Object

Draft Black Country Plan

Representation ID: 14844

Received: 10/10/2021

Respondent: Alison Wilkes

Representation Summary:

Policy ENV1
1b
Object: Sites of Local Importance for Nature Conservation (SLINCs) should not be excluded from this point. The NPPF does not distinguish between types of designated Local Wildlife Sites and so there is no justification for this approach being taken in the BCP. In fact, the NPPF states that locally designated sites should be included in the identification, mapping and safeguarding of local wildlife-rich habitats and networks carried out by Local Plans.

Object: Sites of Local Importance for Nature Conservation (SLINCs) should not be excluded from this point. Defra Group guidance states that Local Wildlife Sites should be included in Core Areas of Local Recovery Maps. These sites are also included in the Nature Recovery Opportunity Map published as Appendix 18 of the BCP.

Comment: Nearby land-use and other changes can have a negative impact on sites, this should be reflected in the wording.

1c
Object: Sites of Local Importance for Nature Conservation (SLINCs) should not be included in this point. The NPPF does not distinguish between types of designated Local Wildlife Sites and so there is no justification for this approach being taken in the BCP. SLINCs should be included in 1b.

2
Comment: The policy should state that a Local Site Assessment must be carried out and submitted to the Local Sites Partnership where development is likely to impact a Site of Important for Nature Conservation, a Site of Local Importance for Nature Conservation or a Potential Site of Importance.

Comment: The policy should clearly state that supporting information must include a data search from the local Environmental Records Centre.