Draft Black Country Plan

Comment

Representation ID: 19294

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: Investment in an improved public transport network provides the opportunity to provide well-planned green and blue infrastructure integrated into the network. The value of well-planned green and blue infrastructure with regards the services it provides and in achieving the desired outcomes described in 9.2 and 9.3 should be made clear. Furthermore, it should be set out in the BCP that this will be a requirement in the planning of public transport network improvements from the earliest stages. Further detail on the requirements for green and blue infrastructure investment should be described in each of the Transport policies.

Support

Representation ID: 21307

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the broad range and detail of the Environmental Transformation and Climate Change policies in the BCP, including the addition of new policies such as ENV3, ENV4 and ENV6 which respond to emerging national legislation and evidence of the value that the natural environment provides the communities of the Black Country.

Comment

Representation ID: 21308

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBBC request an additional Environmental Transformation policy is added concerning the protection, enhancement and investment in river corridors. The value that rivers provide society with regards climate change mitigation and adaptation, flooding, air quality, access and health and wellbeing is increasingly understood. The WMCA Environment Plan 2021 identifies river corridors as a priority action and recognises the value that they provide, identifying the River Stour as a focus. Whilst recognising that Policy CC5 includes appropriate actions for rivers, a strong standalone policy is required to fully maximise the opportunity that river corridors provide to deliver many of the BCP’s ambitions.

Support

Representation ID: 21309

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Introduction
10.2
Support: WTBBC support the recognition in the BCP that the protection and improvement of the Black Country’s biodiversity and geodiversity will improve the attractiveness of the area for people to live, work, study and visit while at the same time improving the physical and natural sustainability of the conurbation in the face of climate change.

Comment

Representation ID: 21310

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Introduction
10.5
Comment: Whilst acknowledging that the BCP recognises the importance of green infrastructure in achieving a healthy and stable environment, WTBBC do not feel this is reflected adequately throughout the Plan. There are numerous opportunities throughout the BCP to further reference and require consideration for and investment in the natural environment and green and blue infrastructure. This is reflected in our comments on the various sections and policies of the BCP. Furthermore, this paragraph should reference the inclusion of the Local Nature Recovery Network in Policy ENV3.

Comment

Representation ID: 21311

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Nature Conservation - Spatial Objectives
10.8
Comment: WTBBC support the recognition in the BCP that the protection and improvement of the Black Country’s biodiversity and geodiversity will safeguard and improve the environmental attractiveness and value of the area for residents and visitors while at the same time improving the physical and natural sustainability of communities within the conurbation in the face of climate change. This paragraph should, however, make more detailed and explicit reference to the broad range of valuable ecosystem services that the natural environment provides the communities of the Black Country.

Object

Representation ID: 21313

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Policy ENV1 – Nature Conservation
1b
Object: WTBBC object strongly to the exclusion of Sites of Local Importance for Nature Conservation (SLINCs) from this point. The National Planning Policy Framework (NPPF) does not distinguish between types of designated Local Wildlife Sites and there is therefore no planning justification for this approach being taken in the BCP. Furthermore, the NPPF states that Local Plans should identify, map and 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.
Object: WTBBC object strongly to the exclusion of Sites of Local Importance for Nature Conservation from this point. Defra Group guidance on the production of Local Nature Recovery Maps states that Local Wildlife Sites should be included in Core Areas, and that the focus in these areas is on improving the condition of habitats, restoring natural ecosystem function and expanding the area of sites. As per this guidance all locally designated sites of importance for biodiversity have been included in the Draft Black Country Local Nature Recovery Opportunity Map commissioned by the BCA and published as Appendix 18 in the BCP.

Comment

Representation ID: 21314

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Policy ENV1 – Nature Conservation
1b
Comment: WTBBC request that the wording ‘development is not permitted where it would harm’ should be changed to ‘development will not be permitted where it would, alone or in combination with other plans or projects, have an adverse impact on’. This change would recognise the negative impact that nearby land-use or other changes can have on sites of high biodiversity value.

Object

Representation ID: 21315

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Policy ENV1 – Nature Conservation
1c
Object: WTBBC object strongly to inclusion of Sites of Local Importance for Nature Conservation in this point. The National Planning Policy Framework (NPPF) does not distinguish between types of designated Local Wildlife Sites and there is therefore no planning justification for this approach being taken in the BCP. SLINCs should be excluded from this point and included in 1b where their protection is provided by the assertion that development is not permitted where it would harm designated nature conservation sites.

Support

Representation ID: 21316

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Policy ENV1 – Nature Conservation
1d
Support: WTBBC support the that the movement of wildlife within the Black Country and its adjoining areas, through both linear habitats (e.g. wildlife corridors) and the wider urban matrix (e.g. stepping-stone sites) is not impeded by development. This point should, however, make explicit reference to the Draft Black Country Local Nature Recovery Opportunity Map and Strategy and the ecological network as identified in this.