Draft Black Country Plan

Object

Representation ID: 44915

Received: 08/10/2021

Respondent: Coal Authority

As you will be aware within the Black Country combined authorities there is signfical coal mining legacy present. Our records indicate that within the combined areas that are coal mining features present at surface and shallow depth including; 15596 mine entires, coal workings, mine gas sites and reproted surface hazards.

Although we appreciate this draft plan sets out strategic objectives for the combined authorities it also acknowledges some of the areas requiring consideration when development is proposed, such as flood risk. Relevant policies in this regard are therefore included.

On this same basis we consider that as coal mining legacy within some of the local authorities is significant the risks that these features pose to surface stability and public safety should be identified within the plan and be the subject of an included policy. Reference to risks posed in respect of land instability could be included as Policy CSP1 as follows:
Policy CSP1 – Development Strategy
1) To deliver sustainable economic and housing growth and to meet strategic
planning targets based on the needs of local communities and businesses,
the BCA, working with local communities, partners and key stakeholders, will:
a) Deliver at least 47,837 net new homes and create sustainable mixed
communities that are supported by adequate infrastructure.
b) Deliver the development of at least 355ha of employment land.
c) Ensure that sufficient physical, social, and environmental infrastructure
is delivered to meet identified needs.
2) The spatial strategy seeks to deliver this growth and sustainable patterns of
development by:
a) Delivering the majority of development in the existing urban area.
b) Supporting and enhancing the sustainability of existing communities
through the focussing of growth and regeneration into the Growth
Network made up of the Strategic Centres and Core Regeneration Areas;
c) Protecting and enhancing the quality of existing towns and
Neighbourhood Areas and re-balancing the housing stock by delivering
homes supported by jobs and local services;
d) Delivering a limited number of Neighbourhood Growth Areas in highly
sustainable locations on the edge of the Urban Area;
e) Protecting the openness, integrity and function of the Black Country’s
designated and retained Green Belt by resisting inappropriate
development;
f) Protecting the Black Country’s character and environmental assets
including heritage assets, natural habitats and open spaces;
g) Minimising and mitigating the likely effects of climate change
f) Ensuring safe and stable development