Comment

Representation ID: 22261

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

13 Sub-Areas and Site Allocations
Comment: WTBBC welcome the BCA’s use of the Site Assessment (selection) process and the evidence that has been collated for and used in this. Many sites put forward through the Call for Sites process where development would have been highly damaging for wildlife, landscape and communities have not been selected as a result of the implementation of this (notable examples are Seven Cornfields in Wolverhampton, the Dudley green belt to the south of Halesowen and numerous sites in the Walsall green belt). A number of sites have, however, been selected where evidence demonstrates they should not, or where significant considerations remain.
Comment: Due to the large number of allocations in the BCP it was necessary to develop a process to determine which sites WTBBC were able to submit evidence-based comments for. Our detailed response to the BCP’s policies provides information on how the remaining allocations should be managed through the planning system.
In summary, we have commented on or objected to sites:
• That the Site Assessment process should not have selected.
• Designated for nature conservation or adjoining these.
• Where a Local Sites Assessment should have been undertaken but has not.
• Of high value for ecological connectivity.
• Understood to be public open space.
Comment: WTBBC understands that any written submission will be transferred by the Black Country Authorities to their digital consultation database which has a 100 word limit per response. Each of our allocation responses has therefore been limited to 100 words. Additional details on our comments, evidence and analysis can be provided subsequent to the consultation deadline upon request. Furthermore, WTBBC are able to provide information regarding the specific development considerations of Strategic Allocations.
For each response given we have preceded this with either Support, Object or Comment as requested in the How to Comment section of the Black Country Plan website.