10 Environmental Transformation and Climate Change

Showing comments and forms 1 to 30 of 34

Comment

Draft Black Country Plan

Representation ID: 10661

Received: 01/09/2021

Respondent: Mrs Su Brad

Representation Summary:

Not every spare brownfield space should be built on. Where would nature live? Even in towns nature needs a home. If there are brownfield sites which have flourished with trees, meadows and wildlife, then these areas should be kept as nature reserves.

Comment

Draft Black Country Plan

Representation ID: 10795

Received: 09/09/2021

Respondent: Mrs Beverley Sproson

Representation Summary:

We need to save the little of what we have left of our green space for future generations & wildlife.Trees that are mature and have nature’s habitat living in them are going to be destroyed by this
proposed development. Houses are being built on every available space with no consideration for
anyone’s mental well being or the destruction of its wildlife.

Comment

Draft Black Country Plan

Representation ID: 10837

Received: 14/09/2021

Respondent: Mr John Garratt

Representation Summary:

The change will lead to:
* Loss of local wildlife habitat, greenbelt and rights of way.

Comment

Draft Black Country Plan

Representation ID: 10854

Received: 14/09/2021

Respondent: Mrs Helen Allez

Representation Summary:

Green spaces are beneficial to mental health and general wellbeing. Building on them and reducing the buffer zones around them, then adding the increased foot traffic and other pressures will destroy the few remaining green spaces and nature reserves.

Comment

Draft Black Country Plan

Representation ID: 10950

Received: 17/09/2021

Respondent: Mr olof lee

Representation Summary:

It beggars belief that local councils don't cherish this land particularly in this day and age of environmental awareness. The damage to the local natural eco system will of course be significant.

Comment

Draft Black Country Plan

Representation ID: 11023

Received: 20/09/2021

Respondent: Mrs Rebecca Bickmore-Green

Representation Summary:

We must preserve as much green land as possible for the sake of the planet and wildlife.

Comment

Draft Black Country Plan

Representation ID: 11026

Received: 20/09/2021

Respondent: Mrs Rebecca Bickmore-Green

Representation Summary:

Do not destroy our green spaces. Look at other areas. We need to look after the planet before it’s too late . Think ! Please !

Comment

Draft Black Country Plan

Representation ID: 11114

Received: 22/09/2021

Respondent: Mr Philip Ryan

Representation Summary:

The development will also threaten local wildlife as well as local beauty spots.

Object

Draft Black Country Plan

Representation ID: 11470

Received: 04/10/2021

Respondent: Mr CLIVE HEYWOOD

Representation Summary:

The BCP does not adequately address the issue of Climate Change , especially in respect of localised flooding. The benefit of Trees in soaking up the excess rainwater has not been appreciated in the plan.
The benefits of Open Spaces /Green Spaces for the physical health and mental wellbeing has not been adequately appreciated .
The BCP plan does not adequately protect Green Spaces.

Comment

Draft Black Country Plan

Representation ID: 11551

Received: 06/10/2021

Respondent: Mrs Emily Curtis

Representation Summary:

I am a member of the Birmingham and Black Country Wildlife Trust and write in support of their documented representations that I have looked at and agree with.

Comment

Draft Black Country Plan

Representation ID: 11785

Received: 08/10/2021

Respondent: Mr Gary Lambert

Representation Summary:

so why are the planning taking conservation status from our local history and archiologie Great Barr Hall gardens and surrounding history

Comment

Draft Black Country Plan

Representation ID: 11977

Received: 10/10/2021

Respondent: Miss Emma Thompson

Representation Summary:

The BCP should provide a policy framework to support the commitments of the government’s 25 Year Environment Plan and the delivery of the West Midlands Combined Authority Natural Environment Plan

Comment

Draft Black Country Plan

Representation ID: 11998

Received: 10/10/2021

Respondent: Miss Emma Thompson

Representation Summary:

The BCP should provide a policy framework to support the commitments of the government’s 25 Year Environment Plan and the delivery of the West Midlands Combined Authority Natural Environment Plan

Comment

Draft Black Country Plan

Representation ID: 12026

Received: 10/10/2021

Respondent: Miss Emma Thompson

Representation Summary:

I support the Wildlife Trust's comment to request an additional Environmental Transformation policy re: protection, enhancement and investment in river corridors. The value that rivers provide with regards climate change mitigation and adaptation, flooding, air quality, access and health and wellbeing is increasingly understood. The WMCA Environment Plan 2021 identifies river corridors as a priority action and recognises the value they provide, identifying the River Stour as a focus. Whilst recognising that Policy CC5 includes appropriate actions for rivers, a strong standalone policy is required to fully maximise the opportunity that river corridors provide to deliver many of BCP’s ambitions.

