1 Introduction

Object

Representation ID: 21403

Received: 11/10/2021

Respondent: Mr Sandra Wickson

Hi
Yes please record my comments as representation.
Again this looks like another case of citizens who work hard, invest in their own home, getting penalised!
Please also record, I feel administration of this consultation process is extremely poor, considering the consultation period started 16th August, how come we residents directly adjacent to the proposed site only found out on Tuesday 28th September and then only by the actions of a fellow resident taking the trouble to print off a plan and post to us with a covering letter!
We were unaware of the drop in events, again until advised by a local councillor, on speaking to planning officials at the 30/09/21 Brownhills drop in, my husband was told Walsall Council’s policy on face to face meetings had meant the drop in sessions had been delayed, in my opinion the closing date for the consultation period should be extended to reflect the delay in Walsall Council’s face to face meetings.
I understand there have been advertising on buses, interesting media considering everyone has been avoiding public transport because of COVID-19, also on social media, let’s be fair advertising is targeted as suits the advertisers, I have no doubt if searched for it could be found, that doesn’t mean thee item is widely advertised.

Thank You
Sandra Wickson
M&S

EMAIL FROM BLACK COUNTRY PLAN TEAM
Sandra,
"Thank you for your comments.
The loss of view is not a material planning consideration. However, I will still record
your comments as a representation if you wish?
This is to confirm that we have received your representations to the Black Country
Plan consultation. Your comments will be taken into account as we move to the next stage of the Plan preparation (Publication Plan), which we will publish for a further
consultation in summer 2022.
Kind regards, Black Country Plan Team"


I live in Shire Lea, this site is DIRECTLY adjacent to my garden, below is the view
from no less than 55 homes along Chester Road and Shire Lea WS8 6NZ I thought
loss of view was an important consideration for planning applications?
>
> This development will impact immensely on the lives of 55+ households on the loss
of view grounds alone.

Object

Representation ID: 21406

Received: 13/01/2022

Respondent: Miss Sarah Brettle

I’m objecting this draft for the following reasons:

1. Highway safety
2. Wildlife and conservation
3. Noise
4. Loss of natural light.
5 loss of privacy and being overlooked by
6. More traffic on a small road
7. Design appearance and materials
8. Parking problems
9. Increase in pollution with more traffic

Object

Representation ID: 21409

Received: 11/10/2021

Respondent: Ms Sarah Connor

Firstly the whole consultation process is flawed & discriminatory, it seems the residents surrounding these areas who this would have great impact on & of no financial gain, have been deliberately left in the dark.

The green belt land as per the national planning policy framework document on the goverment site section 13 paragraphs 137 - 138 state the importance of the greenbelt & keeping them that way. There are plenty of brown field sites across the region that could be built on before destroying the small areas of countryside we have left in this area. These greenfields are natural habitats for lots of different species of wildlife, we have, various insects & birds & wild floweres, once gone these can't be replaced!!

The local infrastructure would collapse if these areas were built on, the local services just wouldn't cope, the doctors surgeries & schools are at breaking point now. There would be higher risk of flooding where I live, as the land acts as a soak away at the moment, build on it & I can see my property & others flooding in the future. There would be far more traffic on the roads, all this at a time where global warming issues are highlighted daily & you want to add more emissions. Peoples health would genuinely suffer from this both mentally & phsyically.

The area around the beacon is full of history, the small printing hut on the Aldridge rd is a listed building. Why do you want areas to merge into one another because this is what will happen, no green spaces left just areas of concrete, it just seems funny how the conservation bounderies have conviently been moved!!! so that tells me it's a done deal!!!

I feel truly sorry for future generations they'll have no countryside left!!

Object

Representation ID: 21426

Received: 11/10/2021

Respondent: Mr Scott Maplass

I'm extremely shocked and concerned as to the nature of this venture. The areas in which you are planning these developments is green belt land, supposed protected land and that is being thrown out of the window to complete a monsterous development which will wipe out homes and half the landscape utilsed by the wildlife across the area. The deciding factors are obvioulsy driven by money and greed rather than "the need for more housing" . From a personal perspective we use the public trails through this land for exercise, dog walking, educating our children about the wildlife and have built many special memories during our time living in the area, if this "plan" goes ahead it will destroy the possibility of creating new family memories as the majority of the area surrounding us will become a building site just to line someones pocket.

