Comment

Representation ID: 23108

Received: 11/10/2021

Respondent: Canal & River Trust

Restoration

Canal restoration projects can bring a wide range of environmental, social and economic benefits for a local area and can be catalysts for redevelopment and regeneration. The Trust supports canal restoration being
considered in draft policy ENV7 and it is welcomed that, where appropriate, development will be expected to protect the line of the historic canal.

However, we question how practical and appropriate it is for decision makers on individual planning applications to assess whether there is a realistic possibility of the restoration of a canal wholly or in part. This requires an element of individual judgement, which opens up the possibility of inconsistency in approach. Such judgements will also be influenced to a significant degree by how far into the future the decision maker looks when considering what is realistic. In this context, it is concerning that para 10.103 appears to suggest that support for some canal restoration schemes should be limited because, amongst other things, some are not expected to be achievable within the plan period. As they are not allocations, we see no justification for why only restoration schemes that can be completed in the plan period should be safeguarded and it should be made clear in the plan that canal restoration routes are safeguarded for the plan period and beyond. We suggest that future reviews of the Black Country Plan should consider whether there is a realistic possibility of the restoration of a canal and that routes should be safeguarded until a review concludes that there is not one. This should not be left to decision makers on individual planning applications.

The policy could more positively support restoration by setting out an expectation that development that comes forward on sites that include sections of disused canals treat these sections as important areas of green infrastructure to be integrated into the development. Positive consideration should be given to re- watering sections in the interests of nature and heritage conservation (even if navigation is not possible in the short/medium term) and developing walking and cycling routes alongside the waterbodies. We understand that the IWA has identified a number of proposed allocations that may benefit from such an approach. Paragraph 10.102 of the plan offers some support for treating canal restoration schemes as green/blue infrastructure opportunities within development sites but we suggest that it would be appropriate to add this to the policy.

We agree that issues such as the environmental value of waterbodies, the availability of water supplies and the impact on the functioning and environment of the existing canal network must be considered in any planning application to bring forward a restoration scheme (para 10.105). However, we suggest that policy ENV7 should be amended to make it clear that there is support in principle for canal restoration, subject to these considerations (and any local factors that might be appropriate). At present, the policy is not positively prepared when it comes to the delivery of canal restoration schemes.

The line of the disused Hatherton Branch Canal is identified on the existing Black Country Core Strategy Key Diagram. It is proposed that the Black Country Plan will not refer to the Hatherton Branch Canal or show it on the Key Diagram(s) because it is included within the Walsall Site Allocations Document. This position seems to be at odds with the general approach that has been taken in preparing the Black Country Plan, with its greater focus on site allocations and designations. We suggest that canal restoration is an issue that requires cross-boundary co-operation and is a strategic issue (as explained in our response to the Issues and Options Report). As such, specific schemes warrant greater consideration in the Black Country Plan.

Between now and the publication of the regulation 19 draft plan in Summer 2022, we suggest that further engagement is required to consider the restoration schemes that should be covered by the plan and the most appropriate means of supporting them. Within this, we suggest that reference should be made to the Bradley Canal restoration, linking the Birmingham Main Line Canal with the Walsall Canal; the Lapal Canal and the Stourbridge Canal (Fens Branch).