Draft Black Country Plan

Comment

Representation ID: 21360

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Delivery
Comment: A full spatial strategy with identified funding mechanisms for the Midlands Heathland Heartland initiative in the Walsall green belt should be included in the delivery of Policy ENV2.

Support

Representation ID: 21673

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC welcome the inclusion of Policy ENV3 Nature Recovery Network and Biodiversity Net Gain, and that WTBBC were invited to provide wording for the policy during the preparation of the Draft BCP. The policy will necessarily be required to be updated for the Publication BCP in response to emerging guidance and legislation relating to Nature Recovery Network and Biodiversity Net Gain (notably the government’s Environment Bill expected to receive Royal Assent in autumn 2021). WTBBC are able to provide further support to the BCA regarding Policy ENV3 during the preparation of the Publication BCP.

Support

Representation ID: 21674

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV4 and the level of detail that is included in the wording of both the policy and the justification. Whilst supporting all the points in Policy ENV4, we have suggested changes and additions to a number of these, and have given explicit support to those which are of particular significance and which WTBBC consider to be innovative in the context of Local Plan policy.
10.53
Support: WTBBC support the recognition of the importance of encouraging and supporting the delivery of green infrastructure and ecological networks through urban areas, especially in relation to their role in climate change mitigation and adaptation and to mitigate the health problems associated with air pollution.

Comment

Representation ID: 21676

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

10.54
Comment: WTBBC request that the evidence used to calculate the target increase in canopy cover to at least 18% over the plan period is published in the BCP.

Support

Representation ID: 21682

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

10.54
Support: WTBBC support the recognition of the importance of identifying the opportunities for tree planting by following the evidence provided in the Draft Black Country Local Nature Recovery Strategy. It should be added to the paragraph that that ecosystem services evidence should be produced and followed in order to maximise the benefits of tree planting for biodiversity and climate change mitigation, and also recognised that tree planting is often not ecologically appropriate.
1
Support: WTBBC support that development that would result in the loss of or damage to ancient trees, ancient woodland or veteran trees will not be permitted.
17
Support: WTBBC support that replacement trees located off-site should not be planted where they would impact on areas designated as ecologically important unless this has been specifically agreed with the relevant authority and its ecological officers / advisers.
24
Support: WTBBC support that there will be a presumption against the wholesale removal of hedgerows for development purposes, especially where ecological surveys have identified them to be species-rich and where they exist on previously undeveloped land.

Comment

Representation ID: 21684

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1
Comment: WTBBC support that development adjacent to ancient woodland will be required to provide an appropriate landscaping buffer, but request that a larger minimum depth of 25m be required, and that the policy state that only in exceptional circumstances would a buffer of less than 50m be permitted. Furthermore, it should be added that developments adjacent to ancient woodland will be required to be orientated so as to face these in order to reduce negative impacts associated with proximity to residential developments such as the introduction of non-native plant species.
4
Comment: WTBBC request that the evidence used to calculate the target increase in canopy cover to at least 18% over the plan period is published in the BCP.


8
Comment: WTBBC request the wording of this point is changed to reflect and reinforce the importance of following the evidence provided by the Draft Local Nature Recovery Strategy, recognising that tree planting is often not the most ecologically appropriate action. Furthermore, it should be stated that ecosystem services evidence should be produced and followed in order to maximise the benefits of tree planting for biodiversity and climate change mitigation by ensuring this is undertaken in the most appropriate locations.
12
Comment: WTBBC support the recognition of the value of large canopied street trees and that the planting of these should be included in all new residential developments and other significant proposals. This should go further, however, and encourage the planting of new street trees in existing residential and employment areas to maximise the wide range of health, biodiversity and climate change mitigation and adaptation benefits. The opportunity to fund the retro-fitting of street trees through Biodiversity Net Gain contributions should be explored, especially as this is expected to provide resources to manage these for a period of 30 years.
13
Comment: Whilst supporting the minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site in new developments, this should be caveated to state that this will not be required if this would lead to damage or loss of existing habitats of value that may otherwise be retained.
16
Comment: WTBBC support that replacement trees of a suitable species must be provided on site where planning permission has been granted that involves the removal of these, and that where sufficient and suitable onsite replacements cannot be provided, off-site planting or woodland enhancement must be provided in the near vicinity of the removed tree(s). Off-site street trees of large-canopied species should be added to the options for delivering this compensation.
25
Comment: WTBBC request that it is added to this point that replacement hedgerows should be of a suitable diverse mix of locally sourced native species, and that a resourced maintenance and management programme will be required that will include the replacement of plants that fail within a specified period by plants of a suitable size, species and quality.

26
Comment: Whilst supporting that the protection of hedgerows before and during development must be undertaken, WTBBC request that the policy states a minimum landscape buffer of 25m will be required, and that only in exceptional circumstances would a buffer of less than 50m be permitted.
27
Comment: Whilst supporting the creation of new hedgerows as part of site layouts and landscaping schemes, WTBBC request that it be added that these should be of a suitable diverse mix of locally sourced native species, and that a resourced maintenance and management programme will be required that will include the replacement of plants that fail within a specified period by plants of a suitable size, species and quality.

Support

Representation ID: 21688

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Justification
10.57
Support: WTBBC support the inclusion of this paragraph and the recognition of the value of wildlife corridors. Furthermore, the inclusion of points such as e) making sure that any new planting is in the right location and of the right species, and f) recognising that woodlands are not simple monoculture habitats and will also contain glades, wet areas, understoreys and grassland, is of particular value in the context of Policy ENV4.
10.61
Support: WTBBC support the recognition of the broad range of ecosystem services benefits that trees in the urban landscape provide.
Trees on development sites
10.67
Support: WTBBC support the inclusion of this paragraph and its aim of eliminating the practice of clearing vegetation from a site prior to the submission of a planning application.
Ancient woodland and veteran trees
10.69
Support: WTBBC support the recognition of ancient woodland and veteran trees as irreplaceable habitat.
Hedgerows
10.73
Support: WTBBC support the recognition that hedgerows are integral to ecological networks, given their linear form, and will be essential elements of habitat linkages within and beyond the Black Country. Planting additional hedgerows will help to support and increase the movement of wildlife and plants through the Black Country.

Comment

Representation ID: 21689

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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 Evidence.

Support

Representation ID: 21690

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV5, its scope and recognition of a broad range of features and characteristics which contribute to locally distinctive character, and the level of detail that is included in the wording of both the policy and the justification.

Comment

Representation ID: 21691

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBBC support the inclusion of features (both natural and made-made) which contribute to local distinctive character of the Black Country’s open spaces and surviving rural landscapes. WTBBC are of the view that the policy could be further strengthened by the inclusion of other habitat features beyond those currently included (e.g. hedgerows, holloways, banks, ditches, field systems, ridge and furrow, areas of open space, woodland and watercourses) to include other habitats and features of historic origin that are a valuable contributor to distinctive character. These should include heathland, permanent grassland (pastures and meadows), colliery spoil tips, furnace slag and historic quarries.