Object

Representation ID: 21442

Received: 11/10/2021

Respondent: Mrs Sharon Cotton

Myself and the others in my household are very concerned about all of the building proposals, the amount of houses it is suggested may be built in the area makes me wonder how the roads and various facilities will cope with such increased pressure, I think it will make a very bad situation worse. I understand the need for more houses, but worry that the houses built will be out of the financial reach of a lot of people anyway, especially the local young people. I am very against the use of green areas unless absolutely necessary because of the impact on wildlife and people's mental health, we need green spaces in busy areas such as this. Having lived in the area all my life, it really saddens me to think the green belt may be lost.

Object

Representation ID: 21444

Received: 07/10/2021

Respondent: Mr Stephen Parr

Tanhouse Road
I knew nothing about this plan until a few days ago when I received a newsletter called Focus issued by the Lib Dems. It mentioned a green belt site they named as Tanhouse Playing Fields which is listed as a site for possible house building . ....
The newsletter said that the end date for consultation is 11.10.21. I have not received any information about these plans from any source: nothing from Sandwell Council, nothing from local councillors , nothing in the newspapers until this week when the Express & Star carried a 2 page story.
I would appreciate an explanation. I have also contacted my MP Nicola Roberts and Mayor Andy Street about this matter.

Object

Representation ID: 21447

Received: 11/10/2021

Respondent: Shaun Stuart

I think more should be done to redevelop brownfield sites and explore other options, before taking the decision to build in green belt areas.

Object

Representation ID: 21456

Received: 11/10/2021

Respondent: Cllr Lorna Rattigan

In reading the information in the Black Country Plan booklet, it is not clear where all the 32 proposed sites are, as the map supplied is not easy to see exactly where they are, especially for residents within this ward and especially if they are not aware by reading the document or do not have access to online resources. My initial impression in reading the booklet is that the bigger sites that are highlighted and named on the opposite page of the booklet are the main focused sites. In addition there are a couple of mistakes with exact locations of these as well eg Coronation Road and Mob Lane, which affects primarily residents in Pelsall and Shelfield, as well as Aldridge North. However, I have been told that the named sites are just a selection from the 32 proposed sites. This is not clear and for the next consultation I would like to see all proposed sites more evident for each individual ward area, by using bigger and localised ward maps in the booklet. In addition to more broad casting of planning consultations, targeting residents who will be affected
by proposed sites, by sending out letters as is the process on current planning items as well as notifying local councillors for the particular wards.

Object

Representation ID: 21464

Received: 11/10/2021

Respondent: Mr Stephen Ball

Firstly I did not receive the consultation plan till 01/10/21, which gives limited time for to investigate in detail of the proposed plan, and further more the map is of poor quality so as to render it obscure. Why?
Having been a resident in the borough of Walsall for nearly 72 years this is nothing unusual having lived through, open cast mining, north relief toll road,etc. I would be surprised if any constructive objections or comments were considered, but it allows a mere conscientious citizen the satisfaction to speak his mind in a rational way and feel proud of the fact that I can. To keep a copy for my grandchildren to show how much I cared enough for the future they will have to endure when I am gone.
My first and importantly is:-
Using green belt and quality farmland to expand the housing needs for future generations has always been an issue to resolve by local councils, and put the infrastructure in place to prevent flooding in risk areas and on unstable ground like where old mining work subsidence is fairly common, (Coppice Farm for example) but to allow building in such areas is still being witnessed today in neighbouring local areas. Why?
Secondly will there be enough social stucture to the plan? Quality and good education, healthcare like doctors surgeries, waste management, meaningful well paid empoyment and traffic control, because if not history shows that poverty follows these inadequecies, and there is a lot of these places in the borough of Walsall. Again, why?
It is well documented there is a problem with global warming, but what you are propoing is directly adding to that issue? Taking away ANY established green areas with ancient trees and the biodiversity that goes with it is wrong and uncopromising, as when it has gone it has gone forever. Why not recycle redundant and vacant industrial sites, or use empty highstreet shops or offices for residency there is enough of them around to convert. Compulsary purchase orders of residential properties for industrial projects is ok for government and councils, which causes misery to some, so why not use the same criteria or idea for redundant commercial properties as most of the physical infrastructure of water, power,and waste is already there?
I would not consider building a residency on my land if I did not have a guaranteed customer with proven means to buy it. Imporantly nor would I spend someone elses unsecured money to do the same, so why spend already overburdened local tax payers money like that? It is immoral, and unjustifiable.

