Black Country Core Strategy Issue and Option Report

We welcome updates of environmental infrastructure requirements based on up to date evidence such as the Natural England Green Infrastructure and Pinch Point analysis. The Wildlife Trust can provide existing data, advice and support in developing new proposals.

To incentivise best practice and reward developers that provide high quality developments that improve environmental infrastructure.

The application of the principals will vary on a site by site basis, as the environmental and social needs will vary between developments. The location of the site on brownfield or greenfield land is likely to influence the site specific requirements, but different standards should not be applied on the basis of a greenfield/brownfield categorisation.

We welcome the proposal to include reference to the Black Country Geopark which is an internationally important initiative supported by the B&BC Wildlife Trust. The proposed list of requirements for new developments should also incorporate protection and enhancement for valued landscapes and geological conservation interests (NPPF paras 109, 113 and 117.)
We welcome the proposed changes to ENV 1 that provide additional protection to irreplaceable habitats and to bring the definition of mitigation in line with NPPF to require compensation for residual negative impacts.
We further recommend that the proposed additional protection for ancient woodlands is extended to include other irreplaceable features such as ancient and veteran trees. The Wildlife Trust can provide advice on the most accurate data sets available to identify such features.
We think that the policy would also further benefit from the following amendments;
* Reference to supporting the NIA and NIA strategy in accordance with Paragraph 117 and 157 of the NPPF.
* Reference to the role of the LNP as defined by the NPPF and Town and Country Planning Regulations (2012).
* Clarification on the level of protection afforded to SINC and SLINC. They are listed separately in the list of development controls suggesting differing levels of protection but the wording is ambiguous as to what the practical difference is. It states that development that "harms" a SINC will not permitted and SLINC are protected from "negative impacts".
* A recognition that development and changes in landuse outside the boundaries of designated site can have impacts on wildlife within designated sites as discussed in paragraph 3.37 of your report. This is applicable to designated sites of every sort, although the zone of influence will vary significantly depending on the importance of the site and the reasons for which it has been designated. To help guide developers it may be worth referencing the potential of lighting, pets, flytipping and the creation of barriers to wildlife movement as factors to be considered.
* The wording for species protection may also benefit from clarification relating to whether it is harm to individuals or populations of the named species groups that is being considered.
We would like to invite you to work with us in making this policy as robust as possible.
We note that this document states that the policy in its current form has protected and enhanced biodiversity across the Black Country. We would be very interested in seeing the evidence for this assertion as it runs contrary to national trends. Measures in the current authority monitoring reports across the Black Country relate purely to the maintenance of the area of existing designated sites or priority habitats. This is not a measure of biodiversity, does not provide a proxy measurement for biodiversity and does not illustrate the state of nature conservation across the Black Country. The Wildlife Trust can provide advice on developing new monitoring measures that more accurately reflect the duties of the LA under the Natural Environment and Rural Communities Act (2006).Without a dedicated planning ecologist in the Black Country we would also like to re-iterate the value of ecological expertise in delivering this policy

We feel that there could be a greater recognition that nature and natural features are an important constituent of place making and local distinctiveness and often have a strong relationship with historic character. This is a fundamental tenet of geodiversity conservation where the shape of the landscape (e.g. hills and valleys) are determined by geology. The use of local stone for buildings, walls and kerbstones is significant for determining historic character e.g. limestone in Dudley and Walsall, dolerite in Rowley, red sandstone in Stourbridge and Wolverhampton, Gornal Grit and Bilston Stone - yellow sandstones in central Black Country.

All Black Country canals have nature conservation designations. We welcome recognition that all canals are important. However, if particular strategic goals are identified, these should not be ignored due to technical challenges, unless demonstrated to be unfeasible or undesirable. We also note that the international importance of the Cannock Extension Canal SAC has not been referenced here, or elsewhere in the report. We further recommend that the core strategy actively promotes habitat improvement delivery along the canal network in line with the NIA ecological strategy. Canal cuttings also provide important geological exposures.

We strongly agree with the principal of prioritising natural SUDs as this provides greater opportunity for SUDs to provide multiple functions and provide biodiversity features.

We support this policy but suggest additional clarification and strengthening as discussed in our responses to Questions 102b and c. We further recommend that the core strategy actively promotes habitat improvement delivery as part of the normal management of open spaces, in line with the NIA ecological strategy.

Whilst the policy is strong in its rhetoric, it states that development that reduces open space will be resisted and that increases will be encouraged. These are unquantified statements that are unlikely to provide a deterrent or incentive to developers. We suggest the use of a quantifiable measure of the importance of particular areas of open space such as that outlines in the LNP Programme of Action.

We suggest further clarification on what constitutes open space as the policy does not specify publically accessible open space. We would welcome a definition that extends all sites that have developed nature conservation interest, are used informally for recreation or provide other ecosystem services.

We would also expect to see targets for access to open space, sport and recreation in terms of proximity to homes. This should also be extended to explicitly include the provision of multifunctional greenspace to allow healthy lifestyle choices as identified in section 6.11 of this report with reference to quantifiable criteria.