Justification

Object

Representation ID: 12011

Received: 10/10/2021

Respondent: Miss Emma Thompson

No reference is made to evidence commissioned by and provided to the BCA by WTBBC. In October 2019 WTBBC and EcoRecord (the Local Environmental Records Centre) submitted An Ecological Evaluation of the Black Country Green Belt. This comprehensive study analysed a wide range of datasets and assigned a relative ecological value to individual landscape units. The evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC should be included in this list:
- An Ecological Evaluation of the Black Country Green Belt (2019)
- Draft Local Nature Recovery Opportunity Map and component descriptions (2021)

Object

Representation ID: 18509

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
Object: No reference is made in this section to evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC.
In October 2019 WTBBC and EcoRecord (the Local Environmental Records Centre) submitted An Ecological Evaluation of the Black Country Green Belt. This comprehensive study analysed a wide range of datasets and assigned a relative ecological value to individual landscape units.
This report was subsequently published on the Black Country Plan website as part of the Evidence Base, however, no reference is made to its findings being used in the Development Strategy or Site Assessment process.
Object: No reference is made in this section to evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC.
In April 2021 WTBBC and EcoRecord (the Local Environmental Records Centre) submitted a Draft Local Nature Recovery Opportunity Map (and a description of the components of this) which has been published as Appendix 18 in the BCP.
No reference is made to its findings being used in the Development Strategy or Site Assessment process.

Comment

Representation ID: 18511

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.5
Comment: WTBBC have concluded through analysis of data that not all the sites allocated for development in the BCP are sustainable and deliverable. Furthermore, from a biodiversity and ecological network perspective some of these do, indeed, breach the environmental capacity of the area. These statements if made should be caveated with a statement that this is the view of the BCA. Further detail of the findings of our analysis are given in our response to individual allocations.

Comment

Representation ID: 18512

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.7
Comment: It is WTBBC’s view that the Spatial Options Paper oversimplifies the spatial options available to the BCA in their preparation of the BCP. Whilst WTBBC support the approach of Option J Balanced Growth with its emphasis on focusing growth within existing residential and employment areas alongside a limited number of new growth areas, this option should not be pursued to the exclusion of Option G Garden Village/Urban Greening. WTBBC support Option G’s focus on more open space which supports the Nature Recovery Strategy (funded by BNG) and this approach should be followed in all Neighbourhood Growth Areas in the BCP.

Object

Representation ID: 23346

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.4 - In relation to Yorks Bridge the housing numbers and net developable between the Sustainability Appraisal, Site Assessment Report and St Modwen Vision Document do not tally.

Object

Representation ID: 23347

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.8 - 8.12 - Contrary to the finding of the Sustainability Appraisal, a historic assessment of the Site and its surroundings has bene prepared on behalf of St Modwen, which concluded that no intervisibility exists between the Site and the Grade II Listed Pelsall Works Bridge or the Grade II Listed Wyrley & Essington Canal Footbridge at Pelsall Junction.

Object

Representation ID: 23351

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.11 - 8.15 The SA scores York's Bridge a minor negative score because it lies adjacent to an area of High Historic Townscape Value. This relationship according to the SA methodology should score a 0.

Object

Representation ID: 23352

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.16 -8.17 - Table H.2.1, "Only one of these sub-criteria, 'listed building', has been scored as minor negative, the other 7 have all scored neutral. RPS contends that the overall score of minor negative is unduly harsh and does not reflect the overall neutral effect of the site on cultural heritage as a whole."

Object

Representation ID: 23353

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.18 - 8.20 - The SA relies on the Landscape Sensitivity Assessment and the site is small within a much larger parcel and none of the identified constraints affect Yorks Bridge. Also "the SA places significant emphasis on the importance of views of the site, which is not reflected in the LSA appraisal findings"