Draft Black Country Plan

Comment

Representation ID: 18517

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
3.48
Comment: WTBBC support that individual sites (as defined in Policy CSP3) in each of the Neighbourhood Growth Areas are master-planned together. Reference should be made in this paragraph not only to infrastructure needs but also to green and blue infrastructure provision. Furthermore, the collaborative process for masterplanning as set out in the paragraph should include reference to relevant natural environment stakeholders such as the Local Nature Partnership.

Comment

Representation ID: 18523

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Green belt
Comment: WTBBC support the recognition of the valuable contribution that surrounding countryside and the network of green wedges and corridors provides the Black Country. WTBBC do not support the use of ‘where practical and possible’ in reference to the landscape, nature conservation and agricultural land being protected and enhanced. 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 and the network of green wedges and corridors is valued for the benefits it provides the Black Country.

Comment

Representation ID: 18525

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: A point should be added to the policy that directly references the statement made in Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain that all development shall deliver the Local Nature Recovery Network Strategy, and that these will take account of where in the Local Nature Recovery Network the development is located and deliver benefits appropriate to that zone.

Support

Representation ID: 18527

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

6
Support: WTBBC support the pursuance of an integrated and well-connected multifunctional open space network. This point links with Policy ENV8: strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network. WTBBC are of the view that to fully realise many of the BCP’s aspirations that mapping of the existing multifunctional green space and greenway network should be undertaken in parallel with the Local Nature Recovery Strategy. This will enable targeted investment in the network which maximises biodiversity, social and a range of other ecosystem services benefits.

7
Support: WTBBC support the recognition of the value of protecting and enhancing the Black Country canal network in achieving well-designed places.

Comment

Representation ID: 18533

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: It is WTBBC’s view that a paragraph should be added to this section that highlights the value of the natural environment and green and blue infrastructure in achieving well-designed places. Furthermore, this should acknowledge the value of the ecosystem services the natural environment provides the Black Country, and state that this will be invested in to fully deliver well-designed places.

Comment

Representation ID: 19067

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: It is WTBBC’s view that a point should be added to the policy that directly references the statement made in Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain that all development shall deliver the Local Nature Recovery Network Strategy, and that these will take account of where in the Local Nature Recovery Network the development is located and deliver benefits appropriate to that zone.

Comment

Representation ID: 19068

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: It is WTBBC’s view that a paragraph should be added that highlights the Draft Local Nature Recovery Opportunity Map (Appendix 18 of the BCP). The Opportunity Map identifies the importance of the green belt in the ecological network of the Black Country, and allocates all of this to Core Landscapes. The Draft Black Country Local Nature Recovery Strategy (WTBBC and EcoRecord 2021) identifies the key habitats and species in each Core Landscape and prescribes focus actions and measures which seek to enhance and increase the biodiversity value of the green belt.

Object

Representation ID: 19207

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3.77b
Object: Woodland planting should be removed and replaced with habitat creation appropriate to the location as defined in the Draft Black Country Local Nature Recovery Strategy (WTBBC and EcoRecord 2021). The planting of trees and woodland may not be the most ecologically appropriate form of habitat creation, and any habitat enhancements should be informed by the Priority habitats selected as focus actions in the Draft LNRS. Furthermore, the inclusion of tree planting here is likely to influence masterplanners and developers to propose this as habitat loss mitigation whereas they should be directed by the evidence provided in the Draft LNRS.

Object

Representation ID: 19208

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

4 Infrastructure & Delivery
Delivery Constraints
4.6
Object: WTBBC object to the term brownfield-first being used in the BCP. This suggests all land previously occupied by a permanent structure is low value with regards ecosystem services. In the Black Country many sites of high aesthetic, wildlife or health and wellbeing value are post-industrial or have been previously occupied by a structure. The NPPF is clear in its definition of previously developed land that this excludes sites ‘where the remains of the permanent structure or fixed surface structure have blended into the landscape’. This term is widely understood and should be used in place of brownfield throughout the BCP.

Comment

Representation ID: 19211

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

4.8
Comment: Paragraph 4.8 acknowledges that greenfield sites are often quicker and easier to develop than sites in the urban area. It is WTBBC’s view that in response to this reality sites should be released in phases of five years over the life of the plan, with appropriate urban sites released first, thereby avoiding releasing greenfield sites that may later be found to be surplus to requirement through changes in housing demand. This approach will prevent developers ‘cherry-picking’ the most profitable greenfield sites at the expense of the green belt and natural environment, whilst ensuring appropriate urban sites are not left undeveloped.