Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1124

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

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’. 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. See full implications in the full comment given.

Object

Representation ID: 1125

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

DLP Policies Map should include Local Nature Recovery Strategy.
for ease of reference by planning officers.

Comment

Representation ID: 1126

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

We strongly suggest explicit inclusion of Landscape and Ecological Management Plans, nor Construction Environment Management Plans (CEMPs, LEMPs).

Object

Representation ID: 1427

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

1. Introduction
What is a Local Plan review and why are we doing a review?


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. Guidance on complying with the biodiversity duty includes who public authorities are and what they should do. Here, we would strongly suggest ensuring a recognition of the value of brownfield sites for nature recovery. We suggest that the DLP have a mechanism of assessment put in place to check individual sites regarding their nature conservation value, and employing a local site assessment, as appropriate.

Object

Representation ID: 1428

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

1. Introduction
What is a Local Plan review and why are we doing a review?


In order to be compliant with the Revised National Planning Policy Framework (NPPF 2023) and its associated Planning Practice Guidance (PPGs), all plans should include and address “conservation and enhancement of the natural and built environment”. Similarly, the Environment Act 2021 includes a biodiversity duty in that “Public authorities who operate in England must consider what they can do to conserve and enhance biodiversity in England.” Thus, this section should include not only protection, but also enhancing the natural environment toward legal compliance to protect and enhance nature, biodiversity, and contribute to nature’s recovery.

Object

Representation ID: 1429

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

1. Introduction
What is a Local Plan review and why are we doing a review?


Green and blue infrastructure, climate change resilience, and equitable access to greenspaces should be key focuses of the overall development in the urban area, in line with the LNRS, the Revised NPPF (December 2023) (e.g., paragraph 35, “Sustainability soundness test for Local Plan Reviews”), and the adopted Black Country Core Strategy (2011) Policy CSP3 ‘Environmental Infrastructure’. 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, 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 the West Midlands Local Transport Plan (LTP) aims.

Object

Representation ID: 1430

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

2. Profile of the borough
Environment


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. Guidance on complying with the biodiversity duty includes who public authorities are and what they should do. Here, we would strongly suggest including Local Wildlife Sites. These are integral components of Areas of Particular Importance for Biodiversity as identified in the Local Nature Recovery Strategy, as well accessible green space.

Object

Representation ID: 1431

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Table 3.2 Homes and Communities – Issues and Challenges:
Location of development and distribution of growth

Comment: All public authorities have a duty to conserve and enhance biodiversity and must “have regard” to relevant local nature recovery strategies in the process. Guidance on complying with the biodiversity duty includes who public authorities are and what they should do. Here, it is necessary to ensure there’s a recognition of the value of brownfield sites for nature recovery. We suggest that the DLP have a mechanism of assessment put in place to check individual sites regarding their nature conservation value, namely through a local site assessment, as appropriate.

Object

Representation ID: 1432

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Table 3.4 The Natural and Built Environment – Issues

OBJECT – SOUNDNESS

Comment: Evidence list includes both “Black Country Local Nature Recovery Strategy 2022” and “Black Country Local Nature Network Recovery Strategy 2022”. Are these each referring to the “Black Country Local Nature Recovery map and strategy: an emerging approach”? Please amend these evidence references.