Draft Black Country Plan

Comment

Representation ID: 21317

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1e
Comment: Whilst supporting that species that are legally protected, in decline, are rare within the Black Country or that are covered by national, regional, or local Biodiversity Action Plans will be protected as far as possible when development occurs, WTBBC request that ‘where possible’ be removed and replaced by a statement making clear the expectation of development with regards the protection of species. This could be achieved through a commitment to reviewing relevant Supplementary Planning Documents.
2
Comment: Whilst supporting that adequate information must be submitted with planning applications for proposals that may affect any designated site or important habitat, species, or geological feature, WTBCC request that the policy clearly state that a Local Site Assessment must be undertaken and submitted to the Local Sites Partnership where development is likely to impact upon a Site of Importance for Nature Conservation, Site of Local Importance for Nature Conservation or Potential Site of Importance.
Comment: Whilst supporting that adequate information must be submitted with planning applications for proposals that may affect any designated site or important habitat, species, or geological feature, WTBCC request that this point clearly states that supporting information must include a data search from the Local Environmental Records Centre for Birmingham and the Black Country (EcoRecord).
3
Comment: WTBBC request that clarification is provided in this point as to what would comprise strategic benefits of a development that clearly outweigh the importance of a local nature conservation site, species, habitat or geological feature. Furthermore, a clear statement that clarifies by what mechanism applications of this type will be assessed and what relevant stakeholders will be consulted should be provided.
4
Comment: WTBBC request that this point should clearly state that the Local Environmental Records Centre for Birmingham and the Black Country (EcoRecord) hold, collate and disseminate the definitive and up-to-date register of locally designated nature conservation sites on behalf of the BCA.
5
Comment: WTBBC request that an expectation that all canal and natural watercourse-side developments will deliver an improved and extended wildlife corridor for both wildlife and people be added to this point, and that this should be informed by the Black Country Local Nature Recovery Opportunity Map and Strategy as described in Policy ENV3.
6
Comment: WTBBC request that this point should clearly state that details of how improvements (appropriate to their location and scale) will contribute to the natural environment should be informed by the Black Country Local Nature Recovery Opportunity Map and Strategy as described in Policy ENV3, and that details of how this is to be achieved are provided in documents accompanying planning applications.

Comment

Representation ID: 21327

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
Comment: WTBBC request that a paragraph be added to the justification of Policy ENV1 that states the process by which Sites of Importance for Nature Conservation and Sites of Local Importance for Nature Conservation are identified and selected. This should describe the role and membership of the Local Sites Partnership, reference the Birmingham and Black Country Local Sites Selection Guidance document, and outline the process by which recommendations are received, considered and endorsed by the Local Sites Partnership. The addition of this paragraph will provide clarity and transparency for all stakeholders including LPA officers, developers and members of the public.

Support

Representation ID: 21328

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification 10.10
Support: WTBBC support the recognition of the important role the Black Country can play in helping species migrate and adapt to climate change as their existing habitats are rendered unsuitable, and that it is very important to increase the ability of landscapes and their ecosystems to adapt in response to changes in the climate by increasing the range, extent, and connectivity of habitats. Furthermore, WTBBC support reference to the emerging Black Country Local Nature Recovery Strategy, and the assertion that species dispersal will be aided whilst fragmentation and weakening of wildlife sites and wildlife corridors by development will be opposed.
10.11
Support: WTBBC support the BCA’s commitment to meeting their “Biodiversity Duty” under the Natural Environment and Rural Communities Act (2006) and to delivering the principles of the NPPF by proactively protecting, restoring and creating a richer and more sustainable wildlife and geology.

10.12
Support: WTBBC support the BCA’s commitment to partnerships’ work to identify, map, and regularly review the priorities for protection and improvement throughout the Black Country, in accordance with the emerging Black Country Local Nature Recovery Strategy, and that this will be used to inform planning decisions.

Comment: WTBBC request that the Birmingham and Black Country Local Nature Partnership is added to the list of partnerships in paragraph 10.12.

Comment

Representation ID: 21339

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Primary Evidence
Comment: The Draft Local Nature Recovery Opportunity Map and components description (published as Appendix 18 in the BCP) should be added to the list of Primary Evidence.

Comment

Representation ID: 21340

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Delivery
Comment: Development and implementation of Black Country Nature Recovery Network should be changed to Development and implementation of the Black Country Local Nature Recovery Strategy.

Support

Representation ID: 21341

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

10.17
Support: WTBBC support that recognition in the BCP that development over the plan period may adversely affect Special Areas of Conservation and that a policy approach is required to address any identified potential impacts.

Object

Representation ID: 21342

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1c
Object: Policy ENV2 refers only to Cannock Chase SAC. Whilst recognising that reference is made in the policy justification that a specific approach may be required in the Publication BCP for Fens Pools SAC and Cannock Extension Canal SAC, WTBBC object to their exclusion from the Drat BCP Policy ENV2. These sites receive the same level of legal recognition and protection as Cannock Chase SAC and therefore the Publication version of ENV2 must provide equal avoidance and mitigation measures for these sites to any adverse impact upon them through development over the plan period.
Object: WTBBC are of the view that avoidance rather than mitigation measures to any adverse impact upon the integrity of Cannock Chase SAC should be pursued in the Black Country. This can be achieved through investment in natural landscapes within the Black Country that provide similar opportunities for leisure and contact with the natural environment to that which is provided by Cannock Chase SAC, thereby encouraging residents of the Black Country to visit these areas as an alternative to Cannock Chase.

Comment

Representation ID: 21343

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: The Draft Black Country Local Nature Recovery Strategy identifies Core Landscapes in the Walsall green belt where the restoration and expansion of heathland is a priority. Natural England have similarly identified this area as part of their Midlands Heathland Heartland initiative. Partners including WTBBC are working with Natural England on a strategy to realise a vision of a greatly expanded heathland landscape with open access. The BCP should support this initiative and provide funds through financial contributions from development likely to have an adverse impact upon the integrity of Cannock Chase SAC, and through Biodiversity Net Gain contributions (ENV3).

Comment

Representation ID: 21358

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
Comment: The Draft Black Country Local Nature Recovery Strategy identifies Core Landscapes in the Walsall green belt where the restoration and expansion of heathland is a priority. Natural England have similarly identified this area as part of their Midlands Heathland Heartland initiative. Partners including WTBBC are working with Natural England on a strategy to realise a vision of a greatly expanded heathland landscape with open access. The BCP should support this initiative and provide funds through financial contributions from development likely to have an adverse impact upon the integrity of Cannock Chase SAC, and through Biodiversity Net Gain contributions (ENV3).

Comment

Representation ID: 21359

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: The Draft Local Nature Recovery Opportunity Map and components description (published as Appendix 18 in the BCP) should be added to the list of Primary Evidence.