Object

Representation ID: 21465

Received: 11/10/2021

Respondent: Lower Penn Preservation Group

I'm raising an objection on behalf of Lower Penn Preservation Group about the use of greenbelt land in this plan. Brownfield sites should be the major focus of the plan for future developments, as recently stated both by the West Midlands mayor and the prime minister.

Duty to Cooperate:

The Black Country Plan should focus its efforts on using brownfield sites within its authorities rather than exporting its requirements to South Staffordshire. As South Staffs is 80% green belt, this in effect forces them to use their green belt to meet the Black Country requirements (4000 houses) under the duty to cooperate.
(Draft Black Country Plan - Policy CSP1 – Development Strategy- Section 3.20 page 31)

Thus the Black Country responsibilities relating to the sustainability of any developments is being sidestepped by pushing green belt development onto neighbouring authorities. The Black Country sustainability appraisal actually states that the sustainability impacts of exporting development to neighbouring authorities has not been considered by them.
(Black Country Sustainability Appraisal – Section 1.4.4 page 5)

The group believes that more up to date modelling of use of urban spaces will give a more accurate view of housing demand and potential release of space for residential use following the Covid pandemic. This will allow more protection to be afforded to the natural environment in the green belt areas both within the Black Country authorites and within the neighbouring authorities.

Names and addresses of the members of our group that support these statements are attached below.

Comment

Representation ID: 21529

Received: 11/10/2021

Respondent: Angela Duffill

It’s claimed that there are exceptional circumstances now regarding the need for housing and commercial premises. I believe that there is no justification for removing the protection on greenbelt and greenfield land. It can never be replaced as a source of pleasure, and physical and mental wellbeing for the community. It is not sustainable to build on our countryside, resulting in
loss of farmland, natural habitat for wild life, hedgerows and trees.

There are many brownfield sites that remain unused because builders prefer new, easy to develop sites that bring greater profits. The homes built on these greenfield sites are not affordable for most people. More recently many shops and offices are closing whose sites would provide extra capacity for homes in towns and cities which are in need of revival and redevelopment.
Large developments on the edge of our communities bring extra traffic to roads that are already over busy, and extra pressure on local services such as schools and health centres. This lowers the quality of life for the existing population and brings the same problems for new residents that they may not have anticipated. I do not support any loss of green space, greenbelt land or
greenfield land.

Support

Representation ID: 21635

Received: 08/10/2021

Respondent: Spitfire Homes

Agent: JLL

[General]

In principle, we support the policies contained within the Draft Black Country Plan and the allocations, subject to the changes to the details contained within this letter.

Comment

Representation ID: 21837

Received: 11/10/2021

Respondent: Dudley Access Forum

Members raised concerns regarding the eight-week consultation period between August to October and
whether this would be a sufficient amount of time for residents and stakeholders to put forward their queries and concerns.

Comment

Representation ID: 21992

Received: 10/10/2021

Respondent: Mrs Patricia Boulton

I live on the [redacted] but I have not received any notification on these plans except one of the neighbours put a few pages in my letter box, but everybody I speak to have had brochure a letter, so at the moment I don't know what is happening about our side of the A5 regarding these plans could you send me some information please.

Comment

Representation ID: 22051

Received: 11/10/2021

Respondent: Ms Jan Norton

The plan to develop a Borough requires a broad consensus, through meaningful consultation, and
the support of local communities. The process which sits behind the Plan has the potential to be divisive and rides roughshod over feelings of people in the community, potential to tear up precious green spaces and work against the direction we should be going in to respond to the climate emergency.

