Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1110

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Missed opportunities to specify the type of resilience, equitable access to nature, etc. Resilient natural environment and the benefits for people and climate resilience. In several places in the document “resilient” is mentioned, without a specification of the resilience to which this refers. Equitable access to green spaces and nature will help Dudley Council toward its ambitions of both the Dudley Health and Wellbeing Strategy 2023-2028 and the Dudley Climate Action Plan, as well as the Local Nature Recovery Strategy. Establishing a Nature Recovery Network will help to address biodiversity loss, climate change, and wellbeing.

Object

Representation ID: 1111

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

We suggest clarification in the nuance of climate and ecological change to meet the test of soundness, as ecological change can be positive (e.g., where poor quality habitat improves). It is also an opportunity to reiterate a focus on climate change resilience in the strategic priorities toward the aims of the Dudley Climate Action Plan.

Object

Representation ID: 1113

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Nature’s recovery at the heart of urban regeneration because this is key to good environments and healthy, prosperous, climate resilient communities. Having a strong level of green infrastructure network connected to wildlife corridors, in line with the Local Nature Recovery Strategy, will contribute to meeting the duties and aims of the Revised NPPF (December 2023), the Environment Act 2021, and the adopted Black Country Core Strategy (2011) Policy CSP3 ‘Environmental Infrastructure’, Dudley Climate Change Action Plan, the Dudley Health and Wellbeing Strategy 2023-2028, 2023 Natural England Green Infrastructure Framework, and Nature Recovery Network for the Government’s 25 Year Environment Plan.

Object

Representation ID: 1114

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Missed opportunities to specify the type of resilience, equitable access to nature, etc. Resilient natural environment and the benefits for people and climate resilience. Climate crisis mentioned, but then it’s not in the vision. In several places in the document “resilient” is mentioned, without a specification of the resilience to which this refers. Equitable access to green spaces and nature will help Dudley Council toward its ambitions of both the Dudley Health and Wellbeing Strategy 2023-2028, Dudley Climate Action Plan, and Local Nature Recovery Strategy. Establishing a Nature Recovery Network will help to address biodiversity loss, climate change, and wellbeing.

Object

Representation ID: 1115

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

In accordance with the NPPF 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. Protecting and enhancing the natural environment through sustainable development, integrating green and blue infrastructure, protecting and enhancing nature, in line with the Local Nature Recovery Strategy Priorities, will aid Dudley Council in achieving the aims of the Dudley Climate Change Action Plan, the Dudley Health and Wellbeing Strategy 2023-2028, the 2023 Natural England Green Infrastructure Framework, and Nature Recovery Network for the Government’s 25 Year Environment Plan (2018).

Object

Representation ID: 1116

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Nature’s recovery at the heart of urban regeneration because this is key to good environments and healthy, prosperous, climate resilient communities. Access to green spaces and nature will help Dudley Council toward its ambitions for both the Dudley Health and Wellbeing Strategy 2023-2028 and the Dudley Climate Action Plan. It is important that this access be equitable for all. This will contribute to achieving the Dudley Borough Economic Regeneration Strategy 2024 as well.

Object

Representation ID: 1117

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

We would object to any development over SINCs, SLINCs, PSIs, priority habitats, or sites with priority species. 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. Protecting and enhancing the natural environment through sustainable development, integrating green and blue infrastructure, and integrating the priorities and measures of the Local Nature Recovery Strategy will contribute to Dudley Council's legal compliance (see longer comment for specific legislation and policies), and to meet the council's aims and objectives.

Object

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.

Comment

Representation ID: 1122

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

'Local' in this context needs to be defined. As well, the incentive for urban developments to deliver on-site net gain needs to be clarified as 11.32 states that on-site biodiversity improvements will be vital to enhancing the liveability of urban areas. BNG should be delivered on-site with no incentives for BNG delivery off-site, to support the delivery of Local Nature Recovery Strategy priorities, objectives, and measures. Nature’s recovery is at the heart of urban regeneration because this is key to good environments and healthy, prosperous, climate resilient communities.

Object

Representation ID: 1123

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

Biodiversity Net Gain is now mandatory, and all public authorities have a duty to conserve and enhance biodiversity and must “have regard” to relevant local nature recovery strategies in the process (NPPF December 2023). This priorities should be clearly reflected in the Dudley Council Local Plan, and it should be clearly stated that developments which will negatively impact greenspaces and nature's recovery will be rejected except under extraordinary circumstances, with such instances requiring a local site assessment. See further implications in the full comment given.