Comment

Representation ID: 21317

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1e
Comment: Whilst supporting that species that are legally protected, in decline, are rare within the Black Country or that are covered by national, regional, or local Biodiversity Action Plans will be protected as far as possible when development occurs, WTBBC request that ‘where possible’ be removed and replaced by a statement making clear the expectation of development with regards the protection of species. This could be achieved through a commitment to reviewing relevant Supplementary Planning Documents.
2
Comment: Whilst supporting that adequate information must be submitted with planning applications for proposals that may affect any designated site or important habitat, species, or geological feature, WTBCC request that the policy clearly state that a Local Site Assessment must be undertaken and submitted to the Local Sites Partnership where development is likely to impact upon a Site of Importance for Nature Conservation, Site of Local Importance for Nature Conservation or Potential Site of Importance.
Comment: Whilst supporting that adequate information must be submitted with planning applications for proposals that may affect any designated site or important habitat, species, or geological feature, WTBCC request that this point clearly states that supporting information must include a data search from the Local Environmental Records Centre for Birmingham and the Black Country (EcoRecord).
3
Comment: WTBBC request that clarification is provided in this point as to what would comprise strategic benefits of a development that clearly outweigh the importance of a local nature conservation site, species, habitat or geological feature. Furthermore, a clear statement that clarifies by what mechanism applications of this type will be assessed and what relevant stakeholders will be consulted should be provided.
4
Comment: WTBBC request that this point should clearly state that the Local Environmental Records Centre for Birmingham and the Black Country (EcoRecord) hold, collate and disseminate the definitive and up-to-date register of locally designated nature conservation sites on behalf of the BCA.
5
Comment: WTBBC request that an expectation that all canal and natural watercourse-side developments will deliver an improved and extended wildlife corridor for both wildlife and people be added to this point, and that this should be informed by the Black Country Local Nature Recovery Opportunity Map and Strategy as described in Policy ENV3.
6
Comment: WTBBC request that this point should clearly state that details of how improvements (appropriate to their location and scale) will contribute to the natural environment should be informed by the Black Country Local Nature Recovery Opportunity Map and Strategy as described in Policy ENV3, and that details of how this is to be achieved are provided in documents accompanying planning applications.