Draft Black Country Plan

Support

Representation ID: 21692

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV6, its scope and recognition of a broad range of valuable geological features. WTBBC consider Policy ENV6 to be innovative in the context of Local Plan policy.

Support

Representation ID: 21697

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV7, its scope and recognition of a broad range of features and characteristics which are of value to both the built and natural environment, and the level of detail that is included in the wording of both the policy and the justification.

Comment

Representation ID: 21725

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBCC request that a point is added requiring all developments to retain or create a buffer of vegetation to each side of the canal corridor where this is appropriate to the historic environment. Canal corridors are a key component of the ecological network of the Black Country as evidenced in the Draft Local Nature Recovery Opportunity Map (Appendix 18 of the BCP). New developments should therefore be expected to retain and create both aquatic and terrestrial habitats and be discouraged from hard landscaping up to the canal edge.
2c
Comment: WTBCC request that stronger policy wording is included for the retention and restoration, or where absent the construction of sensitive, boundary treatments including walls and other structures associated with the historic environment (including those constructed of furnace slag, locally quarried stone and pre-1939 bricks).
2g
Comment: Whilst supporting the reinstatement and / or upgrading of towpaths and linking them into high quality wider pedestrian and cycle networks, WTBBC request that wording is added to this paragraph that states this should not be undertaken where valuable towpath habitats are lost. For example, the narrow strips of vegetation to each side of towpaths are a characteristic feature of the Black Country canal network. These frequently support a diverse and valuable assemblage of plant species associated with both aquatic and terrestrial habitats that is not found elsewhere in the Black Country. It is important that this habitat is retained.

3d
Comment: WTBCC request that stronger policy wording is included on the layout of new developments regarding providing active frontages onto the canal, stating that only in exceptional circumstances will side and rear boundaries be allowed to face the canal.

Comment

Representation ID: 21727

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: WTBBC request that a paragraph is added to the justification of Policy ENV7 that describes the high ecological value (Priority habitats and protected species) of the Black Country’s canal network and its key role in the ecological network as evidenced in the Draft Local Nature Recovery Opportunity Map (Appendix 18 of the BCP).

Comment

Representation ID: 21730

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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: 22244

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Support: WTBBC support the inclusion of Policy ENV8 and, whilst supporting all the Policy points, have suggested changes and additions to a number of these. Explicit support is given to those which WTBBC consider to be of particular significance in the context of the protection and enhancement of the natural environment.
10.107
Support: WTBBC support the recognition that all development proposals should recognise the values and functions of open space as set out in Government policy and guidance, and also address as appropriate various functions of open space that are of particular importance in the Black Country.
3b
Support: WTBBC support that each local authority will set out proposals for specific open spaces that address the priorities set out in the Draft Black Country Local Nature Recovery Strategy.
3cii
Support: WTBBC support protecting the existing greenway network for recreation and biodiversity and taking opportunities to strengthen and expand the 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.

Comment

Representation ID: 22245

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1g
Comment: WTBBC welcome the BCP’s recognition of the role of open space in preserving and enhancing diversity in the natural and built environment and preventing the fragmentation of habitat networks. WTBBC are of the view, however, that the policy would be stronger if the built and natural environment are included as separate points.
1h
Comment: WTBBC support strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network. This point links with Policy CSP4 point 6: the pursuance of an integrated and well-connected multifunctional open space 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.

Comment

Representation ID: 22246

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

10.155
Comment: WTBBC support the recognition of the value of greenways in the BCP and the acknowledgment of the need to invest in and improve the network. WTBBC are of the view that there is clear link between the network of greenways and the Local Nature Recovery Network, and that the opportunity to invest will benefit the aspirations of both. WTBBC therefore request that this link is referenced in this paragraph. Furthermore, the opportunity to further increase both the extent and quality of greenways along the Black Country’s network of rivers and streams should be made more strongly.

Comment

Representation ID: 22247

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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: 22248

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

WTBBC support the inclusion of Policy ENV9, the recognition of the link between high-quality design and climate change, and the need to ensure development has no harmful impacts on key environmental assets (Policies ENV1 and ENV3).