Comment

Representation ID: 23158

Received: 11/10/2021

Respondent: Environment Agency

The Environment Agency is working with Sustainability West Midlands on a West Midlands Climate Change Action Plan and Risk Assessment with the intention of publishing these in November 2021. The documents will set out a series of climate change adaptation actions that should be considered for implementation by decision makers in the West Midlands, to ensure that our natural environment, people, infrastructure, buildings and businesses are prepared for the impacts of climate change, including greater incidence and severity of flooding, a higher likelihood of water scarcity and more intense and prolonged heatwaves.

We recommend further emphasis on blue-green infrastructure and corridors as they provide multiple benefits to areas including services such as creating habitats, flood management provision, green space, cooling local temperatures, ecological function and amenity. All developments should create space for water by restoring floodplains and contributing towards blue-green infrastructure. Consequently, blue-green corridors need to be afforded high level of protection from encroaching development in order to facilitate their function, particularly when considering the impacts and need for extra capacity within watercourse corridors due to climate change. Green spaces can be designed to be less formal areas with more semi-natural habitats. This will reduce maintenance costs and provide better biodiversity and water management potential in relation to the impacts of climate change. Habitat connectivity will be particularly important in relation to climate change as species will need to be able to move more freely as environmental changes take place.

Our comments on contaminated land relate solely to the protection of controlled waters. In considering the baseline information and key sustainability issues to be considered
as part of the Local Plan, land quality and groundwater quality should be also be considered together with surface water impacts. The protection and enhancement of controlled waters via the planning regime and the redevelopment of contaminated land is encouraged as it provides an opportunity to remove areas of contamination that would otherwise continue to present a risk to our environment, controlled waters and human health.
The Black Country is largely made up of Carboniferous Coal Measures strata designated as Secondary A aquifers. Secondary A Aquifers comprise permeable layers that can support local water supplies, and may form an important source of base flow to rivers. The area also contains some more important Principal sandstone aquifers towards the eastern side. Principle Aquifers are layers of rock or drift deposits that have high intergranular and/or fracture permeability - meaning they usually provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. There are also several groundwater Source Protection Zones designated towards the east of the area covered by the Local Plan, these include designation for public drinking water supply. There are also numerous surface waters bodies within the area covered by the Local Plan.

We recommend there should be specific references to the hydrogeological environment and especially to issues such as groundwater and surface water protection (quality and quantity), contaminated land assessment (and clean-up where needed) and indeed the legislative drivers underpinning all this, such as Environmental Permitting Regulations and Water Framework Directive.