Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 715

Received: 22/12/2023

Respondent: Canal and River Trust

DLP41

Cross-reference to Policy DLP36 given the roles our network can play in the delivery of this policy requirement.

Retrofitting is only briefly mentioned and it will play a large role in the borough. Accordingly, we request that this paragraph is augmented to reflect this reality and to require that development proposals ensure that the chosen approach considers any consequential visual impacts on the canals' setting, heritage significance, or amenity value. (ACTION REQUEST).

Comment

Representation ID: 716

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests mention of the canals as a potential component of heat risk management within Policy DLP43 Managing Heat Risk, and associated justification text. (ACTION REQUEST)

Support

Representation ID: 717

Received: 22/12/2023

Respondent: Canal and River Trust

In relation to Air Quality the Trust welcomes the inclusion of ‘Emissions from Construction Sites’ within the wording of para 12.42 as this aligns to our regular requests for Construction and Environmental Management Plans within our statutory consultation responses to planning applications.

Comment

Representation ID: 718

Received: 22/12/2023

Respondent: Canal and River Trust

Given the increasing susceptibility of the historic canal network to climate change stress the Trust requests the inclusion of the canal network within the justification text to Flood Risk Policy DLP45. As such we also request that Canal and River Trust are listed within the bodies to be consulted on site-specific requirements within sub- section 15 of Policy DLP45 Flood Risk. For this purpose citizens and developers can access our open source mapping data to identify our assets here:

https://data-canalrivertrust.opendata.arcgis.com/ (ACTION REQUEST).

Comment

Representation ID: 719

Received: 22/12/2023

Respondent: Canal and River Trust

Absence of separate justifying text.

We advise that subject to the Trust’s owner agreement to technical and commercial details, surface water can potentially be sustainably discharged to the canal network. Surface water discharge to canals can be a highly effective way of managing local surface water flood risk and may allow development of sites that would otherwise not be viable due to concerns with alternative site drainage options. Should be designed and maintained to ensure they do not pollute or inundate the canal with water.

We request canals be specified as an option for surface water drainage and are listed within Policy DLP46.

Comment

Representation ID: 750

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests inclusion of our network within Policy DLP47 Renewable and Low Carbon Energy and BREEAM Standards, and justification text para 12.56 in relation to the potential for use of our network for water-source heat pumps (ACTION REQUEST)

Comment

Representation ID: 752

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests the inclusion of a list of potential receptors for water quality impacts, and inclusion of our network within it. Alternatively, incorporation of cross-referencing to Canal Policy DLP36.

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.

Comment

Representation ID: 754

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests that section 1 of Policy DLP54 River Stour and its Tributaries, should read ‘Canal and River Trust’. Furthermore, we advise that whilst the River Stour is not one of the Trust’s assets we remain willing to engage in partnership working to identify and mitigate consequential flood risk issues arising from it to our network. (ACTION REQUEST)

Comment

Representation ID: 755

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust welcomes mention of the canal network within section 6h of Policy DLP55 Historic Character and Local Distinctiveness of Dudley, and cross-reference to canals policy DLP36. We also welcome the applicability of this policy to designated and non-designated assets alike. The depth and breadth of this Policy wording is also noted and the Trust queries whether separating the policy out and addressing Archaeology matters within a separate policy would assist in providing clarity. (ACTION REQUEST)

Request cross reference to DLP36 in justification.