Comment

Representation ID: 433

Received: 19/01/2024

Respondent: Dudley Labour Group

How will the Council ensure the planning framework helps protect and provide green spaces for community use in the new neighbourhoods?

Support

Representation ID: 665

Received: 22/12/2023

Respondent: Natural England

Natural England very much welcomes the inclusion of a policy on Green Infrastructure. The Green Network may form a part of the GI network but it could be wider than described in the policy. We recommend a wider GI policy, supported by the production of a Green Infrastructure Strategy and delivery plan which should form part of the Local Plan evidence base. We would also recommend that all major developments are informed by a GI Plan, design codes and best practice in its implementation alongside developers. London is a case study of good practice - urban_greening_and_bng_design_guide_march_2021.pdf (london.gov.uk).
We recommend that the council utilises Natural England’s Green Infrastructure Framework: Green Infrastructure Home (naturalengland.org.uk).
The GI Framework sets out standards for:
• Green infrastructure
• Accessible greenspace
• Urban nature recovery
• Urban greening factor
• Urban tree cover.
The council could use the GI Mapping Tool produced by NE and available online. Natural England would welcome further discussions with Dudley Council on this matter.

Comment

Representation ID: 753

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust welcomes inclusion of the canals within section 1i of Policy DLP51 and its introductory and justification text para 13.10. We also request partner engagement with the Council in any forthcoming preparation, adoption and implementation of Green Infrastructure strategies.

there are opportunities for developers and other agencies to contribute towards further GI improvements through a variety of mechanisms, such as developer contributions through the planning process, corporate partnerships https://canalrivertrust.org.uk/donate/partner-with-us/corporate-partnerships or adopting a section of canal https://canalrivertrust.org.uk/donate/partner-with-us/volunteering-in-partnership

GI Improvements could also be made through the provision of recreation facilities for use by the public - a number of examples provided in submission.

Support

Representation ID: 785

Received: 21/12/2023

Respondent: National Trust

Policy DLP51 Dudley Borough’s Green Infrastructure Network
8 Hills Regional Park will be a vehicle to connect up the green infrastructure network throughout Dudley, Bromsgrove and Birmingham across to the Solihull border. We consider that the proposed Regional Park will accomplish the objectives set out in Policy DLP51 and the 8 Hills Regional Park could significantly strengthen this cross boundary network, whilst achieving all of the benefits and advantages for health and well being, access to public open space and climate change resilience.
We agree that the green infrastructure network should have a multi-functional role as:
a. a wildlife corridor, to provide coherent ecological networks.
b. accommodating pedestrian and cycle paths, particularly in linking the urban area with the Green Belt and open countryside as well as linking towns and places of employment with residential communities.
c. providing opportunities for informal recreation.
d. helping to form a break between locally distinct areas and centres.
e. grazing land for horses and other livestock.
f. a means of maintaining the integrity of water courses across the borough as well as enhancing the natural value and restoration of water courses including de-culverting where opportunities arise.
This multi-functional role is also reflected in the aims and objectives of the delivery of the Regional Park, and the draft Spatial Framework which we have prepared illustrates how we would seek to achieve this. This document will be shared with Dudley Borough Council Officers in the new year.
Whilst we are supportive of the principles of policy DLP51 and thoroughly support the measures to maintain and enhance the green infrastructure network, we would recommend that the 8 Hills Regional Park is referenced in this policy and designated on the Policies Map as land to the south of the A456 and land to the east of Wollescote. We consider that this would both strengthen Dudley’s green infrastructure network and present an opportunity to enter into a partnership with a governance structure for 8 Hills Regional Park and engage in a cross-boundary relationship when it comes to truly integrated green infrastructure for the benefit of people and nature across the West Midlands conurbation and beyond. The designation would align with the proposed designations on the policies map with designations of ancient woodland, areas of high historic landscape value and archaeological priority areas.
With Dudley’s open spaces and existing green infrastructure under such considerable pressure in delivering housing need for the borough and potentially beyond in future, the designation of the 8 Hills Regional Park in this area of Green Belt could potentially be used to ensure that green infrastructure and open space is prioritised when considering new development and could set a high standard for connectivity and mitigation of Green Belt loss, should this be the approach that the Council would be minded to take.

Comment

Representation ID: 811

Received: 30/01/2024

Respondent: Historic England

DLP51. We consider it would be appropriate to include a clause on heritage as a component of green/blue infrastructure and the role it plays including issues such as heritage landscapes and features.

Support

Representation ID: 839

Received: 19/12/2023

Respondent: Sport England

Support part 3c of the policy.

Comment

Representation ID: 873

Received: 09/04/2024

Respondent: Severn Trent

Agent: Severn Trent

Blue Green Infrastructure We are supportive of the principles of blue green infrastructure and plans that aim to improve biodiversity across our area. Looking after water means looking after nature and the environment too. As a water company we have launched a Great Big Nature Boost Campaign which aims to revive 12,000 acres of land, plant 1.3 million trees and restore 2,000km of rivers across our region by 2027. We also have ambitious plans to revive peat bogs and moorland, to plant wildflower meadows working with the RSPB, National Trust, Moors for the Future Partnership, the Rivers Trust, National Forest and regional Wildlife Trusts and conservation groups.
We want to encourage new development to continue this theme, enhancing biodiversity and ecology links through new development so there is appropriate space for water. To enable planning policy to support the principles of blue green Infrastructure, biodiversity and protecting local green open spaces we recommend the inclusion of the following policies:

Blue and Green Infrastructure Policy
Development should where possible create and enhance blue green corridors to protect watercourses and their associated habitats from harm.

Supporting Text:
The incorporation of Sustainable Drainage Systems (SuDS) into blue green corridors can help to improve biodiversity, assisting with the wider benefits of utilising SuDS. National Planning Policy Framework (2021) paragraph 174 States:
“Planning policies and Decisions should contribute to and enhance the natural and local environment by:
a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their Statutory Status or identified quality in the development plan);
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate;
d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.”

Green Open Spaces Policy
Development of flood resilience schemes within local green spaces will be supported provided the schemes do not adversely impact the primary function of the green space.

Supporting Text:
We understand the need for protecting Green Spaces, however open spaces can provide suitable locations for schemes such as flood alleviation schemes to be delivered without adversely impacting on the primary function of the open space. If the correct scheme is chosen, the flood alleviation schemes can result in additional benefits to the local green space through biodiversity and amenity benefits.