Object

Representation ID: 22055

Received: 11/10/2021

Respondent: Mr Neale Fellows

The whole development
Loss of green belt and impact on wild life and the environment.
Effect on local roads, in rush hour it can take over 30 minutes to do a few miles also no railway services in local area.
Effects on local services doctors, dentists, schools, hospitals.
We currently have to many people in the area.

Object

Representation ID: 22064

Received: 08/10/2021

Respondent: Mr Neale Aston

Can I first ask why this form was not received at my household until 1/10/21? This consultation has been running since 16/8/21. Was it a managed restriction on response time? I have asked for an extension to the 11th October 2021 date.

Support

Representation ID: 22072

Received: 11/10/2021

Respondent: Kinver Parish Council

Planning and Compulsory Purchase Act 2004
Town and Country Planning (Local Planning) Regulations 2012
Black Country Plan Consultation – Regulation 18 Response of Kinver Parish Council

We are writing in response to the proposed Black Country Plan, Regulation 18 consultation.

In general, we welcome the Local Plan, which sets out a planning framework for the entire Black Country. We support most of the policies relevant to rural areas such as Kinver and the edge of the Black Country, but do have reservations about some of the proposed allocations and potential policy implications in the wider area. Our concerns are set out in this letter.

Comment

Representation ID: 22182

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

[Comments Form/ Consultation approach]

Attached to this letter at Appendix 2 are the consultation Comments Form with Sections 1 and 3 complete. The remainder of this letter sets out our response to Section 2 – Your Representation/Comments. This approach has been adopted as there is insufficient space within Section 2 of the Comments Form to provide a full response.

Object

Representation ID: 22302

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

Sustainability Appraisal

2.62 Chapter 3 of the ‘Sustainability Appraisal of the Black Country Plan’ (Lepus Consulting, July2021) (‘the SA’) sets out the various housing growth options assessed in sustainability terms. Table 3.1 of the SA outlines the five housing options subjected to the appraisal, as replicated below.
Table 2.4 Sustainability Appraisal Housing Options (May 2021) [see PDF of representation] Source: Sustainability Appraisal of the Black Country Plan (Lepus Consulting, July 2021) Table 3.1
2.63 Although the BCP Preferred Approach (Chapter 3.5) does not actually confirm the BCA’s preferred housing growth option, the Executive Summary confirms that the BCP “proposes a strategy that is most closely aligned with Option 5” (page vii).
2.64 There is seemingly no rationale or justification for the five housing options appraised, other than that “the four authorities developed five housing number and five employment number options to be subject to sustainability appraisal” (paragraph 3.1.2). Notwithstanding, the BCA’s approach is flawed on two grounds.
2.65 Firstly, the preferred option, Option 5, is effectively a duplicate of Option 2 as both options incorporate a housing requirement of 47,837 dwellings within the BCP area boundary. In itself, Option 5 is somewhat disingenuous as it refers to a housing requirement of 76,076 dwellings whilst proposing 28,239 dwellings to be exported outside of the BCP area boundary.
2.66 In this respect, the PPG16 confirms that the reasonable alternatives are to be identified “taking into account the objectives and the geographical scope of the plan or programme”. Consequently, it is not within the remit or scope of the SA to appraise the sustainability credentials of exporting housing growth outside of the administrative area of the Black Country and the area boundary of the BCP.
2.67 This option should therefore be removed, and the SA be amended to clarify that the preferred growth option is indeed Option 2 and not Option 5.
2.68 Secondly, following removal of Option 5 as set out above, the growth alternatives essentially comprise four separate housing quantum options:
• Option 1: 40,117 dwellings;
• Option 2: 47,837 dwellings;
• Option 3: 76,076 dwellings;
• Option 4: 79,076 dwellings.
2.69 Fundamentally, the distinction between Options 1 & 2 and Options 3 & 4 are too broad and wide-ranging such that the sustainability implications of a mid-range growth option have been disregarded. By way of illustration, the proportional difference between Option 1 and 2 amounts to circa 19%, whilst the difference between Option 3 and 4 amounts to circa 4%.
2.70 However, the proportional difference between Option 2 and 3 amounts to circa 59%: this is clearly too significant of a distinction and therefore does not allow for the appraisal of an intermediate growth option and its associated sustainability implications. In this regard, the PPG17 states:
“Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in the plan. They need to be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made.”
2.71 By omitting a mid-range growth option, for example an option within a range of between 50,000–70,000 dwellings, the BCA has artificially omitted a reasonable but realistic alternative which could potentially provide more positive and less negative sustainability impacts, whilst still meeting the objectives, than the preferred option.
2.72 In this respect, whilst R (Friends of the Earth) v Welsh Ministers [2015]18 confirms it is for the plan-making body to identify the reasonable alternatives, Hickinbottom J sets out:
“Article 5(1) refers to “reasonable alternatives taking into account the objectives… of the plan or programme…” (emphasis added). “Reasonableness” in this context is informed by the objectives sought to be achieved. An option which does not achieve the objectives, even if it can properly be called an “alternative” to the preferred plan, is not a “reasonable alternative”. An option which will, or sensibly may, achieve the objectives is a “reasonable alternative”.” (paragraph 88)
2.73 Consequently, the SA as currently prepared is unsound as the BCA has failed to identify and test the sustainability implications of a growth option within a range of between 50,000–70,000 dwellings as a reasonable alternative.

