Draft Black Country Plan

Support

Representation ID: 15288

Received: 11/10/2021

Respondent: Natural England

Policy CSP4 - Achieving well-designed places

We welcome this policy direction, specifically in reference to development proposals employing methods to help achieve climate change mitigation and adaption, minimising carbon causes and non renewable resources, and securing integrated and well connected multifunctional open space networks.

Support

Representation ID: 15289

Received: 11/10/2021

Respondent: Natural England

Policy GB1 – The Black Country Green Belt

We welcome this policy direction, specifically in reference to improving/ enhancing the environmental quality, value and function, along with improving biodiversity.

Support

Representation ID: 15290

Received: 11/10/2021

Respondent: Natural England

Policy DEL3 – Promotion of Fibre to the Premises and 5G Networks

We support paragraph 5 of this policy.

Comment

Representation ID: 15291

Received: 11/10/2021

Respondent: Natural England

5 Health and Wellbeing

We would add that public access/closeness to wildlife rich green spaces and green infrastructure from their doorstep out into a widening landscape, where biodiversity can thrive alongside nature based solutions such as flood mitigation and, carbon storage, all contribute to mental and physical wellbeing. For example, through the Midland Heath Heartland partnership - Purple Horizons Nature Recovery Project (see Annex 1 for more details). This project aims to create, enhance and connect up fragmented heathland habitat and other wildlife-rich habitats between Cannock Chase and Sutton
Park, which will benefit local communities in escaping the urban environment to ‘recharge their internal
resilience through nature’. The health and wellbeing of people living in a very urban environment will be compromised if the Core Habitat Zones (Ref. Natural Capital Mapping 2021-contact Natural England
for further detail) within the greenbelt area are not assessed fully to accommodate these opportunities.

Support

Representation ID: 15292

Received: 11/10/2021

Respondent: Natural England

Policy HW1 – Health and Wellbeing

We welcome this policy direction, specifically in reference to environmentally sustainable travel, energy efficiency, climate change, water and air quality, green and blue infrastructure.

The natural environment affords the best ‘natural’ play opportunities for children while offering multi- functional nature based solutions to climate change etc. These can be blended into wildlife rich green infrastructure and green open spaces that can act as destination play sites for local children (See best practice at Play England and Play Wales ) that have proven health and wellbeing value.

Evidence for nature play and health:
Play, naturally: a review of children’s natural play
Nature for health and wellbeing | The Wildlife Trusts
Good practice in social prescribing for mental health: the role of nature-based interventions - NECR228 (naturalengland.org.uk)

Comment

Representation ID: 15294

Received: 11/10/2021

Respondent: Natural England

Policy HOU6 – Houses in Multiple Occupation

We would advise that section 1.c) of the above policy should be revised. We are not clear as to your meaning in regard to the natural environment. Are you saying that development should not have a significant adverse impact on the character and appearance of the natural environment, or are you saying that development should not have a significant adverse impact on the natural environment?

Comment

Representation ID: 15297

Received: 11/10/2021

Respondent: Natural England

Policy ENV2 - Development Affecting Special Areas of Conservation (SACs)

We welcome the inclusion of this policy within the draft plan, however we do have some concerns.
10.19 (page 209) states that “Walsall and Wolverhampton Councils are part of the Cannock Chase SAC Partnership”. Walsall is not currently a formal member of the Cannock Chase Partnership and are not signed up to the Cannock Chase Partnership proposed mitigation scheme which is due to start in April 2022.

The European Site Conservation Objectives for Cannock Chase SAC identify in the Supplementary advice (pages 15/16 and 27/28) recreational disturbance and the direct and indirect damaging impacts it can have on the heathland’s flora and fauna as one of the biggest threats to Cannock Chase SAC. Erosion, path widening, trampling, arson, pollution of soil from horse dung and dog waste can change the vegetation over time away from heathland and disturbance in the breeding season also directly harms reptiles and birds that nest on the ground in the open heathland. The objectives for the SAC include ‘restore’ objectives for dry and wet heath which will require mitigation for cumulative, recreation impacts from new housing which would otherwise undermine the ‘restore’ objective by having an in combination impact.

