Comment

Draft Black Country Plan

Representation ID: 15298

Received: 11/10/2021

Respondent: Natural England

Representation Summary:

Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain
We welcome this policy. Nature Recovery Network
We advise including the Natural England’s Midlands Heathland Heartland partnership and the Purple
Horizons Nature Recovery Project within the policy. This project aims to create, enhance and connect up fragmented heathland habitat and other wildlife rich habitats between Cannock Chase and Sutton Park which will benefit local communities in escaping the urban environment to ‘recharge their internal resilience through nature’. The project will link and buffer existing sites while creating a network of further complementary habitats, while also providing new public access and recreational opportunities and health benefits. This links in with the government’s 25 Year Environment Plan and the Council aims to facilitate nature recovery networks. See Annex 1 for further information on the project.

Walsall council’s local sites receive high numbers of visitors and are in prominent places in the community so the project work provides an opportunity to demonstrate the approach that can be rolled out more widely into the future. The Purple Horizons heathland restoration work offers the council the opportunity to build on the works done to date by Walsall council who have gradually moved away from an intensively managed public open urban greenspace practice to a more biodiverse acid grassland
and heathland mosaic. These works will create important stepping-stones between protected sites that exist between Cannock Chase SAC and Sutton Park SSSI that include: Cannock Extension Canal
SAC/ SSSI, Jockey Fields SSSI, Clayhanger SSSI, Chasewater and The Southern Staffordshire
Coalfield Heaths SSSI, Sutton Park SSSI & NNR, Gentleshaw Common SSSI, Stubbers Green Bog
SSSI, Daw End Railway Cutting SSSI and Swan Pool and the Swag SSSI.

Barr Beacon Local Nature Reserve. This site offers significant heathland restoration opportunities as part of the Local Nature Recovery Strategy for the area. Natural England’s national recovery area project – Purple Horizons has identified Barr Beacon Local Nature Reserve as a site that should be doubled in size to accommodate new heathland and species rich habitat mosaics to be created.

Biodiversity Net Gain

In regards to net gain, we would advise that you include add the following within the policy:

• It needs to be clear within the policy that biodiversity net gain is not applied to irreplaceable habitats and it should also be made clear that any mitigation and/or compensation requirements for European sites should be dealt with separately from biodiversity net gain provision.
• The policy should set out how biodiversity net gain will be delivered and managed through the lifetime of the scheme.
• Requirements to monitor biodiversity net gain should be included within the policy. This should include indicators to demonstrate the amount and type of gain provided through development.
The indicators should be as specific as possible to help build an evidence base to take forward
for future reviews of the plan, for example the total number and type of biodiversity units created, the number of developments achieving biodiversity net gains and a record of on-site and off-site contributions.

Please note that The Biodiversity Metric 3.0 is now available and replaces the beta Biodiversity Metric
2.0 (JP029) published in 2019. We would advise updating the policy accordingly.