Draft Black Country Plan

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: 23142

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We welcome that climate change is given high priority (Strategic Priority 1 & 2 within table 1). We would suggest that the emerging visitor economy and/or Geopark could be included in policy references in Table 1 under Strategic Priority 8 for ‘Enabling a strong, stable and inclusive economy’.

We support Strategic objectives 11 and 12 relating to natural and cultural environment and support Strategic Priorities13,14 & 15 relaying to sustainable resource provision and infrastructure.

Comment

Representation ID: 23145

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We feel that the importance of the UNESCO brand within the context of Black Country visitor economy is understated in the wording within the 10 points listed within the panel for policy CSP5. The Black Country UNESCO Global Geopark and policy ENV 6 should also be mentioned here alongside the canals and ENV 7 comment due to its importance in international profile of the Black Country and destination perception for the visitor economy. We particularly welcome the recognition of the Geopark in paragraph 3.63

We understand the pressures to develop in the green belt and how important the green belt is to limit ‘urban sprawl’. In the context of the quality of the environment and the Geopark the natural connections to the surrounding countryside and entry points into the Black Country as a visitor economy destination are very important and need to be protected. We suspect that permission of development in ‘sustainable locations’ may be difficult to understand/explain/justify and fear setting precedents that harm the green infrastructure connectivity of such places. We see the Greenbelt statements of section 3.49 as very important but are concerned by the statement within it ‘
‘The landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible’.

Comment

Representation ID: 23146

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We see future transport to and within the Black Country as fundamental elements of the Geopark/visitor economy/environmental aspects of the plan. We acknowledge how quick technological change can be within this sector and that lifestyle shift through events such as the Covid 19 pandemic can rapidly influence future workstyles and requirements of intrastructure and transportation modes. In that context the Geopark has witnessed a substantial increase in the use of and value of its accessible greenspaces and active transport networks/ purchase and use of cycles etc.

We welcome and support the statements and policies in the plan supporting green infrastructure/accessible greenspaces and the further development of well-connected walking and cycle networks for the multiple health, wellbeing and environmental benefits that they offer.

Comment

Representation ID: 23147

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We think that section 5 is particularly important for the future development of the Black Country and the health and happiness of its residents and visitors. We welcome that Geopark and other Environmental policies so strongly cross referenced here. We concur and support many of the generic statements of paragraphs 5.7 to 5. 13.

We would however recommend that para’s 5.12, 5.16 and 5.22 also include a specific bullet point/statement that highlights the specific importance of accessible natural and cultural places to wellbeing as these are increasingly being prescribed by health professionals for mitigating poor mental and physical health issues.

Comment

Representation ID: 23148

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

Whilst this section is inevitably strongly biased towards growing population driving target numbers of new homes and improved design/refurbishment of homes etc, we feel it is important to also emphasize quality, connectivity to landscape, natural and cultural heritage and environment here too within the plan. Such things offer considerable added value to such developments and In the context of the Geopark, new development often offer potential benefits for the connection of residents to the special features of their local area, the encouragement of healthier and happier lifestyles and the enhancement and maintenance of greenspaces and local distinctive features of their surrounding landscapes. The proximity of educational greenspace in connection with residential areas with schools and colleges is also understated in the plan at present. Connectivity to walking and cycling routes is alluded to in paragraph 6.16 and in policy HOU5 but wider connectivity to the landscape around by cross referencing with ENV policies would be a very useful addition to this section.

Comment

Representation ID: 23149

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

A glaring omission to our mind in this section of the plan is the lack of recognition of the visitor economy and the accomodation and hospitality sectors – which are strongly associated with heritage clusters and strategic centres. We feel that these important and growing areas of the economy should at least be cross referenced to the policies in other sections which indicate the strategic importance of these sectors of the economy and their strategic sites and centres. It would be preferable though to explicitly cite these within the EMP3 bullet points for local employment areas.

Comment

Representation ID: 23150

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

As stated in paragraph 8.2 ‘ The purpose of the centres policies is to help secure the investment, jobs and regeneration needed to create a mature, balanced, and well-functioning network of centres where residents shop, work, live and spend their leisure time’

We feel that under point c) of policy CEN 1 that reference should also be made to natural and cultural heritage links within the strategic centres and the important role that these centres will play in the visitor economy.Similarly, in Policy CEN 2 point 4) the natural and cultural assets of the strategic centres are missed and should be mentions. This comment also particularly applies to the edge of centre and out of centre sections as many links to cultural and natural features of the Black country will be found in these surrounding zones and add value to the strategic centres.

Comment

Representation ID: 23151

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We generically agree with the need for a better connected, greener, sustainable transport system as set out in the paragraphs and policies of section 9, and the transformation to lower carbon, healthier transport options. In terms of the Geopark and connecting its many natural and cultural assets to pubic transport and healthy travel we particularly support policy TRAN 5, and feel that perhaps the strategic importance of heritage locations should be specifically referenced in TRAN 6 as the visitor economy and access to areas of special character may influence travel choices.

Comment

Representation ID: 23152

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

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.