Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1471

Received: 29/11/2024

Respondent: Canal and River Trust

COMMENTS ON INTRODUCTION, PROFILE OF THE BOROUGH, CONTEXT OF THE LOCAL PLAN, VISION

Introduction: no further additions to Reg 18 observations.

Profile of the borough: Welcome addition of paragraph 2.5 - request inclusion of 'active travel' and 'well-being' within its values.

Context of the Local Plan: no further additions to Reg 18 observations.

Vision, Objectives and Priorities: reiterate previous Regulation 18 comments. In relation to ‘Delivery, Monitoring, and Implementation’ maintain Regulation 18 request for ‘opportunity to engage with the Council on an on-going basis throughout the plan period to secure the benefits to the canal network envisaged by the Plan’s suite of policies.’

Comment

Representation ID: 1472

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate suggested approach at Regulation 18 stage, of focussing on main canal specific policy DLP36 rather than repeated mention of the canal/river network within other plan policies. Suitable cross-referencing within justification text however would remain beneficial. Wish to engage with the Council in forthcoming local design codes.

Comment

Representation ID: 1473

Received: 29/11/2024

Respondent: Canal and River Trust

No further additions to make to Regulation 18 observations. Repeat request for mention of the canal network as a delivery option within justification text for Policy DLP7 Broadband and Telecommunications.

Comment

Representation ID: 1474

Received: 29/11/2024

Respondent: Canal and River Trust

Repeat Regulation 18 request for the incorporation of cross referencing to Canal Policy DLP36 within the justifying text to this section and/or Policy DLP8 Health and Wellbeing.

Comment

Representation ID: 1475

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterates previous Regulation 18 comments.

Content that canal-specific implications arising from the draft Housing need and supply policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy DLP36. The inclusion of the canal network within relevant allocation maps helpfully enables developers to identify canal related constraints at an early stage and engage with us. Requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice directly.

The Trust can provide information of priority areas for upgrading on a case-by-case through responses to planning application consultations, and will seek to request Section 106/CIL monies and/or planning conditions if appropriate. The Trust has some specific critical assets within the Dudley area especially within Brierley Hill and along the Dudley No 1 Canal, as well as over Trust tunnels, which will require careful assessment of allocations for impact and mitigation under Policy DLP36 – Canals.

Comment

Representation ID: 1476

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterates previous Regulation 18 comments.

Content that canal-specific implications arising from the draft Employment policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy DLP36 - Canals. This includes the assessment of implications arising for existing boating businesses which adjoin development sites, or opportunities arising for the creation of compatible business boating activity. The inclusion of the canal network within relevant allocation maps helpfully enables developers to identify canal-related constraints at an early stage and engage with us accordingly. Request on-going engagement from the Council on submitted pre application enquiries, and also encourages developers to seek pre application advice directly.

Comment

Representation ID: 1479

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterates previous Regulation 18 comments.

Content that canal-specific implications arising from the Council’s Centres and Town Centres policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy DLP36 Canals. The inclusion of the canal network within relevant allocation maps helpfully enables developers to identify canal related constraints at an early stage and engage with us accordingly. Requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice directly.

Comment

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

Representation ID: 1481

Received: 29/11/2024

Respondent: Canal and River Trust

Advocates for canals to be recognized as part of the local Biodiversity Action Plan (BAP), playing a crucial role in species recovery strategies. Urge continued engagement in BNG policy development, aiming for canals to be considered as offsetting sites for biodiversity loss.

Comment

Representation ID: 1482

Received: 29/11/2024

Respondent: Canal and River Trust

Stress the need for policies to protect trees, woodlands, and hedgerows, specifically asking for cross-referencing to Canal Policy DLP36 to ensure proper policy application for canals. Suggest separating tree retention from habitat creation aspects to aid planning assessments.