Draft Black Country Plan

Object

Representation ID: 18506

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

2d
Object: The statement ‘Delivering a limited number of Neighbourhood Growth Areas in highly sustainable locations on the edge of the Urban Area’ underplays the impact on the Black Country landscape of these allocations. The term Neighbourhood Growth Areas refers to large-scale developments on greenfield sites and this should be clear. It should also be clear that these allocations are predominantly in the existing green belt.

Support

Representation ID: 18507

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

2f
Support: WTBBC support protecting the Black Country’s character and environmental assets including heritage assets, natural habitats and open spaces.

Comment

Representation ID: 18508

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

2g
Comment: The statement minimising and mitigating the likely effects of climate change should be expanded to reference the multiple benefits of green infrastructure in minimising and mitigating the likely effects of climate change and utilising nature-based solutions to meet this aim.
Justification

Object

Representation ID: 18509

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
Object: No reference is made in this section to evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC.
In October 2019 WTBBC and EcoRecord (the Local Environmental Records Centre) submitted An Ecological Evaluation of the Black Country Green Belt. This comprehensive study analysed a wide range of datasets and assigned a relative ecological value to individual landscape units.
This report was subsequently published on the Black Country Plan website as part of the Evidence Base, however, no reference is made to its findings being used in the Development Strategy or Site Assessment process.
Object: No reference is made in this section to evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC.
In April 2021 WTBBC and EcoRecord (the Local Environmental Records Centre) submitted a Draft Local Nature Recovery Opportunity Map (and a description of the components of this) which has been published as Appendix 18 in the BCP.
No reference is made to its findings being used in the Development Strategy or Site Assessment process.

Comment

Representation ID: 18511

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.5
Comment: WTBBC have concluded through analysis of data that not all the sites allocated for development in the BCP are sustainable and deliverable. Furthermore, from a biodiversity and ecological network perspective some of these do, indeed, breach the environmental capacity of the area. These statements if made should be caveated with a statement that this is the view of the BCA. Further detail of the findings of our analysis are given in our response to individual allocations.

Comment

Representation ID: 18512

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.7
Comment: It is WTBBC’s view that the Spatial Options Paper oversimplifies the spatial options available to the BCA in their preparation of the BCP. Whilst WTBBC support the approach of Option J Balanced Growth with its emphasis on focusing growth within existing residential and employment areas alongside a limited number of new growth areas, this option should not be pursued to the exclusion of Option G Garden Village/Urban Greening. WTBBC support Option G’s focus on more open space which supports the Nature Recovery Strategy (funded by BNG) and this approach should be followed in all Neighbourhood Growth Areas in the BCP.

Object

Representation ID: 18513

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Object: The evidence commissioned by and provided to the BCA in their preparation of the BCP by WTBBC should be included in this list:
- An Ecological Evaluation of the Black Country Green Belt (2019)
- Draft Local Nature Recovery Opportunity Map and component descriptions (2021)

Support

Representation ID: 18514

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3b
Support: WTBBC support the recognition of the value of a high quality natural environment in Strategic Centres and the inclusion of this in Policy CSP2.
4d
Support: WTBBC support the recognition of the value of linked comprehensive networks of attractive green infrastructure in Core Regeneration Areas linking the Strategic Centres and the inclusion of this in Policy CSP2.

Object

Representation ID: 18515

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1bi and 1d
Object: The statement ‘A network of new Neighbourhood Growth Areas providing 6,792 homes, in highly sustainable locations on the edge of the Urban Area’ underplays the impact on the Black Country landscape of these allocations. The term Neighbourhood Growth Areas refers to for large-scale developments on greenfield sites and this should be clear. It should also be clear that these allocations are predominantly in the existing green belt.

Comment

Representation ID: 18516

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1e
Comment: WTBBC support the aim of delivering an integrated and continuous (where possible) network of green infrastructure, walking and cycling routes. The importance of this should be emphasised through it being in a separate point to a network of centres, health, leisure and community facilities.
1g
Comment: WTBBC support a defensible green belt to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents. WTBBC do not support the use of ‘where possible’ in reference to the landscape being safeguarded and enhanced for its heritage, recreation, agricultural and nature conservation value. This caveat allows for the redrawing of green belt boundaries as proposed elsewhere in the plan, but its use here weakens the BCA’s assertion that the green belt is valued for the benefits it provides the Black Country.