Comment

Representation ID: 22319

Received: 11/10/2021

Respondent: RCL Partners

While we appreciate and understand the due process that has to be followed as the Plan is constructed and eventually submitted, we are keen to highlight the importance of also looking at ways the region’s local authorities can cut through some of the process, where appropriate, and expediate development opportunities.

Object

Representation ID: 22334

Received: 01/10/2021

Respondent: Mr Robert Janes

No details of objection supplied

Object

Representation ID: 22430

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

[Sustainability Appraisal]

2.62 Chapter 3 of the ‘Sustainability Appraisal of the Black Country Plan’ (Lepus Consulting, July
2021) (‘the SA’) sets out the various housing growth options assessed in sustainability terms. Table 3.1 of the SA outlines the five housing options subjected to the appraisal, as replicated below.
Table 2.4 Sustainability Appraisal Housing Options (May 2021) [see PDF of representation] Source: Sustainability Appraisal of the Black Country Plan (Lepus Consulting, July 2021) Table 3.1
2.63 Although the BCP Preferred Approach (Chapter 3.5) does not actually confirm the BCA’s preferred housing growth option, the Executive Summary confirms that the BCP “proposes a strategy that is most closely aligned with Option 5” (page vii).
2.64 There is seemingly no rationale or justification for the five housing options appraised, other than that “the four authorities developed five housing number and five employment number options to be subject to sustainability appraisal” (paragraph 3.1.2). Notwithstanding, the BCA’s approach is flawed on two grounds.
2.65 Firstly, the preferred option, Option 5, is effectively a duplicate of Option 2 as both options incorporate a housing requirement of 47,837 dwellings within the BCP area boundary. In itself, Option 5 is somewhat disingenuous as it refers to a housing requirement of 76,076 dwellings whilst proposing 28,239 dwellings to be exported outside of the BCP area boundary.
2.66 In this respect, the PPG16 confirms that the reasonable alternatives are to be identified “taking into account the objectives and the geographical scope of the plan or programme”. Consequently, it is not within the remit or scope of the SA to appraise the sustainability credentials of exporting housing growth outside of the administrative area of the Black Country and the area boundary of the BCP.
2.67 This option should therefore be removed, and the SA be amended to clarify that the preferred growth option is indeed Option 2 and not Option 5.
2.68 Secondly, following removal of Option 5 as set out above, the growth alternatives essentially comprise four separate housing quantum options:
• Option 1: 40,117 dwellings;
• Option 2: 47,837 dwellings;
• Option 3: 76,076 dwellings;
• Option 4: 79,076 dwellings.
2.69 Fundamentally, the distinction between Options 1 & 2 and Options 3 & 4 are too broad and wide-ranging such that the sustainability implications of a mid-range growth option have been disregarded. By way of illustration, the proportional difference between Option 1 and 2 amounts to circa 19%, whilst the difference between Option 3 and 4 amounts to circa 4%.
2.70 However, the proportional difference between Option 2 and 3 amounts to circa 59%: this is clearly too significant of a distinction and therefore does not allow for the appraisal of an intermediate growth option and its associated sustainability implications. In this regard, the PPG17 states:
“Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in the plan. They need to be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made.”
2.71 By omitting a mid-range growth option, for example an option within a range of between 50,000–70,000 dwellings, the BCA has artificially omitted a reasonable but realistic alternative which could potentially provide more positive and less negative sustainability impacts, whilst still meeting the objectives, than the preferred option.
2.72 In this respect, whilst R (Friends of the Earth) v Welsh Ministers [2015]18 confirms it is for the plan-making body to identify the reasonable alternatives, Hickinbottom J sets out:
“Article 5(1) refers to “reasonable alternatives taking into account the objectives… of the plan or programme…” (emphasis added). “Reasonableness” in this context is informed by the objectives sought to be achieved. An option which does not achieve the objectives, even if it can properly be called an “alternative” to the preferred plan, is not a “reasonable alternative”. An option which will, or sensibly may, achieve the objectives is a “reasonable alternative”.” (paragraph 88)
2.73 Consequently, the SA as currently prepared is unsound as the BCA has failed to identify and test the sustainability implications of a growth option within a range of between 50,000–70,000 dwellings as a reasonable alternative. For this reason, Draft Policy CSP1 is unsound as it conflicts with NPPF paragraphs 32 and 35(c).

