Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you
Representation ID: 176
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
The Core Strategy includes robust environmental policies. We support a partial review and have provided advice to make policy ENV1 clearer and more robust and advice where other policy changes may affect decisions pertaining to the natural environment.
We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157.
The Core Strategy includes robust environmental policies. We support a partial review and have provided advice to make policy ENV1 clearer and more robust and advice where other policy changes may affect decisions pertaining to the natural environment.
We would also like to see greater reference to the Birmingham and Black Country Nature Improvement Area (NIA). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157.
Object
Black Country Core Strategy Issue and Option Report
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there
Representation ID: 177
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
We welcome the Ecological Network Study and Strategic Mapping to provide robust, up-to-date and comprehensive evidence. These should build on the NIA ecological network mapping. The Wildlife Trust can provide advice on their scope and methods.
We would also particularly welcome a review of land outside designated sites to identify further sites meeting SINC selection criteria. These may not have been assessed since 1977 and could have changed dramatically. NIA mapping provides a robust framework to target survey effort.
We would also welcome a review of data-sets regarding Geological Heritage Consideration Zones.
We welcome the Ecological Network Study and Strategic Mapping to provide robust, up-to-date and comprehensive evidence. These should build on the NIA ecological network mapping. The Wildlife Trust can provide advice on their scope and methods.
We would also particularly welcome a review of land outside designated sites to identify further sites meeting SINC selection criteria. These may not have been assessed since 1977 and could have changed dramatically. NIA mapping provides a robust framework to target survey effort.
We would also welcome a review of data-sets regarding Geological Heritage Consideration Zones.
Support
Black Country Core Strategy Issue and Option Report
Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
Representation ID: 181
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
We welcome an evidence based review of greenbelt function but urge you to extend this across all of the Black Country, not just greenbelt. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife, geodiversity and people as some greenbelt sites. We would like to refer you to the Wildlife and Countryside Link guidance on Permission in Principal and Brownfield Registers of land for further information on this.
The Wildlife Trust can provide advice on conducting such a study.
We welcome an evidence based review of greenbelt function but urge you to extend this across all of the Black Country, not just greenbelt. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife, geodiversity and people as some greenbelt sites. We would like to refer you to the Wildlife and Countryside Link guidance on Permission in Principal and Brownfield Registers of land for further information on this.
The Wildlife Trust can provide advice on conducting such a study.
Object
Black Country Core Strategy Issue and Option Report
Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be
Representation ID: 182
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
For Key Issue 5 we welcome the commitment to make provision for environmental infrastructure (Paragraph 3.35) although would like to see a greater emphasis on allocating land for this within policies. The Wildlife Trust can provide guidance for this commitment building on existing NIA mapping .
We welcome the recognition in Paragraph 3.38 that designated sites may be affected by developments beyond their boundaries. We hope that this principal will be adopted for all nature conservation sites within the Black Country. This may be an area in which additional ecological support may be beneficial for local authorities.
For Key Issue 5 we welcome the commitment to make provision for environmental infrastructure (Paragraph 3.35) although would like to see a greater emphasis on allocating land for this within policies. The Wildlife Trust can provide guidance for this commitment building on existing NIA mapping .
We welcome the recognition in Paragraph 3.38 that designated sites may be affected by developments beyond their boundaries. We hope that this principal will be adopted for all nature conservation sites within the Black Country. This may be an area in which additional ecological support may be beneficial for local authorities.
Object
Black Country Core Strategy Issue and Option Report
Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
Representation ID: 183
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
We strongly disagree with the principle of always prioritising brownfield sites for development. Urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some greenbelt sites. We would like to refer you to the Wildlife and Countryside Link guidance on Permission in Principal and Brownfield Registers of land for further information. All sites should be assessed on the same merits regardless of location. Whilst the re-use of brownfield sites is encouraged in the NPPF, Paragraph 111 states that this is only when they do not have high environmental value.
We strongly disagree with the principle of always prioritising brownfield sites for development. Urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some greenbelt sites. We would like to refer you to the Wildlife and Countryside Link guidance on Permission in Principal and Brownfield Registers of land for further information. All sites should be assessed on the same merits regardless of location. Whilst the re-use of brownfield sites is encouraged in the NPPF, Paragraph 111 states that this is only when they do not have high environmental value.
Object
Black Country Core Strategy Issue and Option Report
Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate
Representation ID: 184
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
Given that paragraph 1.1 of this document states that one of the three main purposes of the strategy is to direct environmental activity to the right places it is surprising that there is no spatial objective that explicitly allows for the provision of green infrastructure. Environmental Infrastructure is one of the five strategic policies subsequently set out in the document but this would be greatly strengthened if it were backed up by an explicit spatial objective such as "safeguard existing environmental assets and take opportunities to improve environmental infrastructure to support wildlife populations and provide other ecosystem services".
Given that paragraph 1.1 of this document states that one of the three main purposes of the strategy is to direct environmental activity to the right places it is surprising that there is no spatial objective that explicitly allows for the provision of green infrastructure. Environmental Infrastructure is one of the five strategic policies subsequently set out in the document but this would be greatly strengthened if it were backed up by an explicit spatial objective such as "safeguard existing environmental assets and take opportunities to improve environmental infrastructure to support wildlife populations and provide other ecosystem services".
Object
Black Country Core Strategy Issue and Option Report
Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.
Representation ID: 185
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
Object
Black Country Core Strategy Issue and Option Report
Question 12a - Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing re
Representation ID: 186
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
Object
Black Country Core Strategy Issue and Option Report
Question 13a - Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibi
Representation ID: 187
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
Object
Black Country Core Strategy Issue and Option Report
Question 13b - What infrastructure do you think would be needed for different sizes of SUEs?
Representation ID: 188
Received: 07/09/2017
Respondent: Birmingham and the Black Country Wildlife Trust
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
From an environmental perspective it would be preferable if the selection of sites were undertaken using an evidence based approach that weighs up the pros/cons of each individual site. The impact on and potential benefits for the provision of green and environmental infrastructure should be one of the characteristics used in the assessment of sites. This is not currently referred to in the opportunities and challenges tables for the different approaches.
Assessing each proposed development on its merits rather than using a broad-brush approach provides a genuine spatial choice that enables better sustainable development.
