Comment

Draft Black Country Plan

Representation ID: 16556

Received: 11/10/2021

Respondent: Friends of the Earth Stourbridge

Representation Summary:

Environmental Transformation and Climate Change: (BC Plan pg. 201-295)
Dudley will be required soon to produce a Local Nature Recovery Strategy as part of
a requirement to meet biodiversity targets. Our Local Plan should aim to reduce
greenhouse gases, restore nature and increase resilience to extreme weather
events.
Dudley MBC should manage the land they own and have control over in a way that
helps nature and increases biodiversity such as managing roadside verges for
wildflowers, planting trees, developing meadows, preserving and increasing
designated nature reserves. The Council has a substantial role in deciding how land
is used in an area, particularly when it comes to the Local Plan. In this way Dudley
can make a significant contribution to nature restoration. The government's
Environment Bill places extra emphasis on the role of the local council in nature's
recovery.
The Local Plan needs to protect all wildlife in the area and ensure its abundance
across all rural, suburban and urban landscapes. This means ensuring that places
like nature reserves are not lost or damaged by development, but also aiming to
increase space for nature outside of designated nature reserves and biodiversity
hotspots. Creating networks of nature corridors for wildlife to move through can help
with this, as can protecting green open spaces and the green belt from
development. More and better access to nature and green spaces also has public
health benefits.
Dudley MBC needs to identify how nature can help mitigate against extreme
weather. For example, flood plains, wetlands and increased tree cover can act as
natural flood defences. Creating green open spaces and planting trees lowers
temperatures and so in built up areas can be effective in mitigating heat islands.
Dudley MBC can also integrate nature restoration into activities like grass cutting and
hedge trimming. Cutting grasses at the right time of year and in the right ways can
help wildflowers and associated wildlife thrive, while bad and untimely grass and
hedge management can set back ideal conditions for nature for years for example
the wildflower meadows currently in preparation at the 3 Fields, near the Roman
Road site in Stourbridge.
Only 7% of Dudley area, including greenbelt, has tree cover but Friends of the Earth
UK have identified an additional 62 hectares of land (1 hectare = a football pitch) in
the Borough which may be suitable for new woodlands. Some of these areas are
extensions of existing woods and green space such as Iverley, near Racecourse
Lane, opposite Norton Covert, Wychbury Hill, Gibbett Lane, Botts Farm, The Clump,
Mount Pleasant and Ridgehill Wood. More information can be found here.
https://takeclimateaction.uk/woodland-opportunity-mapping-england
We urge Dudley MBC to protect all greenbelt land carefully and to fully assess the
biodiversity impact of new development on brownfield sites as well as greenbelt.
Friends of the Earth Stourbridge: 11.10.21:
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We want Dudley to double tree cover on council-owned land, update local planning
strategies to significantly increase tree cover across the Local Authority area, and
ensure existing trees are properly protected in order to store carbon, support nature,
aid flood protection and deliver mental health benefits.
Dudley MBC should transition to organic weed management on council-owned land,
streets and verges by eliminating the use of herbicides such as glyphosate for weed
management. This will help to increase biodiversity and draw down carbon pollution.
It can provide a significant boost for pollinators and other wildlife to manage parks,
and other green spaces as well as grass verges with nature in mind. Development of
new meadows alongside other designated nature reserves would increase potential
for bio-diversity.
We would like to see Dudley’s Green Care produce a pollinator action plan as part of
their management strategy. They can also influence other land owners including
schools and colleges to manage their grounds for nature. By eliminating the use of
herbicides and pesticides in their parks, playgrounds, verges and green spaces to
protect residents’ health as well as help plant and wildlife.
Dudley MBC has limited green space and it must protect existing local green spaces,
the green belt and locally designated nature sites, and ensure public access to local
authority owned green spaces, including golf courses. Dudley needs new good
quality green spaces in areas which fall short of recommended minimum levels (2
hectares of green space within 5 minutes’ walk), particularly in areas where people
have less access to private gardens.
Dudley Borough has more than 6 neighbourhoods which are identified as deprived of
green space which is essential for physical and mental health. They are:
o Cradley West and the Hayes
o Cradley East
o Stourbridge Town and the Old Quarter
o Brierley Hill
o Kates Hill
o Upper Gornal and Ruiton
o Wordsley and Buckpool
o Dudley Town
o Russells Hall
This is again a matter of social justice. A Friends of the Earth study found that
persons of Black, Asian or minority ethnic (BAME) people are more than twice as
likely as a white person to live in areas in England that are most deprived of green
space. The research also found a correlation between income and green space
rating, although it is not as strong as for ethnicit