Comment

Draft Black Country Plan

Representation ID: 21482

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Representation Summary:

Policy ENV1 – Nature Conservation

6.1. The aims of the Plan in seeking to safeguard nature conservation are supported in principle, however it is important that this is balanced with the need to deliver appropriate levels of

development within the Plan area. Where sites are recognised as being of value for nature conservation purposes, it is important that the protection afforded to them reflects the level of significance. This should not necessarily restrict the potential for any development to be accommodated in close proximity or within designated areas, if it can be suitably demonstrated through the site selection and/or planning application process that any harm to the protected site would be mitigated as part of the development.

6.2. In the case of land at Corbett Hospital, it is noted that the site is designated as a Site of Local Importance for Nature Conservation (SLINC). However, the emerging Policy ENV1 does not seek to prevent entirely any development that may affect such designations, however seeks to protect such sites from development proposals that could negatively impact them. It is important therefore that when applying the policy, the authorities do not seek to restrict proposals that otherwise would deliver sustainable development, but instead works with applicants or developers in order to facilitate development that could deliver housing (or commercial uses) alongside potential enhancements to such features.

6.3. Policy ENV1 recognises that there may be circumstances where ‘strategic benefits of a development clearly outweigh the importance of a local nature conservation site… damage must be minimised’. It is considered that this should include recognition of the significant benefits that delivering housing development within the urban area would deliver, in particular where there would also be enhancements delivered to the designated site. This is particularly important due to the scale of housing shortfall anticipated, and the need therefore to ensure that all opportunities to deliver housing in appropriate locations can be realised.