Comment
Draft Black Country Plan
Representation ID: 15478
Received: 11/10/2021
Respondent: Natural England
Minerals polices
We note that some of the mineral safeguarding areas overlap with where our mapping records show that there are deep peaty soils. We advise that included within an appropriate policy, it should recognise the existence of peaty soils within the safeguarding areas and the importance of peats (and other organic rich soils) to ensure that they are appropriately managed when development takes place. This can be achieved by including in the policy the requirement to adhere to the Defra’s Code for the Sustainable Use of Soil on Construction Sites, which requires soil resource surveys to identify what soils are on site (including peats, low nutrient soils etc) prior to development taking place so that the design of the development and soil management plans (which feed in to Construction Environmental Management Plans) can take appropriate account of them. We would also advise that the following guidance is included within the relevant policies: Defra Good Practice Guide for Handling Soils and Defra Guidance for Successful Reclamation of Mineral and Waste sites.