Draft Black Country Plan
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Draft Black Country Plan
Policy ENV9 – Design Quality
Representation ID: 22249
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
5
Comment: WTBBC support the recognition of the opportunities that major developments provide in contributing to the greening of the Black Country, and the specific references in points 5a, 5b and 5c to green infrastructure opportunities. WTBBC are of the view, however, that these opportunities can be realised in most developments at any scale, and therefore request that this should not apply only to major developments.
Support
Draft Black Country Plan
Policy CC5 – Flood Risk
Representation ID: 22251
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
12
Support: WTBBC support that developments should, where possible, naturalise urban watercourses (by reinstating a natural, sinuous river channel and restoring the functional floodplain) and open up underground culverts, to provide biodiversity net gain as well as amenity improvements.
Comment
Draft Black Country Plan
Policy CC5 – Flood Risk
Representation ID: 22252
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
15
Comment: Whilst WTBBC support that there should be no built development within five metres of an ordinary watercourse and ten metres of the top of the bank of a main river, these buffers should be given as minimums allowed only in exceptional circumstances. Developers should be expected to provide buffers which protect and, where relevant, increase the extent of the natural environment adjoining the watercourse. Furthermore, whilst WTBBC support the enabling of the preservation of the watercourse corridor, public access and new and improved greenways should also be given as a desired outcome, with links to policies CSP4 and ENV8 made.
Support
Draft Black Country Plan
Policy CC6 - Sustainable drainage and surface water management (SuDS)
Representation ID: 22253
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
1
Support: WTBBC support that all new developments should incorporate SuDS and all development proposals should provide details of adoption, ongoing maintenance, and management of SuDS.
Comment
Draft Black Country Plan
Policy CC6 - Sustainable drainage and surface water management (SuDS)
Representation ID: 22254
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
2
Comment: Whilst WTBBC support that preference will be given to systems that contribute to the conservation and enhancement of biodiversity and green infrastructure in the wider area, a clear link to Policy ENV3 and the delivery of the Draft Black Country Local Nature Recovery Strategy should be made.
Comment
Draft Black Country Plan
Evidence
Representation ID: 22255
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.
Comment
Draft Black Country Plan
Policy MIN3 - Preferred Areas for New Mineral Development
Representation ID: 22256
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
8
Comment: Whilst supporting that due to the constraints of the Brownhills Common site, mineral working is not expected to take place during the plan period, we request that constraints including the site’s nature conservation designation and amenity value are outlined in this point.
Support
Draft Black Country Plan
Policy MIN3 - Preferred Areas for New Mineral Development
Representation ID: 22257
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
9
Support: WTBBC support significant weight being be given to proposals that would allow for the revocation of the existing ‘dormant’ permission at Brownhills Common.
Comment
Draft Black Country Plan
Policy MIN4 - Managing the Effects of Mineral Development
Representation ID: 22260
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
6
Comment: WTBBC are of the view that this point should more strongly support minerals sites restoration plans which deliver significant environmental and social benefits. Existing and proposed mineral extraction sites are located within the Walsall green belt. 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. Policy MIN4 should therefore require mineral sites restoration plans to provide the creation of suitable heathland habitats as identified in the Draft LNRS.
Comment
Draft Black Country Plan
1 Sub-Areas and Site Allocations
Representation ID: 22261
Received: 11/10/2021
Respondent: The Wildlife Trust for Birmingham and the Black Country
13 Sub-Areas and Site Allocations
Comment: WTBBC welcome the BCA’s use of the Site Assessment (selection) process and the evidence that has been collated for and used in this. Many sites put forward through the Call for Sites process where development would have been highly damaging for wildlife, landscape and communities have not been selected as a result of the implementation of this (notable examples are Seven Cornfields in Wolverhampton, the Dudley green belt to the south of Halesowen and numerous sites in the Walsall green belt). A number of sites have, however, been selected where evidence demonstrates they should not, or where significant considerations remain.
Comment: Due to the large number of allocations in the BCP it was necessary to develop a process to determine which sites WTBBC were able to submit evidence-based comments for. Our detailed response to the BCP’s policies provides information on how the remaining allocations should be managed through the planning system.
In summary, we have commented on or objected to sites:
• That the Site Assessment process should not have selected.
• Designated for nature conservation or adjoining these.
• Where a Local Sites Assessment should have been undertaken but has not.
• Of high value for ecological connectivity.
• Understood to be public open space.
Comment: WTBBC understands that any written submission will be transferred by the Black Country Authorities to their digital consultation database which has a 100 word limit per response. Each of our allocation responses has therefore been limited to 100 words. Additional details on our comments, evidence and analysis can be provided subsequent to the consultation deadline upon request. Furthermore, WTBBC are able to provide information regarding the specific development considerations of Strategic Allocations.
For each response given we have preceded this with either Support, Object or Comment as requested in the How to Comment section of the Black Country Plan website.