Comment

Draft Black Country Plan

Representation ID: 23152

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

Representation Summary:

We strongly support statements and policies of this section of the plan.

Accessible natural and cultural heritage, used for the benefit of the environment, residents and visitors to the Black Country and international promotion of this area a s a global heritage destination is the core purpose of the Geopark.

In paragraph 10.6 the Geopark Policy (ENV 6). should be named

In paragraph 10.13 the word geodiversity should be added as these policies and practices have also benefited geodiversity outcomes too.

Within the context of policy ENV 4, we are aware that Ash dieback disease is beginning to take hold in parts of the Black Country where significant stands of Ash trees are present. Is it important to have a bullet point that relates to such natural factors that may result in significant changes in tree cover, that whilst not development or refurbishment consequences per se, can significantly affect landscape character?.

We particularly welcome the sub section of the Environment chapter on the Geodiversity and the Geopark and support its policy and statements.

We would recommend a slight amendment to the wording of introductory paragraph 10.86 to include the international important fossil heritage of the Black Country. We suggest replacing the wording with

‘The geology of the Black Country is very rich in industrial minerals. Limestone, ironstone, fireclay, coal and other industrial minerals provided the ingredients to make iron and paved the way for an intense and very early part of the Industrial Revolution to begin in the area. The rock layers of the Black Country are also internationally important because of the exceptionally preserved and diverse fossils that they contain.’

Paragraph 10.98 has a typo and requires the date to read 2020.

Many geodiversity gains are from short-lived geological exosures of rocks in excavations during earthworks for various development sites. It would be very useful to include a similar bullet point to that used in ENV 7 for canals. i.e.

‘Where a proposed development may temporarily uncover geological features or rock layers then the developer must permit access to the site to record, and sample such layers or features as may be exposed working with site staff and programmes as appropriate’

We concur with the statements and support policy that encourages high-quality urban design, and particularly agree with the statement in paragraph 10.121 that ‘High-quality design will help to stimulate economic, social and environmental benefits, including ensuring that new homes and other buildings are designed and built to help to mitigate and minimise climate change impacts. Ensuring good design is embedded across the Black Country will help support regeneration and the delivery of an inclusive and robust economy, attracting people and businesses to both relocate to and remain in the area’

We generically support policies CC1 to CC7 and statements relating to Climate change mitigation in the plan.