Comment

Representation ID: 22438

Received: 11/10/2021

Respondent: Tettenhall Horse Sanctuary

Today Oct 6th front page helpline UNDER THREAT.

Yes these green spaces amongst the mass conurbation of bricks and concrete are essential to the visionary minds of all especially children of low academic schooling which makes them become wild street kids expounding their unrecognised frustrations in violence and drugs. Green grass and trees are natural relief.

How blind are the planners? Just drive out two/three miles or more to Staffordshire/Shropshire, see the potential to create new pocket villages of 300/1000 homes to sit peacefully amongst the vast fields of plough and grazing. (Pattingham is 3000 homes, Church, Village Hall, Shops, Schools etc).

Imagine these villages surrounded and set amongst thousands of trees. Also bring relief to farmers who are hard pressed to make farming today a viable business.

Support

Representation ID: 22482

Received: 11/10/2021

Respondent: South Staffordshire Council, Planning and Strategic Services

PLAN
We trust that the above comments assist the Black Country in finalising its approach prior to the
submission of the Black Country Plan. Overall, the District Council is supportive of the efforts to
date made by the Black Country Plan to address its development needs and intends to continue co-
operating with the Black Country to address these issues, subject to further discussions on the
matters set out above. We would welcome further discussions with officers to agree ways forward
on these points.

Object

Representation ID: 22552

Received: 04/10/2021

Respondent: Mr Michael O'Kelly

Number of people: 2

8. This is the very first i have heard of the planning application, yet it is already been poorly advertised and even mislabelled it "Wood End Road".
9. It must be more widely distributed to allow for discussion / comment. I know plenty of local people who have NOT been advised of this application.
10. It seems very sly & deceitfull how this has been carried out so far!!

Object

Representation ID: 22611

Received: 07/10/2021

Respondent: Miss Michelle Southall

Number of people: 9

The consultation period for the above began on the 16th of August 2021, fora project which will have such a detrimental effect on not just our wellbeing and property values why are we just hearing about this on the 30th of September2021? Is there no legal obligation to inform homeowners bordering the area when such a huge amount of construction is proposed? And still not all the
homes severely affected by this proposal have received any official notice, how many homes have been informed in time to raise objections? including Chester Road, Lichfield Road, Barracks Lane, and Ogley Road. We can only assume the delay is intentional.

Comment

Representation ID: 23103

Received: 11/10/2021

Respondent: Canal & River Trust

Black Country Plan Regulation 18 consultation

Thank you for the opportunity to comment on the Draft Black Country Plan.


We are the charity who look after and bring to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our waterways and promoting their use we believe we can improve the wellbeing of our nation. The Trust is a statutory consultee in the Development Management process.

