Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 905
Received: 01/11/2024
Respondent: Corbett Meadow Action Group
CMAG support the hierarchy of protection for sites important for Nature Conservation as is required by paragraph 181 of the National Planning Policy Framework December 2023 ; and also support the designation of Corbett Meadow as a Site of Importance for Nature Conservation..
In CMAG's view the proposed designation of Corbett Meadow as a SINC is fully warranted, legally compliant and sound - please see attached document which sets out CMAG's representations in full.
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 919
Received: 01/11/2024
Respondent: Corbett Meadow Action Group
CMAG support the hierarchy of protection for sites important for nature conservation as is required by para 181 of NPPF; and also support the designation of Corbett Meadow as a Site of Importance for Nature Conservation.
As noted above, the Meadow was upgraded from a SLINC (local interest) to SINC (regional significance) through a proper and fully evidenced process in October 2022 https://cmis.dudley.gov.uk/cmis5/Meetings/tabid/116/ctl/ViewMeetingPublic/mid/543/Meeting/6444/Committee/468/SelectedTab/Documents/Default.aspx and http://planningdocuments.dudley.gov.uk/AnitePublicDocs/00655832.pdf and so its protection as such is provided by the provisions of the adopted Black Country Core Strategy and Dudley Development Strategy.
However, the Draft Local Plan provides the first opportunity for public & other stakeholder comment on the SINC designation; and so CMAG would wish to record here its full & strong support for such designation.
Again it is noted that the full site assessment is included in the Council’s evidence base https://www.dudley.gov.uk/media/joricypg/corbett-hospital-grounds-local-site-assessment-report-form-2022.pdf
Therefore, the proposed designation of Corbett Meadow as a Site of Importance for Nature Conservation is fully warranted, legally compliant and sound.
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 981
Received: 25/11/2024
Respondent: Dennis R Whittaker
Humans are themselves part of Nature. Whether people realise it or not, preserving the natural environment is necessary for the well-being of Mankind and, ultimately, our very survival.
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1012
Received: 25/11/2024
Respondent: Ms Helen Cook
Corbett Meadow is a rare urban green space connected to the Coalbourne Brook Valley, supporting declining habitats and wildlife. To protect its ecology, traditional grazing and haymaking should continue. The meadow should be designated a Site of Importance for Nature Conservation (SINC).
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1024
Received: 27/11/2024
Respondent: Lance Cartwright
Corbett Meadow, a rare urban green space, connects to the Coalbourne Brook Valley and is protected as a Site of Importance for Nature Conservation (SINC). It hosts declining habitats, including pignut grassland, ponds, wetlands, and mature trees, supporting wildlife such as mammals, birds, amphibians, and insects. Protecting and enhancing these habitats is crucial for maintaining biodiversity. Future plans should continue traditional grazing and haymaking to preserve the meadow’s flora.
I fully SUPPORT the designation of Corbett Meadow as a Site of Importance for Nature Conservation. (SINC)
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1119
Received: 29/11/2024
Respondent: Suzanne Webb
CMAG support the hierarchy of protection for sites important for nature conservation as is required by
para 181 of NPPF; and also support the designation of Corbett Meadow as a Site of Importance for
Nature Conservation.
As noted above, the Meadow was upgraded from a SLINC (local interest) to SINC (regional
significance) through a proper and fully evidenced process in October 2022
https://cmis.dudley.gov.uk/cmis5/Meetings/tabid/116/ctl/ViewMeetingPublic/mid/543/Meeting/6444/Co
mmittee/468/SelectedTab/Documents/Default.aspx and http://planningdocuments.dudley.gov.uk/Anite
PublicDocs/00655832.pdf and so its protection as such is provided by the provisions of the adopted
Black Country Core Strategy and Dudley Development Strategy.
However the Draft Local Plan provides the first opportunity for public & other stakeholder comment on
the SINC designation; and so CMAG would wish to record here its full & strong support for such
designation.
