Object
Draft Black Country Plan
Representation ID: 19208
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
4 Infrastructure & Delivery
Delivery Constraints
4.6
Object: WTBBC object to the term brownfield-first being used in the BCP. This suggests all land previously occupied by a permanent structure is low value with regards ecosystem services. In the Black Country many sites of high aesthetic, wildlife or health and wellbeing value are post-industrial or have been previously occupied by a structure. The NPPF is clear in its definition of previously developed land that this excludes sites ‘where the remains of the permanent structure or fixed surface structure have blended into the landscape’. This term is widely understood and should be used in place of brownfield throughout the BCP.