Our waterways do, or have the potential to, provide important areas for recreation, biodiversity, sustainable active transport (with related health and air quality benefit), business, tourism and a focal point for cultural activities. They are heritage assets. Waterways can also provide a resource that can be used to heat and cool buildings, a corridor in which new utilities infrastructure can be installed and a way of sustainably draining surface water away from new developments.

The Trust owns and manages approximately 150km of waterways within the Dudley, Sandwell, Walsall and
Wolverhampton local authority areas, including:


• The Old Main Line Canal
• The New Main Line Canal
• The Shropshire Union Canal
• The Staffordshire & Worcestershire Canal
• The Titford Canal
• The Wyrley & Essington Canal
• The Bradley Arm Canal
• The Wednesbury Old Canal
• The Walsall Canal
• The Rushall Canal
• The Daw End Canal
• The Dudley Number 1 Canal
• The Dudley Number 2 Canal
• The Stourbridge Canal



and proposed) with one another and to areas of open space and countryside. Canals have played a significant part in the development of the Black Country and they continue to be a valued social, economic and environmental asset, with even greater potential to support regeneration and the wellbeing of individuals and communities.

Over 70 per cent of the residents of the Black Country (approximately 850,00 people) live within a
They should be highly valued as accessible blue and green assets Making the waterways of the Black Country easier, safer and more attractive to visit should ensure that they can do even more to support the wellbeing of individuals and communities.

Our Towpath Count data shows a significant increase in use of towpaths in the Black Country since the first COVID-19 lockdown in Spring 2020, with sites in Sandwell experiencing nearly a 300% increase in average daily usage between 21 March 2020 and 5 July 2020. Where we have data available, usage remains higher now than it was pre-pandemic, significantly so in some locations. For example, average daily usage from
our Towpath Count data in Walsall was shown to have increased by approximately 100% compared to pre- pandemic levels. We are keen to build on this increased awareness of and appreciation for the canal network and the Black Country is a regional priority area for the Trust.

We note that the plan recognises that the Black Country performs worse than the England average with regards to risk factors for poor health outcomes that are linked to the built and natural environment. Within the Black Country 68% of households within 1km of a Trust waterway are classified as being deprived in one or more dimension waterways can play a valuable role in helping to tackle this through providing a space for healthier lifestyles,
community engagement and skills development.


Enhanced waterways form an important part of the vision for the development of the area and we believe that this can support many of the strategic objectives, including providing a built and natural environment that supports the making of healthier choices; protecting health and wellbeing; promoting sustainable and active travel; improving public realm; enhancing the natural environment and mitigating climate change.

Our comments on the Draft Black Country Plan are set out below. We focus first on policy ENV7 before considering other relevant policies and site allocations.

Comment

Representation ID: 23141

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

General comments; The Black country UNESCO Geopark Partnership acknowledges the difficult balance that this document deals with between urban growth and development whilst maintaining quality of environment, the provision of outdoor inspirational places for health and wellbeing, and the growing importance of the visitor economy that this plan is attempting to address. Our comments and suggested amendments are focused on those aspects of policy which particularly align with the work and aspirations of the Black country UNESCO Global Geopark (BCUGGp), These are; the natural & cultural Heritage, its fundamental importance to sustainable growth , the visitor economy,learning, skills development and training, creativity, the quality of life and wellbeing of our communities and the increasing importance of the threats to quality of the environment including climate change.

We feel that this section is a reasonable summary of the context and underpinning principles of the plan. We particularly note and concur with important observations stated in paragraphs 1.18 and 1,36. These stating that consultation demonstrated that there was support for housing to be built in sustainable locations and a desire to protect the environment of the Black Country (section 1.18) and that the plan recognises that deprivation, obesity and wellbeing are issues, which negatively affect the physical and mental health and wellbeing of residents of the Black Country, that are influenced by the quality of, and opportunities within, the built and natural environment(section 1.36)

Comment

Representation ID: 23178

Received: 11/10/2021

Respondent: Environment Agency

Sustainability Appraisal (July 2021)
In line with the comments above in relation to the Water Framework Directive (and associated River Basin Management Plans), water quality and water Cycle Study, we find the SA lacking in its consideration of the water environment baseline data and overarching policy drivers. We recommend this is rectified and associated policies incorporated into the next version of the plan.