Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 649

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of requirements 2e and 3g for “an improved network of green and environmental infrastructure”. This is a vital part of regeneration.
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We also welcome the additional description in table 5.2 -
Brierley Hill strategic centre
We welcome the following points:
• …imaginatively landscaped and well-connected public spaces
• being a much greener place, with increased tree cover and more biodiversity including wildlife corridors, which is better linked to the Saltwells and Fens Pool Nature Reserves.
• … well designed public open spaces around them
• having a high quality and beautiful built, natural, and historic environment that respects and enhances local character, including important historic buildings and areas, and makes effective use of the canal network as an asset.
Stourbridge town centre
Halesowen town centre
We welcome the references to the river Stour and the canals in the opportunities sections for Stourbridge and Halesowen. It would be good if this could come through more strongly in the vision.
RC2 – Dudley to Brierley Hill to Stourbridge
We welcome the reference to the canals, the river Stour and to Fens Pool nature reserve. Fens Pool is a Special Area of Conservation. The Habitat Regulations Assessment needs to be utilised here in order to ensure plans and policies do not result in adverse effects on integrity.
RC3 – Stourbridge to Lye
We welcome the reference to the river Stour and note the production of the Lye and Stour Valley design code.
RC4 – Dudley to Coseley
We welcome the proposed enhancement of open spaces including Wren’s Nest National Nature Reserve.

Support

Representation ID: 650

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of point 4, particularly the reference to green and blue infrastructure and bringing this into the heart of the urban area:
4. Improved green and blue infrastructure, linked with protected Green Belt will promote health and wellbeing, support biodiversity and will bring the countryside and its landscape into the heart of the urban area.

Comment

Representation ID: 651

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of points 8 and 9, which are about high quality green infrastructure and its contribution towards a nature recovery network. The term ‘green infrastructure’ should be used.
8. An integrated and well-connected multifunctional open space network will be pursued throughout the borough, including through the design and layout of new residential and employment developments. This will deliver opportunities for sport and recreation and will help establish and support a strong natural environment. Properly designed and well-located open spaces will help mitigate flood risk, provide space for wildlife and encourage informal recreation for local people as well as help create a high-quality living environment. This will also be important for the delivery of the Nature Recovery Network strategy (Policy DLP32).
9. The protection and enhancement of the borough’s historic canal network and the area’s natural waterways will be sought to the extent possible through the design and layout of appropriately located housing and employment development and by the integration of
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waterways into those proposals to create attractive waterside development. This will act as a unifying characteristic within the Dudley Borough’s urban structure and landscape.
Reference could be made to NE’s GI Planning and Design Guide.

Comment

Representation ID: 652

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of a strong policy on nature conservation. We particularly welcome the inclusion of point 5 -
5. All appropriate development should positively contribute to the natural environment of Dudley by:
a. extending and improving the condition of nature conservation sites;
b. improving wildlife movement; and / or
c. restoring or creating habitats / geological features that actively contribute to the implementation of Nature Recovery Networks, Biodiversity Action Plans (BAPs) and / or Geodiversity Action Plans (GAPs) at a national, regional, or local level.
d. ensuring that canal and natural watercourse-side developments deliver improved and extended corridors for the movement of wildlife and people.
We welcome the reference to climate change adaptation in the policy justification, the link to the Local Nature Recovery Strategy and the connection made to the Local Authorities “Biodiversity Duty”.
The policy and its justification could be strengthened by recognising the relationship between nature conservation and green infrastructure. We recommend reference to Natural England’s Green Infrastructure Framework.
The urban nature recovery standard in NE’s GI Framework recommends that in urban and urban-fringe areas, GI should be increased by an agreed percentage, and that developers should identify in their GI Plan the development’s contribution to nature recovery.
NE’s GI Framework sets out the following urban greening factor:
• At least 40% average green cover in urban residential neighbourhoods.
• No net loss of green cover in urban neighbourhoods.
• Urban Greening Factors for development of
o 0.4 for residential
o 0.3 for commercial
o 0.5 for residential greenfield.
We would welcome it if this could be written into policy.

Comment

Representation ID: 653

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of a strong policy on the Nature Recovery Network and Biodiversity Net Gain. Connection should also be made to green infrastructure, with reference to NE’s GI Framework. In applying BNG metrics to brown field sites, careful consideration/strategy should be given to ensuring that these sites can often be naturally biodiverse given the time they may have been left fallow. The Brachen in Berlin offers potential inspiration in valuing sites of such character - NATURA URBANA – THE BRACHEN OF BERLIN.

Comment

Representation ID: 654

Received: 22/12/2023

Respondent: Natural England

We welcome the inclusion of this policy, particularly the requirement to retain existing mature trees, the requirement for 20% canopy cover within major developments, street trees, the consideration of climate change and the enhancement of ecological networks and the Nature Recovery Network.
8. Opportunities for increasing tree provision through habitat creation and the enhancement of ecological networks, including connecting areas of ancient woodland, will be maximised, in particular by means of the biodiversity net gain and Nature Recovery Network initiatives (see Policy DLP32).
Reference should be made to the urban tree cover standards in NE’s GI Framework, which state:
• Urban Tree Canopy Cover is increased by agreed %.
• Major residential and commercial development is designed to meet these targets.
• New and existing trees are incorporated into new developments and new streets are tree lined.
Reference should be made to the Standing advice for ancient woodlands produced jointly by Natural England and the Forestry Commission: Ancient woodland, ancient trees and veteran trees: advice for making planning decisions - GOV.UK (www.gov.uk).

Support

Representation ID: 655

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes this policy

Support

Representation ID: 656

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes this policy. We support the connections made to green infrastructure. Specific reference could be made to Saltwells and Wren’s Nest National Nature Reserves.

Support

Representation ID: 657

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes this policy. We welcome the reference to green infrastructure in the justification, and would support a reference being included in the actual policy.

Comment

Representation ID: 658

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of this policy.
We support the recognition of the wide value of open space listed under point 1:
f. mitigating the effects of climate change in accordance with relevant policies, through flood risk betterment, reducing potential urban heat island effects and providing opportunities for additional landscaping and tree planting;
g. preserving and enhancing diversity in the natural and built environment and preventing the fragmentation of habitat networks;
h. strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network;
i. providing outdoor sport and physical activity facilities, including footpath and cycle networks and areas for informal recreation and children’s play;
j. providing opportunities for people to grow their own food on allotments and encouraging urban horticulture; and
k. enhancing people’s mental and physical health and well-being.
Under point 3c on making more efficient use of the urban land, we advise that care should be taken to not lose biodiversity value in a drive for multifunctionality.
We welcome the inclusion of 3c iv on increasing accessible public open space and suitable recreational use of the Green Belt.
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We note that Dudley will move towards up-to-date local open space and recreation standards in terms of quantity, quality and access (3a). Reference should be made to the Accessible Natural Greenspace Standards set out in NE’s GI Framework. These state:
• Everyone has access to good quality greenspace close to home to meet Accessible Greenspace Standards, with a focus on access to greenspace within 15 minutes.
• Local authorities have at least 3 hectares per 1000 population of publicly accessible greenspace.
• Accessible greenspace meets the Green Flag Award criteria and achieve best practice in accessibility for all.
• Developers meet Local Authority requirements for accessible greenspace.
We welcome the inclusion of the reference to greenways in the justification. This could be included in the policy itself.