Comment
Draft Black Country Plan
Representation ID: 47041
Received: 13/09/2022
Respondent: HIMOR
Agent: Turley Associates
Policy ENV1 of the BCP seeks to ensure that development is not detrimental to the natural environment, and outlines a series of measures / tests to ensure that any development can have a measurable improvement to the natural environment.
Ecology Solution’s Biodiversity Technical Note (Appendix 5) sets out that the ecology work undertaken to date identifies limited potential for protected species at the site, and that there are not any overriding ecological constraints to development. Indeed our proposals can achieve a biodiversity net gain. The note also demonstrates that the Council’s proposal to designate the entire site as a Site of Important Nature Conservation (SINC) is not justified. The proposals can therefore be delivered without unacceptable impacts on biodiversity. We discuss this father at Section 4.