Object

Draft Black Country Plan

Representation ID: 12064

Received: 10/10/2021

Respondent: Mr Jatinder Randhawa

Representation Summary:

The main general point is that building on and developing green land is a long term mistake considering the strong evidence of the climate emergency we all face.

Object

Draft Black Country Plan

Representation ID: 12202

Received: 11/10/2021

Respondent: Mr Tony Cox

Agent: Mid West Plannning Ltd

Representation Summary:

One of the challenges should be to preserve the best and most versatile agricultural land in the Local Plan Area, and to prioritise the less productive and less vesatile agricultural land for food production.

REASON - If, as stated, the number of households is set to increase from 495,000 to 1.2m by 2039, then we will need to produce more food, and ideally not be reliant on imported foods. We will need the best and most versatile land for food production, and this should be a major consideratin when determining if land should be taken out of the green belt.

Comment

Draft Black Country Plan

Representation ID: 13235

Received: 08/10/2021

Respondent: Mrs Angela Wadeley

Representation Summary:

We must protect our Green spaces of all incarnations for the "Nature Services" we receive. We need for example productive farmland, forestry, drainage and flood protection, heatwave cooling, clean air, fauna and flora protection, carbon storage, and space to breathe. The pandemic has shown that we appreciate Green spaces for their intrinsic value and for the physical and mental health benefits we gain. Without the Green Belt which defines and separates the four boroughs and also other surrounding boroughs, our local identities will merge into Greater Birmingham and the wider West Midlands Conurbation. I expect that this will have detrimental consequences now, for the next generation growing up and for future generations.

Comment

Draft Black Country Plan

Representation ID: 14523

Received: 11/10/2021

Respondent: Bill Hawkins

Representation Summary:

We are rapidly approaching a climate crisis and green areas are essential for the survival of this planet. We can't afford to lose one more square metre of them. The loss of habitat for wildlife will be catastrophic, especially pollinators such as bees who are in decline at present

Comment

Draft Black Country Plan

Representation ID: 15448

Received: 11/10/2021

Respondent: Natural England

Representation Summary:

Soil and Best and Most Versatile agricultural land.

We are disappointed that no polices specially address soil protection or loss of best and most versatile agricultural land. We acknowledge that compared to other areas there is limited best and most versatile agricultural land in the plan area. We would still advise adding in a policy for soil protection that
includes best and most versatile agricultural land, in line with paragraph 174 a) and b) of the National
Planning Policy Framework and the government’s 25 Year Environment Plan.

The Local Plan should give appropriate weight to the roles performed by the area’s soils. These should be valued as a finite multi-functional resource which underpin our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver, for example:

• Safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future.
• To avoid development that would disturb or damage other soils of high environmental value (e.g. wetland and other specific soils contributing to ecological connectivity, carbon stores such as peatlands etc) and, where development is proposed.
• Ensure soil resources are conserved and managed in a sustainable way.

Further information can be found in Natural England's Technical Information Note 049 on Agricultural
Land Classification (ALC).
We would advise that the plan refers to sources of Agricultural Land Classification and Best and Most Versatile mapping and data which will include but not limited to: the www.magic.gov.uk website and Natural England. For example Agricultural Land Classification map West Midlands Region (ALC004) and Likelihood of Best and Most Versatile (BMV) Agricultural Land - Strategic scale map West Midlands Region (ALC016.

The plan should recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process. We advise that policy should support developments that enhance soils, avoid soil sealing and provide mitigation to avoid soil disturbance

We advise that Plan policies refer to the Defra Code of practice for the sustainable use of soils on construction sites and that major development should have a soils management plan.

Comment

Draft Black Country Plan

Representation ID: 15475

Received: 11/10/2021

Respondent: Natural England

Representation Summary:

Climate change policies

We welcome the climate change policies. We advise that the plan should go further and would be more robust if it looked at ways to adapt and mitigate for the consequences of climate change. ‘Nature-based solutions’, are essential to achieve this. These involve the restoration of ecosystems for the long-term benefit of people and nature. Examples include:

• Expansion of tree and woodland cover - to strengthen woodland habitat networks, protect soils, provide shade whilst capturing additional carbon from the atmosphere.
• Restoration and creation of priority habitats such as lowland heathland, lowland meadows, lowland fens and rush pastures. This improves places where people live and recreate, protecting carbon stores and strengthening the nature recovery network.
• Natural floodplain management, through the use of tree planting, habitat creation and restoration, to alleviate flooding further downstream.
• Retrofitting of green and blue infrastructure such as trees and sustainable urban drainage systems (SUDS) in urban localities to address flood risk and heat island effects.

