Draft Black Country Plan

Comment

Representation ID: 16765

Received: 10/10/2021

Respondent: Birmingham & Black Country Botanical Society

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

Support

Representation ID: 16767

Received: 10/10/2021

Respondent: Birmingham & Black Country Botanical Society

As a resident of Wolverhampton I am personally relieved and delighted that the part of the Penn Brook Green Wedge between Wolverhampton and Dudley (i.e. Pennwood Farm) has not been allocated for development. Its loss would represent a significant diminution of the nature conservation value of the west of the conurbation and I hope that any appeal against this decision will be resisted.

Object

Representation ID: 16768

Received: 10/10/2021

Respondent: Birmingham & Black Country Botanical Society

I would however like to object on behalf of the Birmingham and Black Country Botanical Society to the omission of the Sites of Local Importance for Nature Conservation (SLINCs) from policy ENV1, points 1c and 1d of the Vision and Policies document. These sites have been allocated a nature conservation designation by a transparent and Black Country-wide inclusive system which involved and is agreed by the local authorities. You will also be aware that the National Planning Policy Framework (NPPF) states that local plans should safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity.
Sites of importance for nature conservation (SINCs) may have a more easily assessed significance, but SLINCs still fall within the NPPF definition. They need to have at least some core biodiversity elements in order to be designated, and in fact they are part of the Core Habitat Zone in the draft Local Nature Recovery Map being produced by EcoRecord. Also in most cases the SLINCs buffer and connect the more easily characterisable SINCS and SSSIs. Since Sir John Lawton's seminal report to government in 2010 it has been accepted that core areas of biodiversity need these buffer and connectivity areas if they are to survive. This has been at the root of the entire programme of nature improvement and nature recovery in Britain ever since.
Despite the core and buffering biodiversity elements which they represent, it would appear that no less than 29 of the draft housing allocation sites are SLINC sites. Building on these must represent a significant diminution in the connectivity of nature in the Black Country. A further number of sites allocated for development are potential sites of importance, not to mention those which are parts of the extant green belt.