The evidence base has shown that new dwellings and tourist accommodation within 15km of the Cannock Chase SAC are likely to lead to increased recreational impacts on the SAC and therefore to have an in combination adverse effect on integrity of the SAC without mitigation. Part of Wolverhampton and Walsall fall within 15km of Cannock Chase SAC (see figure 11 page 208), therefore to be able to conclude no adverse effect on integrity, mitigation is required. Walsall do not have a memorandum of understanding with the Cannock Chase Partnership or have their own
mitigation strategy in place to mitigate for recreational impacts, and we would advise that without one of these the Competent Authority will be unable to conclude no adverse effect on integrity and the Black
Country Local Plan will be unsound. We would advise Walsall Council to either agree a memorandum of understanding with the Cannock Chase Partnership on mitigation measures, or to devise their own
mitigation strategy to mitigate for recreational impacts on the SAC. An intention to do either would not provide enough certainty to conclude no adverse effects on integrity i.e. a suitable strategy would need
to be available in time for the Black Country Plan examination. We would expect to see this addressed in the Habitats Regulation Assessment (HRA), though we note that the HRA in the evidence base is only to the screening stage and advise that an appropriate assessment is required.

We would also advise, that currently the policy’s focus is on recreational impacts on Cannock Chase SAC and this does not align with the justification that also refers to air quality impacts on SACs, impacts on Fens Pools SAC and Cannock Extension Canal SAC. We would suggest either making this policy specifically about recreational impacts on Cannock Chase SAC and having a separate policy to address the other European/International protected sites/ issues or splitting the current policy up and
making it clearer to those who may not be aware of the issues, specifically what the policy is addressing. In addition this policy may require expanding following the completion of the Habitats Regulation Assessment.

Comment

Representation ID: 15298

Received: 11/10/2021

Respondent: Natural England

Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain
We welcome this policy. Nature Recovery Network
We advise including the Natural England’s Midlands Heathland Heartland partnership and the Purple
Horizons Nature Recovery Project within the policy. This project aims to create, enhance and connect up fragmented heathland habitat and other wildlife rich habitats between Cannock Chase and Sutton Park which will benefit local communities in escaping the urban environment to ‘recharge their internal resilience through nature’. The project will link and buffer existing sites while creating a network of further complementary habitats, while also providing new public access and recreational opportunities and health benefits. This links in with the government’s 25 Year Environment Plan and the Council aims to facilitate nature recovery networks. See Annex 1 for further information on the project.

Walsall council’s local sites receive high numbers of visitors and are in prominent places in the community so the project work provides an opportunity to demonstrate the approach that can be rolled out more widely into the future. The Purple Horizons heathland restoration work offers the council the opportunity to build on the works done to date by Walsall council who have gradually moved away from an intensively managed public open urban greenspace practice to a more biodiverse acid grassland
and heathland mosaic. These works will create important stepping-stones between protected sites that exist between Cannock Chase SAC and Sutton Park SSSI that include: Cannock Extension Canal
SAC/ SSSI, Jockey Fields SSSI, Clayhanger SSSI, Chasewater and The Southern Staffordshire
Coalfield Heaths SSSI, Sutton Park SSSI & NNR, Gentleshaw Common SSSI, Stubbers Green Bog
SSSI, Daw End Railway Cutting SSSI and Swan Pool and the Swag SSSI.

Barr Beacon Local Nature Reserve. This site offers significant heathland restoration opportunities as part of the Local Nature Recovery Strategy for the area. Natural England’s national recovery area project – Purple Horizons has identified Barr Beacon Local Nature Reserve as a site that should be doubled in size to accommodate new heathland and species rich habitat mosaics to be created.

Biodiversity Net Gain

In regards to net gain, we would advise that you include add the following within the policy:

• It needs to be clear within the policy that biodiversity net gain is not applied to irreplaceable habitats and it should also be made clear that any mitigation and/or compensation requirements for European sites should be dealt with separately from biodiversity net gain provision.
• The policy should set out how biodiversity net gain will be delivered and managed through the lifetime of the scheme.
• Requirements to monitor biodiversity net gain should be included within the policy. This should include indicators to demonstrate the amount and type of gain provided through development.
The indicators should be as specific as possible to help build an evidence base to take forward
for future reviews of the plan, for example the total number and type of biodiversity units created, the number of developments achieving biodiversity net gains and a record of on-site and off-site contributions.

Please note that The Biodiversity Metric 3.0 is now available and replaces the beta Biodiversity Metric
2.0 (JP029) published in 2019. We would advise updating the policy accordingly.

Support

Representation ID: 15300

Received: 11/10/2021

Respondent: Natural England

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows

We welcome the inclusion of this policy within the plan.
We would suggest that you split paragraph 1 and put the text specifically about ancient woodland as a separate paragraph.

We would advise you to expand on the buffers, explaining that the size of the buffer will depend on the type of the development proposed and the type of the woodland/tree.

Support

Representation ID: 15301

Received: 11/10/2021

Respondent: Natural England

Policy ENV6 - Geodiversity and the Black Country UNESCO Global Geopark

We welcome this policy.