Within your Plan we suggest you consider including the following actions:

1. Set an ambitious climate-specific policy with targets for reducing greenhouse gas emissions.
Plans should include a clear commitment to achieving the national statutory target of net zero emissions by 2050, with policies to secure significant reductions in greenhouse gas emissions over the Plan period;
2. Identify, protect and plan to restore all areas of peatland. Our mapping system shows that there are areas of peat in the Plan area within the northern Walsall area. Ideally any plan to restore
peatland, should wherever possible include management of the catchment areas that support the peatland. We would advise extending this approach to shallow peaty areas in addition to
deep peats.
3. Identify opportunities to increase tree and woodland cover consistent with the UK target.
Wherever possible, this should provide multi-functional benefits. Planting on peatlands and other open habitats must be avoided.
4. Identify areas where nature-based solutions can provide benefits to people whilst reducing
climate change vulnerability in the natural environment.
5. Identify habitats and protected sites that are particularly vulnerable to the impacts of climate change and consider how the planning system can work to reduce these vulnerabilities.

We advise that these actions are integrated into a strategic approach alongside green infrastructure, health and wellbeing, biodiversity net gain, natural flood management, air and water quality to deliver multifunctional benefits to people and wildlife. The Plan should make clear that development will be consistent with these policies, to ensure sustainable development is properly achieved across the Plan period. Meaningful targets should be set that can be appropriately monitored over the Plan period to
demonstrate the effectiveness of the Plan/Policy in addressing climate change and to ensure appropriate remedial action can be taken as necessary.

Further information on climate change resources can be found in Annex 2. Natural England would be happy to advise further on this aspect of the Local Plan development.

Comment

Draft Black Country Plan

Representation ID: 16765

Received: 10/10/2021

Respondent: Birmingham & Black Country Botanical Society

Representation Summary:

I am impressed by the scope and depth of the document as a whole.

Object

Draft Black Country Plan

Representation ID: 16958

Received: 11/10/2021

Respondent: Kerrie Richards

Representation Summary:

Can you please post a copy back to me to ensure receipt.
I want to raise the following objection to the Local Plan
I have lived and worked within the Black Country and surrounding area all my life and wish to object to the Black Country Local Plan methodology and process as follows:
1. Local Plans should safeguard areas that have local wildlife-rich habitats and wider ecological networks, including locally designated sites of importance for biodiversity. There are sites selected that are disregarding this policy.
2. Building on green belt takes away high quality accessible natural greenspace which is a necessity to reduce pollution and help in the global fight against climate change. Building on green belt areas should only be considered as a last resort when ALL other sites have been identified. Not all brown sites have been proactively identified in this process, you have used a call for sites and this is not proactive.
3. Local mental and physical needs have not been assessed when selecting sites, these accessible green areas are vital to our communities health and wellbeing.
4. Not all of the designated sites are in areas where employment is increasing or growth is identified. The policy is a “finger in the air” policy that looks at sites put forward and doesn’t assess the economical or growth needs of each individual area. Assis ng other authorities with housing needs because they are not providing the houses is just widening the issue of unnecessary building on green belt.
5. The process of asking for feedback on sites once the preferred options are already identified is not democratic.
6. There should be a study made of all land and buildings that would benefit the communities if they were developed. I.e., brownfield, derelict, businesses looking to close or relocate, buildings that have potential to be re-classified. Only when all of these have been studied should there be any consideration of building on green sites.
7. The housing target numbers are outdated. The empty homes haven’t been taken into consideration, neither has the impact of Brexit or Covid which are key considerations at this current me.
8. The consulta on process is difficult for lay people to understand and therefore gives the developers an unfair advantage. There is not enough opportunity for the non-technical person to object to sites.
9. The current government is calling for a re-working of policy against building on green belt sites. The continuation of the local plan is therefore a “local officer led” initiative not government led, and thus once more is undemocratic.
10. There is no incentive in this process for developers to put forward brown field sites if green belt sides are under consideration.
11. The quality of life of existing residents has not been considered. The stress and worry and reduction in house value of proper es bordering green belt sites.
12. The process encourages land banking.
13. Not enough adequate studies on the infrastructure on land put forward as preferred by neighbouring authorities or within neighbouring authorities.
14. The green belt provides easy access to the countryside for local residents. The plans wording allows for the re-drawing of green belt and doesn’t value for the benefits it provides for current residents.
15. No rail networks will force more commuters to use cars and further gridlock the roads.
16. The doctors and schools are already over subscribed, or will not be able to cope with the planned extra housing - there is no joined up plan to take into account the extra strain on amenities and infrastructure that will be also caused by the South Staffordshire plan that has preferred sites on the Black Country Border. ie Lower Penn.
17. There is already congestion on the roads, which is adding to pollution, however consideration should also be given to the increased risk of accidents with more vehicles being pushed to use local village roads.

