Comment

Draft Black Country Plan

Representation ID: 21725

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

Comment: WTBCC request that a point is added requiring all developments to retain or create a buffer of vegetation to each side of the canal corridor where this is appropriate to the historic environment. Canal corridors are a key component of the ecological network of the Black Country as evidenced in the Draft Local Nature Recovery Opportunity Map (Appendix 18 of the BCP). New developments should therefore be expected to retain and create both aquatic and terrestrial habitats and be discouraged from hard landscaping up to the canal edge.
2c
Comment: WTBCC request that stronger policy wording is included for the retention and restoration, or where absent the construction of sensitive, boundary treatments including walls and other structures associated with the historic environment (including those constructed of furnace slag, locally quarried stone and pre-1939 bricks).
2g
Comment: Whilst supporting the reinstatement and / or upgrading of towpaths and linking them into high quality wider pedestrian and cycle networks, WTBBC request that wording is added to this paragraph that states this should not be undertaken where valuable towpath habitats are lost. For example, the narrow strips of vegetation to each side of towpaths are a characteristic feature of the Black Country canal network. These frequently support a diverse and valuable assemblage of plant species associated with both aquatic and terrestrial habitats that is not found elsewhere in the Black Country. It is important that this habitat is retained.

3d
Comment: WTBCC request that stronger policy wording is included on the layout of new developments regarding providing active frontages onto the canal, stating that only in exceptional circumstances will side and rear boundaries be allowed to face the canal.