public, aside from two existing rights of way. This means local people are not able to make use of this disused golf course as they would other local parks.
We are proposing to create the first new public park in Sandwell's 48-year history, which requires significant investment, and will only be possible through the development of new homes. By bringing forward a mixed use for the site, we can deliver and maintain a park and associated amenities along with much needed affordable homes.
How will wildlife and trees on the site be protected?
We recognise how important the protection of local wildlife and habitats are to residents. As part of our work, we are committed to protecting the wildlife present on the site. Where possible, we will look to mitigate impacts, enhance existing habitats and create new habitats as part of this development.
We're currently undertaking a number of surveys on the site, and in the local area, to understand the wildlife and trees currently on the site so that this information can influence the layout of the masterplan.
The masterplan will show where trees are to be retained and where new trees should be planted. In accordance with planning policy, steps would need to be taken to mitigate the impact on any animals and birds using the site. Where possible, we will aim to enhance the landscape, including trees, as part of Brandhall Village.
How are you accounting for the wildlife on site?
We're currently undertaking a number of surveys on site to understand the wildlife present. These surveys are carried out by specialist ecologists in line with recognised standards and will inform the development of the masterplan and preparation of the Environmental Statement that we produce as part of the planning application.
How can I find the results of the surveys?
The results of surveys will be submitted as part of the planning application. All documents that form the Outline Planning Application will be publicly available once the application has been validated. The Planning Application, including an Environmental Statement, will be reviewed by independent specialists.
Would Parsons Hill Park be retained?
All masterplan options presented in the July 2022 Cabinet report retain Parsons Hill Park.
Why is Sandwell Council considering building on green space?
Brandhall Golf Course is currently classed as restricted because it is not fully accessible to the public. This means local people are not able to use this green space as they would other local parks. Now the golf course is formally closed, this provides an opportunity to consider opening part of the site to local people creating, a fully accessible public park. By doing this, we would be making green space more accessible in the community.
Why is Sandwell Council considering building houses on a greenfield site when there are brownfield sites available? What brownfield sites have been/are being considered for new homes? / How does this fit with West Midlands Combined Authority / Mayor's brownfield first commitment?
The council has a brownfield first policy, meaning that brownfield sites should be considered for development first. All large brownfield sites are already allocated for housing, meaning that housing development would be supported on these sites.
The issue with some of the brownfield sites is that they are not viable for homes because of land contamination. The council is working with the landowners of brownfield sites, where possible, to support them to bring the site forward for housing. The council is also working with partners to bring forward contaminated sites for housing development using grant funding from the West Midlands Combined Authority.
However, should the housing supply from all allocated sites be brought forward, which may not be possible, there would still be a shortfall in terms of the council's current targets for housing need. The development of greenfield sites does therefore need to be considered to meet this housing shortfall.
Has the council considered the flood risk on the site and how this could affect developing it for housing?
We recognise the concerns of the local community with regard to flooding in the local area and on the Brandhall Village site. If the site proceeds further, a Flood Risk Assessment and a Drainage Strategy that sets out any sustainable mitigation to potential flood risk would need to be developed.
Wouldn't a new park just encourage more anti-social behaviour?
We would ensure through the design, management and usage of the park that it provides the opportunity for people to engage in positive activities. We would work with our Anti-Social Behaviour teams to ensure that this has a positive impact on the local community.
How will the scheme impact on the health of local residents given green-space will be lost?
At present the site is not fully accessible to local people, with access restricted to two existing public rights of way. The development of Brandhall Village provides opportunity to create a large new, accessible public park which could create a variety of leisure and recreation opportunities to help improve health and wellbeing.
In addition, the masterplan would look to encourage active travel through the provision of attractive and convenient cycle paths and footways which would provide connections to surrounding communities and local amenities.
How does the proposed align, or otherwise, to the Council’s Green Space Strategy?
Brandhall Golf Course was classed as an ‘Outdoor Sports Facility’; therefore it was not classified as public open space. Access to the site by the general public was restricted although there are public rights of way that cross the site and afforded limited access to walk across the site.
As outlined in Sandwell’s Green Space Strategy, the golf course is excluded from the Unrestricted Green Space calculations for Sandwell. This, as well as the semi-private nature of the site, means that the site was not considered accessible green space in the strategy.