Draft Black Country Plan

Comment

Representation ID: 18495

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1.4
Comment: A point should be added stating that the BCP will provide a policy framework to support the commitments of the government’s 25 Year Environment Plan and the delivery of the West Midlands Combined Authority Natural Environment Plan.
Comment: A point should be added stating that the BCP will provide a policy framework that recognises, encourages investment in and capitalises on the value and benefits that the natural environment provides to the communities of the Black Country.

Comment

Representation ID: 18496

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: Under the duty to cooperate local authorities are required to cooperate with Local Nature Partnerships (LNPs) and must have regard to their activities when preparing local plans. This requirement is the same as that for Local Enterprise Partnerships. No reference is made in the BCP to the Birmingham and Black Country LNP and no evidence is provided in the Statement of Consultation that the LNP was consulted.
This contrasts to the section Black Country Local Enterprise Partnership (1.11 and 1.12) in the BCP, and to the evidence provided in the Statement of Consultation that the LEP was consulted at length.

Comment

Representation ID: 18497

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

A paragraph should be added that describes the natural landscape of the Black Country.
The Black Country Spatial Portrait recognises the significant influence that industrial heritage has on today’s physical environment but not the geological resources that shaped that industry and the pattern of settlement it left behind.
WTBBC welcomes the reference to the influence of the natural environment on health and wellbeing, however, the richness and value of the existing natural environment of the Black Country should be both described and celebrated in a standalone natural environment paragraph.

Support

Representation ID: 18499

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1.43
e) Climate change and protecting and enhancing the environment
Support: WTBBC welcome the BCP’s recognition of the need to address the challenge of mitigating and adapting to the impacts of climate change. WTBBC also welcome recognition of the need to create a strategy for the enhancement and protection of the Black Country’s environment. Explicit reference should be made, however, to the natural environment.

This paragraph could be further strengthened through an explicit recognition of the wide range of benefits (ecosystem services) that the natural environment provides the Black Country, and the need to further understand and invest in green infrastructure to maximise benefits in mitigating and adapting to climate change.

Support

Representation ID: 18500

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

h) Health and Wellbeing
Support: WTBBC welcome the BCP’s recognition of the role of the environment in shaping the social, economic and environmental circumstances that determine health and wellbeing. Explicit separate references should be made, however, to the built and natural environment.

Comment

Representation ID: 18501

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

2.3
Comment: It is WTBBC’s view that the Vision for the Black Country ‘Creating a prosperous, stronger and sustainable Black Country’ could equally apply to the aspirations of any place at any given time. A more localised, unique and ambitious vision should be given which sets the Black Country apart and more directly responds to What is driving the Vision for the Black Country? (2.1).
Comment: WTBBC advocates for a vision that puts the natural world at the centre of decision making and a green transformation of the Black Country. The Black Country landscape should meet the needs of all those who live, work in or visit the area by delivering a prosperous and healthy environment that provides the livelihoods, homes and lifestyles they aspire to.

Comment

Representation ID: 18502

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBBC welcome the equal value that is given to the eight objectives, and that climate change and the natural environment are recognised as being of equivalent importance to housing, economy and transport.
WTBBC are of the view that the built and natural environment are, however, distinct in this context and that the BCP would be stronger and more impactful if these were included as separate objectives.

Comment

Representation ID: 18503

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment:
- Climate Change: WTBBC welcome enhancing the Black Country’s Green and Blue Infrastructure, however, investing in nature-based solutions should also be included.
- Improving the Health and Wellbeing of residents and promoting social inclusion: WTBBC welcome providing a built and natural environment that supports the making of healthier choices, however, equal access for all to high quality natural green space should also be included.
WTBBC welcome providing a natural environment that protects health and wellbeing and the reference to the benefits to society this provides.
Comment:
- Enhancing our natural & built environment: WTBBC welcome the protection and enhancement of the natural environment, biodiversity, wildlife corridors, geological resources, countryside, and landscapes, whilst ensuring that residents have good access to interlinked green infrastructure.
WTBBC welcome protecting, sustaining and enhancing the quality of the built and historic environment whilst ensuring the delivery of distinctive and attractive places.
WTBBC are of the view, however, that the BCP would be stronger if the built and natural environment are included as separate objectives.

Support

Representation ID: 18504

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.1
Support: WTBBC support the aim of the plan to ensure the Black Country benefits from the right development in the right place at the right time, and that this will meet the needs of people living and working in the Black Country, while protecting and enhancing the environment and the unique character of the area.
WTBBC are of the view that this aim would be stronger and more impactful if this read …protecting and enhancing the natural and built environment and the unique character of the area.

Comment

Representation ID: 18505

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Figure 2 - Key Spatial Diagram
Comment: On the Key Spatial Diagram it is difficult to distinguish Core Regeneration Areas from the Black Country Green Belt. Furthermore, the diagram depicts only selected development allocations, which doesn’t make the cumulative extent of the impact of these on the landscape clear. It should be made clear in the key that the diagram only shows a selected number of allocations, or alternatively all allocations should be depicted as points.