Draft Black Country Plan

Comment

Representation ID: 22344

Received: 11/10/2021

Respondent: Canal & River Trust

Policy DEL1 states that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, masterplans what infrastructure will be provided, how it will be prioritised and what funding sources will be used. The Trust looks forward to working with the Black Country Authorities on this to ensure that the potential of our waterways to support sustainable development is unlocked, including through towpath upgrades, access improvements and wayfinding, as is supported by policies TRAN5 and ENV7 in the plan. We suggest that the Black Country Canals Strategy may identify priority areas for investment, which could be fed into
infrastructure delivery plans or other relevant documents.

Para 2.4 of the plan includes an 'open' list of the types of infrastructure that may need to be funded to support development. We suggest that 'sustainable travel' and 'green and blue infrastructure' are added to this list in the interests of internal consistency within the plan.

Comment

Representation ID: 22345

Received: 11/10/2021

Respondent: Canal & River Trust

Waterways provide established corridors through the heart of urban areas with the potential to accommodate communications infrastructure with relatively little disturbance in comparison to, for example, digging up main roads and pavements in busy locations. There is a real opportunity to maximise the use of the Trusts existing fibre optic networks and the canal corridor and Trust s land holdings for the provision of new and improved infrastructure around densely populated areas, such as the routing of infrastructure for district heating schemes and increasing mobile cell density to create 5G towns and cities

Comment

Representation ID: 22347

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust supports the design and placemaking aspirations of policy CSP4, in particular part 7, which deals specifically with the canal network. However, we would like to see the words 'wherever possible' completely from this part of the policy so that protection and enhancement of the canal network through design and layout and integration into the development is always an expectation for canalside sites. We suggest that this is consistent with the NPPF (chapters on design and historic environment) and the National Design Guide (on integrating nature and public spaces).

Comment

Representation ID: 22348

Received: 11/10/2021

Respondent: Canal & River Trust

We strongly welcome the recognition of the canal network as a significant visitor attraction for the Black Country and the support for maintaining and expanding amenities and visitor hubs. We are keen to create high quality destinations on the canal network in the Black Country to support uses on the water and on the towpath. As part of this, we have obtained Green Flag status for Revolution Walk between The Roundhouse in Birmingham and Chance Glass Works in Smethwick and are next keen to achieve Green Flag status for our waterways in Wolverhampton and Walsall. In Dudley, we are keen to develop a welcome station and cycle hub. Furthermore, we want to work in partnership with organisations to deliver a legacy for the canals of the Black Country from the Commonwealth Games.

Comment

Representation ID: 22350

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust welcomes the policy aspiration for regeneration of the Black Country to support an environment that protects and improves the physical, social and mental health and wellbeing of its residents, employees and visitors and reduces health inequalities, including by protecting, enhancing and providing new green and blue infrastructure. We believe that the canal network has a significant role to play in this regard, whether it be through offering a place for recreation, a route for sustainable travel or a focal point for community engagement, skills development or volunteering. Research by Simetrica carried out for the Trust has demonstrated the wellbeing benefits of spending time by our waterways. Through protecting and enhancing the quality and accessibility of the canal network, we believe that it can deliver more wellbeing benefits for residents of the Black Country.

We would hope to see green and blue infrastructure properly considered in Health Impact Assessments required under policy HW3.

Comment

Representation ID: 22352

Received: 11/10/2021

Respondent: Canal & River Trust

We welcome the encouragement for the use of waterways for freight. We suggest that the policy could helpfully go further by requiring applicants for major developments to consider the feasibility of using waterborne freight in the construction, demolition and excavation phases where the development site is adjacent to a navigable waterway. This would set a clearer expectation for developers and indicate to a decision maker how they should consider this issue in a planning application.

Comment

Representation ID: 22354

Received: 11/10/2021

Respondent: Canal & River Trust

We support the requirement, where possible, for existing links such as the canal network to be
enhanced. This is consistent with policy ENV7. We have suggested amendments to policy DEL1, above, to further support this.

As well as providing opportunities for sustainable travel within the Black Country, the canal network provides opportunities for sustainable travel to/from neighbouring areas. We note that nothing within policy TRAN5 excludes the possibility of improving such links but we would suggest that the supporting text is amended to confirm this. At present, much of paragraphs 9.50 to 9.52 'refers to within the Black Country'

Comment

Representation ID: 22355

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust welcomes the recognition of the importance of linear habitats within policy ENV1(1)(d).

Comment

Representation ID: 22356

Received: 11/10/2021

Respondent: Canal & River Trust

Policy ENV2 is intended to apply to development affecting Special Areas of Conservation. At present this policy only considers Cannock Chase SAC. Paragraphs 10.26 to 10.29 explain that the Fens Pools and Cannock Extension Canal SACs require further consideration. As the owner of these assets and an organisation with knowledge and expertise to provide, the Trust would welcome further engagement with the Black Country Authorities and its consultants in the preparation of the further evidence that has been identified as required. We would welcome the opportunity to review the updated Habitats Regulations Screening Assessment and draft policy ENV2 prior to publication of the draft plan.

We note that para 10.27 states that the Fens Pools SAC is sensitive to changes in air quality and vulnerable to water pollution and that further evidence on air quality impacts is required. We suggest that Fens Pools is also sensitive to recreational pressure. All of these impacts should be considered as part of the evidence base for the plan and policies should be developed accordingly.

Para 10.29 states that air quality has been identified as a threat to the Cannock Extension Canal SAC. The site is also sensitive to water pollution and the potential for this should be considered alongside air quality in the evidence base for the plan and policies should be developed accordingly.

Comment

Representation ID: 22360

Received: 11/10/2021

Respondent: Canal & River Trust

We note the proposals for the development of a Local Nature Recovery Network and Biodiversity Net Gain within this policy. The draft plan also includes a Black Country Nature Recovery Opportunities Map, which shows many of the area's canals within a 'Priority Network Restoration Zone'. We look forward to working with the Black Country Authorities to refine these initiatives and shape policy as the national framework for Nature Recovery and Biodiversity Net Gain takes shape.