Comment

Representation ID: 15475

Received: 11/10/2021

Respondent: Natural England

Climate change policies

We welcome the climate change policies. We advise that the plan should go further and would be more robust if it looked at ways to adapt and mitigate for the consequences of climate change. ‘Nature-based solutions’, are essential to achieve this. These involve the restoration of ecosystems for the long-term benefit of people and nature. Examples include:

• Expansion of tree and woodland cover - to strengthen woodland habitat networks, protect soils, provide shade whilst capturing additional carbon from the atmosphere.
• Restoration and creation of priority habitats such as lowland heathland, lowland meadows, lowland fens and rush pastures. This improves places where people live and recreate, protecting carbon stores and strengthening the nature recovery network.
• Natural floodplain management, through the use of tree planting, habitat creation and restoration, to alleviate flooding further downstream.
• Retrofitting of green and blue infrastructure such as trees and sustainable urban drainage systems (SUDS) in urban localities to address flood risk and heat island effects.

Within your Plan we suggest you consider including the following actions:

1. Set an ambitious climate-specific policy with targets for reducing greenhouse gas emissions.
Plans should include a clear commitment to achieving the national statutory target of net zero emissions by 2050, with policies to secure significant reductions in greenhouse gas emissions over the Plan period;
2. Identify, protect and plan to restore all areas of peatland. Our mapping system shows that there are areas of peat in the Plan area within the northern Walsall area. Ideally any plan to restore
peatland, should wherever possible include management of the catchment areas that support the peatland. We would advise extending this approach to shallow peaty areas in addition to
deep peats.
3. Identify opportunities to increase tree and woodland cover consistent with the UK target.
Wherever possible, this should provide multi-functional benefits. Planting on peatlands and other open habitats must be avoided.
4. Identify areas where nature-based solutions can provide benefits to people whilst reducing
climate change vulnerability in the natural environment.
5. Identify habitats and protected sites that are particularly vulnerable to the impacts of climate change and consider how the planning system can work to reduce these vulnerabilities.

We advise that these actions are integrated into a strategic approach alongside green infrastructure, health and wellbeing, biodiversity net gain, natural flood management, air and water quality to deliver multifunctional benefits to people and wildlife. The Plan should make clear that development will be consistent with these policies, to ensure sustainable development is properly achieved across the Plan period. Meaningful targets should be set that can be appropriately monitored over the Plan period to
demonstrate the effectiveness of the Plan/Policy in addressing climate change and to ensure appropriate remedial action can be taken as necessary.

Further information on climate change resources can be found in Annex 2. Natural England would be happy to advise further on this aspect of the Local Plan development.