Again it is noted that the full site assessment is included in the Council’s evidence base
https://www.dudley.gov.uk/media/joricypg/corbett-hospital-grounds-local-site-assessment-report-form-
2022.pdf
Therefore the proposed designation of Corbett Meadow as a Site of Importance for Nature Conservation is fully warranted, legally compliant and sound.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1121
Received: 29/11/2024
Respondent: Birmingham and Black Country Wildlife Trust
Legally compliant? No
Sound? No
Duty to co-operate? No
Local Site Assessment required with planning, and protections should be extended to Sites of Local Importance to Nature. Nature’s recovery is at the heart of urban regeneration because this is key to good environments and healthy, prosperous, climate resilient communities. In accordance with the National Policy Framework and Guidance, all public authorities have a duty to conserve and enhance biodiversity and must “have regard” to relevant local nature recovery strategies in the process.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1297
Received: 27/11/2024
Respondent: Dudley Group NHS Foundation Trust
Number of people: 2
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The proposed policies for protecting biodiversity and geodiversity, particularly Policy DLP31, are not considered robust or aligned with national policy requirements. The policy provides excessive protection for regionally designated nature sites, potentially conflicting with the need to address emerging housing needs. It is suggested that the policy be modified to better reflect national policy and allow for sensitive development on sites like Land at Corbett's Hospital, while ensuring that stricter policies, if implemented, are fully justified.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1323
Received: 28/11/2024
Respondent: Home Builders Federation
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy DLP31: Nature Conservation is considered unsound by the Home Builders Federation (HBF) due to a lack of justification, effectiveness, and alignment with national policy.
LNRS Preparation: HBF notes that Local Nature Recovery Strategies (LNRS) have not yet been prepared and that the plan should reflect the current status of LNRS preparation as the planning process progresses.
SPDs and National Guidance: The policy seems to give Local Plan status to Supplementary Planning Documents (SPDs) that have yet to be written, which is inappropriate and contrary to national planning guidance. Planning policies should be formed through the Local Plan process, with proper public consultation and independent scrutiny.
Clarity and Effectiveness: The use of notations in the policy is seen as confusing, and the layout of the policy should be revised for clarity and effectiveness.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1378
Received: 27/11/2024
Respondent: Charles Church Homes
Number of people: 2
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The proposed policies for protecting biodiversity and geodiversity, particularly Policy DLP31, are not considered robust or aligned with national policy requirements. The policy provides excessive protection for regionally designated nature sites, potentially conflicting with the need to address emerging housing needs. It is suggested that the policy be modified to better reflect national policy and allow for sensitive development on sites like Land at Corbett's Hospital, while ensuring that stricter policies, if implemented, are fully justified.
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1403
Received: 21/11/2024
Respondent: National Trust
Environment
We are especially supportive of paragraph 11.2 which promotes the protection and improvement of the borough’s biodiversity and geodiversity on the basis that this “will improve the attractiveness of the area for people to live, work, study and visit while at the same time improving the physical and natural sustainability of the conurbation in the face of climate change.” Paragraph 11.4 acknowledges the importance of green infrastructure, which we thoroughly support.
Support
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1404
Received: 21/11/2024
Respondent: National Trust
We maintain our support for the policy approach to DLP31 and consider that the inclusion of the Regional Park within the Green Infrastructure Network can support the achievement of many of the indicators set out within the policy wording and supporting justification.
Comment
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1480
Received: 29/11/2024
Respondent: Canal and River Trust
Reiterate comments from Regulation 18 stage. Outline key points regarding nature conservation, emphasizing the importance of protecting natural sites and species, especially in the context of the Fens Pools Special Areas of Conservation (SAC) and canal networks.
Fens Pools SAC Protection: highlight the significance of the Fens Pools SAC, noting its European importance. Welcome the protection measures under Policy DLP31 and stress the need for careful management to prevent adverse impacts from development. Recommend reviewing options for Suitable Alternative Natural Greenspaces (SANG) near Fens Pools to mitigate potential harm.
The HRA already advises 'Public access and disturbance/ recreational pressure: Increased development has the potential to increase recreational pressure upon Habitats sites which are accessible to the public. Urbanisation: Urban development has the potential to result in disturbing activities (such as noise, lighting and visual disturbance). Disturbance effects may impact upon Habitats sites themselves and also their qualifying features,
Comment
Part One: Spatial Strategy and Policies (Regulation 19)
Representation ID: 1490
Received: 29/11/2024
Respondent: Hagley Homes
Agent: Lichfields
Draft Policy DLP31 (Nature Conservation) sets out that the Council will ensure that Sites of Local Importance for Nature Conservation are protected from development proposals which could negatively impact them. Hagley Homes notes that the site (alongside other adjacent land parcels) has been designated as a Site of Local Importance for Nature Conservation [SLINC] within the PP; this represents an expansion of the boundary of an existing SLINC designation as defined by the Dudley Borough Development Strategy (adopted 2017).
Hagley Homes supports the Councils efforts to safeguard nature conservation, however, considers that the Council should give further consideration to the site’s designation as a SLINC. In this regard, these representations provide an overview of the Councils evidence base which underpins the SLINC designation and set out the conclusions of the Preliminary Ecological Technical Note (“the appraisal”) prepared by FPCR.