10 Environmental Transformation and Climate Change

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.

Comment

Representation ID: 23175

Received: 11/10/2021

Respondent: Environment Agency

Figure 10- Environment Key Diagram should be amended to include key rivers and/or floodplains and buffer for habitat function.

Comment

Representation ID: 23241

Received: 11/10/2021

Respondent: Member of Parliament

The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.

Comment

Representation ID: 46266

Received: 11/10/2021

Respondent: Walsall Group of the Ramblers

Walsall Group of the Ramblers wish to make the following comments in the consultation phase of the Black Country Plan. (BCP).
[Our remarks focus on the perceived impact of the BCP on the Walsall Borough - other boroughs in the Black Country have similar Ramblers groups who may wish to comment with respect to their particular areas].
Introduction.
The recent pandemic has clearly illustrated how valuable open spaces are for the health, (physical and mental), of people everywhere. With the Black Country’s already identified lower rates of physical activity, higher rates of obesity, alcohol abuse, depression and social isolation, opportunities for exercise and outdoor outlook changes are vital as the population expands and issues relating to social support within the community are further increased.
Naturally enough we anticipate the erosion of green space that will occur as the Plan is implemented, especially in the strategic building areas bordering on the Green Belt, but look forward to observing the commitments in the Plan that not only aim to preserve trees, woodlands and hedgerows, but also to develop canal towpaths to enable links to other cycle and walking routes. We also look forward to the proposed changes that will lead to multi-functional green spaces and greenway systems. The use of Green Belt land for public open space, sport and recreation appears, to us, a good use of the asset - providing it is done with appropriate care. We welcome resources aimed at furthering the protection of the local natural environment, (SSSIs, etc), whilst also utilising funds to bring these areas nearer to the public, (sensitively), via an enhanced system of cycle and footpath routes.
Footpaths and Byways.
From the footpath perspective we see an opportunity to have footpaths in local boroughs planned/implemented in association with those who might use them. (We have seen enough paths ‘wedged’ into development plans that have proved to be not only unsuitable for users involved, but also prone to ASB and damage).
There is also the further possibility of an expansion of Black Country-wide footpaths - that were popular some years ago - linking boroughs, but which have declined more recently and need refurbishment/improvement, (e.g. The Beacon Way, The Wulfrun Way).
[Four years ago we re-labelled the Beacon Way from Sandwell Park Farm to Castle Ring on Cannock Chase, but lack of resources within Walsall Council has meant we have been unable to publicise this on a local web-site].
Our Concerns
...
As a Ramblers group committed to furthering the interests in walking for both health and social motives, [at the same time as supporting fully the Plan’s strategic policy 11- to protect the natural environment, wildlife corridors, countryside landscapes, etc including an interlinked green infrastructure protection/maintenance of the countryside], we would wish to see introduced a separate Black Country-wide Footpath Development Plan, that is clearly documented and approved.
We would see this running in parallel to the wider BCP timescales and fully accessible to all interested parties. On a positive note, however, we feel that as far as Public Rights of Way, (PROWs), are concerned the implementation of the BCP should be used as a means of expanding the footpath network in both Walsall and across the other boroughs of the Black Country.
Black Country-wide Footpath Development Plan, (BCFDP).
We seek a coordinated development of this network expansion between the BCP itself and reviewed/updated Rights of Way Improvement Plans, (ROWIPS), in all boroughs. We see this operating via a Black Country ROWIP, (created from individual borough ROWIPs), that is monitored via Local Access Forums, (LAFs), whose members are drawn from ROW user groups, (e.g. walkers, horse riders, cyclists, canal boat owners, etc).
As in the BCP itself, the current Walsall ROWIP places much emphasis on the maintenance and development of public open space and hence the ROWIP/BCFDP should work in parallel over the entire duration of BCP to ensure a long-term strategy for footpaths and adjoining spaces is produced and enacted.
(The Walsall ROWIP is already being prepared for an overdue review and we hope to have some input into that once more).
However, recent reductions in resource levels with ROW Teams throughout the Black Country suggests that currently this might be unattainable and that cost-saving will continue to dominate this area allowing an uncertain and likely unplanned development of leisure services in this section.
(Walsall Situation).
Ramblers volunteers in Walsall have worked closely with Walsall MBC Rights of Way team for some years to help keep footpaths and byways in order throughout the borough, but whilst being exceptionally grateful for their commitment, we are acutely aware of their limitations.
We are working closely with the ROW Team in Walsall Council, both in monitoring footpath situations and actively volunteering to help keep local routes open and viable. (This is particularly important in an urban area where paths are somewhat limited, but as a result our more rural footpaths are heavily used by the general population).
Our own LAF has been operating in ’background’ mode owing to pandemic restrictions, but we are seeking to reinstate it shortly. We see this function as a means of keeping abreast of the BCP’s progress whilst also permitting representation of implicated Council departments for discussion along the way.
Like many other areas of the Council, the ROW Team is under-resourced and consequently all project and proposals take a long time to move forward – especially since COVID restrictions.
[We are currently attempting a DMMO to formalise the route of Sutton’s Drive on the Great Barr Hall Estate, but progress is particularly slow further and exacerbated by delays incurred by continued remote working by the MBC].
In Conclusion.
Footpaths and opportunities to take exercise in the wider environment have already demonstrated their benefits and will continue to do so. We therefore need to understand the changes implied by the BCP to make sure that in future our ROWs are not only preserved, but wherever possible expanded and developed. These are assets which all community members within the Black Country have a right to understand and access whenever they wish.

(See Rep ID 11482 for the original submission)