Comment

Representation ID: 23103

Received: 11/10/2021

Respondent: Canal & River Trust

Black Country Plan Regulation 18 consultation

Thank you for the opportunity to comment on the Draft Black Country Plan.


We are the charity who look after and bring to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our waterways and promoting their use we believe we can improve the wellbeing of our nation. The Trust is a statutory consultee in the Development Management process.

Our waterways do, or have the potential to, provide important areas for recreation, biodiversity, sustainable active transport (with related health and air quality benefit), business, tourism and a focal point for cultural activities. They are heritage assets. Waterways can also provide a resource that can be used to heat and cool buildings, a corridor in which new utilities infrastructure can be installed and a way of sustainably draining surface water away from new developments.

The Trust owns and manages approximately 150km of waterways within the Dudley, Sandwell, Walsall and
Wolverhampton local authority areas, including:


• The Old Main Line Canal
• The New Main Line Canal
• The Shropshire Union Canal
• The Staffordshire & Worcestershire Canal
• The Titford Canal
• The Wyrley & Essington Canal
• The Bradley Arm Canal
• The Wednesbury Old Canal
• The Walsall Canal
• The Rushall Canal
• The Daw End Canal
• The Dudley Number 1 Canal
• The Dudley Number 2 Canal
• The Stourbridge Canal



and proposed) with one another and to areas of open space and countryside. Canals have played a significant part in the development of the Black Country and they continue to be a valued social, economic and environmental asset, with even greater potential to support regeneration and the wellbeing of individuals and communities.

Over 70 per cent of the residents of the Black Country (approximately 850,00 people) live within a
They should be highly valued as accessible blue and green assets Making the waterways of the Black Country easier, safer and more attractive to visit should ensure that they can do even more to support the wellbeing of individuals and communities.

Our Towpath Count data shows a significant increase in use of towpaths in the Black Country since the first COVID-19 lockdown in Spring 2020, with sites in Sandwell experiencing nearly a 300% increase in average daily usage between 21 March 2020 and 5 July 2020. Where we have data available, usage remains higher now than it was pre-pandemic, significantly so in some locations. For example, average daily usage from
our Towpath Count data in Walsall was shown to have increased by approximately 100% compared to pre- pandemic levels. We are keen to build on this increased awareness of and appreciation for the canal network and the Black Country is a regional priority area for the Trust.

We note that the plan recognises that the Black Country performs worse than the England average with regards to risk factors for poor health outcomes that are linked to the built and natural environment. Within the Black Country 68% of households within 1km of a Trust waterway are classified as being deprived in one or more dimension waterways can play a valuable role in helping to tackle this through providing a space for healthier lifestyles,
community engagement and skills development.


Enhanced waterways form an important part of the vision for the development of the area and we believe that this can support many of the strategic objectives, including providing a built and natural environment that supports the making of healthier choices; protecting health and wellbeing; promoting sustainable and active travel; improving public realm; enhancing the natural environment and mitigating climate change.

Our comments on the Draft Black Country Plan are set out below. We focus first on policy ENV7 before considering other relevant policies and site allocations.