Object

Representation ID: 18575

Received: 11/10/2021

Respondent: Dudley Labour Group

Agent: Councillor Qadar Zada

Nature conservation and other environmental considerations


The UK is one of the most nature depleted countries in Europe and very recently, environmental experts have reiterated their concerns that the continuing loss of biodiversity in the UK is at crisis point and that expanding towns and cities through house building and road construction will exacerbate an evolving problem.


One of the stated aims of the BCP is to use the opportunity that additional housing provides to improve the environment. Given the views of experts on the causes of the loss of biodiversity, it is not certain how this is possible. Even the language used in the plan suggests one of
mitigation rather than improvement. For example, in reference to green belt development, the Black County Authorities have agreed a policy of
‘least harm’.

There are also several unanswered questions relating to trees with protection orders and if felled to make way for development, where they will be alternatively planted and the impact on habitats that could be destroyed at or near to the affected sites. In the case of several sites, it is obvious from the RAG rated assessments for each site, that in many cases, the assessment of the biodiversity at them is incomplete and therefore, these sites should not have been put forward. There is also reference to the Fens Pool Nature Reserve, an SSSI site at the heart of the borough, which is not proposed for development but is referred to in the context of the uncertainty that development of the borough will have on biodiversity at this site. This is of great concern for a site which is of significance to an area with pockets of high deprivation including poor health and for which there are plans to introduce a wildlife corridor and eventually attract green flag status to provide biodiversity and regeneration as a visitor attraction.