Comment

Representation ID: 23105

Received: 11/10/2021

Respondent: Canal & River Trust

Policy ENV7


The Trust strongly welcomes the inclusion of a canal specific policy within the Black Country Plan. We believe that this is more than justified, given the important contribution that canals make to the area. This should be protected and the opportunities for them to support ongoing economic, social and environmental regeneration maximised.

Our comments on the proposed policy and additional issues that we believe should be considered by policy ENV7 are set out below:

Black Country Canals Strategy


The Trust and the four Black Country Authorities have agreed that a Black Country Canals Strategy should be developed to bring together the wide range of existing initiatives and opportunities that exist to improve the canal network and its environment. We suggest that this should be referenced in policy ENV7 or its supporting text and that, where relevant, development proposals should have regard to it.

Creating great waterway places

Great waterway places require a positive relationship between the canal network and its surroundings. The Trust welcomes part 1 of policy ENV7 that defines the canal network as including their surrounding landscape corridors, designated and undesignated historic assets, character, settings, views and interrelationships .

The Trust supports the requirements of parts (2)(c), (2)(e), (3)(d) and (3)(e), which seek to protect and enhance historic significance; protect and enhance visual amenity, views and settings; promote high quality design; provide active frontages; improve public realm and integrate canal features. We also support (3)(a) providing opportunities for leisure, recreation and tourism. These are important aspects of creating great waterway places.

We also welcome parts 2(d), 2(f) and 3(c) which seek to ensure that the ecological value and water quality of the canal network is protected and enhanced through new development.

Development adjacent to the canal network in parts of the Black Country has not always met the standards for the built and natural environment that are expected under this policy. At present, no monitoring indicators are proposed for policy ENV7 and we suggest that this is reconsidered with a view to identifying an effective means of monitoring how the policy is delivering great waterway places.

In appropriate locations, we suggest that buffers alongside canals and/or buffers alongside existing canalside vegetation may be needed to deliver the environmental aims of this policy by reducing human disturbance of established habitat, reducing the concentration of contaminants in surface water run-off and mitigating the adverse impacts of artificial lighting on canal corridors.


The Trust has an aspiration to develop a ‘Great Canal Orchard’ between Wolverhampton and Worcester.
The aim is to see a resilient fruit tree planted approximately every 30m along the canal network. We believe that this would benefit local biodiversity, promote a greater community interest in reducing food miles and provide a further incentive for communities to engage with their local waterway. We would welcome recognition of this within the supporting text to policy ENV7 and encouragement for developers to consider opportunities to support the scheme, consistent with parts 2(d), 3(a) and 3(c) of the policy. We suggest that this is in keeping with para 131 of the NPPF.