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: 441
Received: 07/09/2017
Respondent: Local Nature Partnership
The Core Strategy includes robust environmental policies. We support a partial review and provide advice to make policy ENV1 more robust and 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) and Local Nature Partnership (LNP). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157. The Town and Country Planning Regulations (Local Planning) 2012 as amended requires co-operation with Local Nature Partnerships for planning sustainable development in cross-boundary strategies.
The Core Strategy includes robust environmental policies. We support a partial review and provide advice to make policy ENV1 more robust and 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) and Local Nature Partnership (LNP). Support for NIA is required in National Planning Policy Framework (NPPF) paragraphs 117 and 157. The Town and Country Planning Regulations (Local Planning) 2012 as amended requires co-operation with Local Nature Partnerships for planning sustainable development in cross-boundary strategies.
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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: 442
Received: 07/09/2017
Respondent: Local Nature Partnership
We welcome Ecological Network and Strategic Mapping to provide robust, up-to-date and comprehensive evidence. These should build on the NIA ecological network mapping and Natural England's Green Infrastructure and Pinch Point Mapping. The LNP 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 Ecological Network and Strategic Mapping to provide robust, up-to-date and comprehensive evidence. These should build on the NIA ecological network mapping and Natural England's Green Infrastructure and Pinch Point Mapping. The LNP 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: 443
Received: 07/09/2017
Respondent: Local Nature Partnership
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.
In line with guidelines in the NPPF, Planning practice guidance 2016 and Town&Country Planning Regulations 2012, the LNP can advise on conducting such a study. For Garden City aspirations to materialise, brownfield sites should be enhanced for nature conservation and quality of life values.
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.
In line with guidelines in the NPPF, Planning practice guidance 2016 and Town&Country Planning Regulations 2012, the LNP can advise on conducting such a study. For Garden City aspirations to materialise, brownfield sites should be enhanced for nature conservation and quality of life values.
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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: 444
Received: 07/09/2017
Respondent: Local Nature Partnership
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 within policies on allocating land for this. The LNP can provide guidance for this commitment building on existing mapping by the NIA and Natural England.
We welcome the recognition in Paragraph 3.38 that designated sites may be affected by developments beyond their boundaries and proposes greater scrutiny and mitigation for developments within this zone of influence. We hope that this principal will be adopted for all nature conservation sites within the Black Country.
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 within policies on allocating land for this. The LNP can provide guidance for this commitment building on existing mapping by the NIA and Natural England.
We welcome the recognition in Paragraph 3.38 that designated sites may be affected by developments beyond their boundaries and proposes greater scrutiny and mitigation for developments within this zone of influence. We hope that this principal will be adopted for all nature conservation sites within the Black Country.
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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: 445
Received: 07/09/2017
Respondent: Local Nature Partnership
We strongly disagree with the principle that brownfield sites will always be prioritised for development and it is our opinion that all sites must 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 brownfield sites do not have high environmental value. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some areas of greenbelt.
We strongly disagree with the principle that brownfield sites will always be prioritised for development and it is our opinion that all sites must 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 brownfield sites do not have high environmental value. There is a growing body of evidence that urban greenspace and brownfield sites can be of equal or greater importance for wildlife and people as some areas of greenbelt.
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: 446
Received: 07/09/2017
Respondent: Local Nature Partnership
As one of the three stated purposes of the strategy is to direct environmental activity, the LNP would expect to see a spatial objective for green infrastructure and a greater recognition of Natural Capital and the benefits integrating environmental infrastructure for other priorities including health and wellbeing and more desirable developments.
Environmental Infrastructure is one of the five strategic policies subsequently set out, but this would be greatly strengthened if it were supported 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".
As one of the three stated purposes of the strategy is to direct environmental activity, the LNP would expect to see a spatial objective for green infrastructure and a greater recognition of Natural Capital and the benefits integrating environmental infrastructure for other priorities including health and wellbeing and more desirable developments.
Environmental Infrastructure is one of the five strategic policies subsequently set out, but this would be greatly strengthened if it were supported 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".
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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: 447
Received: 07/09/2017
Respondent: Local Nature Partnership
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.
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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: 448
Received: 07/09/2017
Respondent: Local Nature Partnership
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.
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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: 449
Received: 07/09/2017
Respondent: Local Nature Partnership
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: 450
Received: 07/09/2017
Respondent: Local Nature Partnership
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.