Comment

Representation ID: 22356

Received: 11/10/2021

Respondent: Canal & River Trust

Policy ENV2 is intended to apply to development affecting Special Areas of Conservation. At present this policy only considers Cannock Chase SAC. Paragraphs 10.26 to 10.29 explain that the Fens Pools and Cannock Extension Canal SACs require further consideration. As the owner of these assets and an organisation with knowledge and expertise to provide, the Trust would welcome further engagement with the Black Country Authorities and its consultants in the preparation of the further evidence that has been identified as required. We would welcome the opportunity to review the updated Habitats Regulations Screening Assessment and draft policy ENV2 prior to publication of the draft plan.

We note that para 10.27 states that the Fens Pools SAC is sensitive to changes in air quality and vulnerable to water pollution and that further evidence on air quality impacts is required. We suggest that Fens Pools is also sensitive to recreational pressure. All of these impacts should be considered as part of the evidence base for the plan and policies should be developed accordingly.

Para 10.29 states that air quality has been identified as a threat to the Cannock Extension Canal SAC. The site is also sensitive to water pollution and the potential for this should be considered alongside air quality in the evidence base for the plan and policies should be developed accordingly.