Support

Draft Black Country Plan

Representation ID: 17113

Received: 30/09/2021

Respondent: House of Commons

Representation Summary:

The protection of green belt land stems the tide of poor air quality that many residents of the Black Country, including some of my own constituents, suffer from. It is also key to the fight against climate change, the effects of which have been outlined in the BCP, including the potential of more risk of flooding. Given that the River Stour runs through the green belt land in the south of Halesowen, and has historically caused flooding issues in the past, building more homes in close proximity to its banks would have the potential to cause further issues.

Comment

Draft Black Country Plan

Representation ID: 21249

Received: 11/10/2021

Respondent: Newlands Developments

Representation Summary:

Biodiversity Net Gain
NPPF Paragraph 32 advises that Local Plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Moreover, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

As such, it is considered that draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) is not consistent with national policy as it requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The NPPF places no requirement on development proposals to deliver a notional target of a 10% net gain. It is therefore considered that draft Policy ENV3 should be amended to simply require all development proposals to achieve a biodiversity net gain.

Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. Part 1(d) of Draft Policy ENV9 is of particular relevance to employment developments as it encourages developments to consider crime prevention measures and Secured by Design Principles. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards.

Support

Draft Black Country Plan

Representation ID: 21307

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

Support: WTBBC support the broad range and detail of the Environmental Transformation and Climate Change policies in the BCP, including the addition of new policies such as ENV3, ENV4 and ENV6 which respond to emerging national legislation and evidence of the value that the natural environment provides the communities of the Black Country.

Comment

Draft Black Country Plan

Representation ID: 21308

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

Comment: WTBBC request an additional Environmental Transformation policy is added concerning the protection, enhancement and investment in river corridors. The value that rivers provide society with regards climate change mitigation and adaptation, flooding, air quality, access and health and wellbeing is increasingly understood. The WMCA Environment Plan 2021 identifies river corridors as a priority action and recognises the value that they provide, identifying the River Stour as a focus. Whilst recognising that Policy CC5 includes appropriate actions for rivers, a strong standalone policy is required to fully maximise the opportunity that river corridors provide to deliver many of the BCP’s ambitions.

Support

Draft Black Country Plan

Representation ID: 21309

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

Introduction
10.2
Support: WTBBC support the recognition in the BCP that the protection and improvement of the Black Country’s biodiversity and geodiversity will improve the attractiveness of the area for people to live, work, study and visit while at the same time improving the physical and natural sustainability of the conurbation in the face of climate change.

Comment

Draft Black Country Plan

Representation ID: 21310

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Representation Summary:

Introduction
10.5
Comment: Whilst acknowledging that the BCP recognises the importance of green infrastructure in achieving a healthy and stable environment, WTBBC do not feel this is reflected adequately throughout the Plan. There are numerous opportunities throughout the BCP to further reference and require consideration for and investment in the natural environment and green and blue infrastructure. This is reflected in our comments on the various sections and policies of the BCP. Furthermore, this paragraph should reference the inclusion of the Local Nature Recovery Network in Policy ENV3.

Comment

Draft Black Country Plan

Representation ID: 22633

Received: 11/10/2021

Respondent: National Highways

Representation Summary:

Environmental Transformation and Climate Change
It is noted that the draft submitted version of the local plan and identified allocations will
increase the number of residents in proximity of the SRN. It is likely that these locations
will be impacted by noise pollution from the SRN and raise the potential for exceedances
of air quality standards for which extraordinary measures in the form of permenant speed
restrictions have already been put in place on the M5 and M6.
Several policies, and the Black Country SPD set out requirements for developments to
reduce the impact on, or improve, local air quality but this does not directly relate to the
SRN and what mitigation may be required. We will continue to work proactively with
yourselves on these matters but would recommend a specific policy which identifies how
air quality impacts and noise pollution would be monitored and managed and what
interventions may be required.

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.