Comment

Representation ID: 17112

Received: 11/10/2021

Respondent: Tarmac Trading Ltd (Sharne Sahajpal)

Agent: Heatons

The BCP acknowledges the Environment Bill, with particular regard to the requirement for 10% uplift in habitat quality where sites are being developed. Policy ENV3 of the BCP focuses on the plans ‘Nature Recovery Network and Biodiversity Net Gain’, stating in Point 2, the need for all development to deliver a minimum of 10% net gain in biodiversity value when measured against baseline site information. Point 5a and 7 of this policy is of particular pertinence to the purpose of this letter; they read:
“5) Biodiversity net gain shall be provided in line with the following principles:
a) A preference for on-site habitat provision / enhancement wherever practicable, followed by improvements to sites within the local area; and then other sites elsewhere within the Black Country;
7) Compensation will only be accepted in exceptional circumstances. Provision of off-site compensation should not replace or adversely impact on existing alternative / valuable habitats in those locations and should be provided prior to development”
THE SITE’S ROLE IN BIODIVERSITY BENEFITS
As stated above, the BCP aims to deliver 47,837 homes and 355Ha of employment land within the Black Country. The Sandwell Draft Policies Map and the Dudley Draft Policies Map illustrates the proposed housing allocations under Policy HOU1 of the BCP. From reviewing the BCP and the draft Policies Maps, we found that within a 2km radius from the centre of our client’s site, there are 11 housing allocations, stretched across the authorities of Sandwell and Dudley. These allocations total a potential housing delivery of 1095 homes across the plan period. The closest of these sites being the former Edwin Richards Quarry (SAH100) with capacity for 281 homes, and an indicative delivery timescale of 2026-2032.
Considering the emerging legislation in relation to biodiversity net gain, and the extensive level of growth required within the emerging plan period, it is considered reasonable to assume that there will be a requirement for off-site compensation to be achieved in coordination with new development.
A description of the site and its history is provided at the beginning of this letter. Our client seeks to promote this site for biodiversity off-setting in accordance with the emerging legislation set out above. Promotion of the site for biodiversity enhancement is considered to support the environmental objectives of the district and county council, particularly in relation to Policy ENV3 of the emerging BCP.