The Black Country Plan Consultation

Have your say on the future of the Black Country’s precious landscape

 

 

The Black Country Plan Consultation

The Wildlife Trust’s work to influence where and how new homes and places of work are built is critical to our vision of a future Birmingham and the Black Country which has more wildlife, more wild places and more people with a strong connection to the natural world. New developments can be an opportunity to learn from the past and create communities which are better for wildlife and people. In the next 20 years, however, the urban area of the Black Country is due to expand at a rate not seen since the middle of the 20th century, and the scale of planned new developments presents a real threat to wildlife and wild places which must be challenged.

We understand the passion that people feel for their local environment and are fully committed to supporting communities that want to protect their local wildlife and wild places from damage and harm.

The Black Country Plan (referred to as the BCP or the Draft Plan) will provide the framework for all development decisions in the four local authority areas of Dudley, Sandwell, Walsall and Wolverhampton for a 15 year period from 2024 to 2039. Large-scale land-use changes are expected to take place during its lifetime, and therefore the final Plan’s content will have a significant and permanent impact on the quality of the Black Country environment.

The consultation on the Draft Plan gives everyone the opportunity to influence the future of the Black Country. Whether you want the Plan to have stronger environmental policies or want to protect a local area of green space from development, now is the time to make yourself heard.

While understanding the need to provide new homes and places of work, the Wildlife Trusts will strongly oppose any development that will damage or destroy sites that are important to wildlife.

The consultation on the Draft Plan is open until Monday 11th October 2021.  We are currently preparing our response and will share this with our members and supporters once this has been submitted.  If you would like to be notified when our response has been published please sign-up to our e-newsletter.

Background

The Black Country local authorities (referred to in the Plan as the BCA) are required by the government’s National Planning Policy Framework (NPPF) to produce a Development Plan that sets out how the area will grow over at least the next 15 years, and which provides the framework for decisions on all planning applications during this period.

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The NPPF states that ‘the planning system should be genuinely plan-led’ and that policies within Development Plans should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, employment, retail, leisure and other commercial development; infrastructure (including transport and the provision of minerals), community facilities (such as health, education and cultural infrastructure); conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation.

The consultation process

The government requires development plans to be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators, and statutory consultees (NPPF, 2021).

There are a number of stages to the Black Country Plan consultation:

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  • During the summer of 2017 an Issues and Options consultation formed the first phase of the formal review. This sought views on the period that the review should cover; the evidence base to be prepared; cross boundary and strategic issues that will need to be addressed; the key challenges that the Black Country faces; the level of growth that should be provided for; and the opportunities that exist to accommodate this growth.
  • In accordance with Government guidance, the BCA undertook a ‘Call for Sites’ where submissions of sites were requested from anyone who wished these to be considered for development. The Call for Sites opened for two periods between July 2017 and August 2020. The sites that were submitted can be viewed on the Black Country Interactive Site Map.
  • The current consultation on the Draft Plan (known as Regulation 18 after the Town and Country Planning (Local Planning) Regulations 2012 which requires the consultation) runs from 6th August to 5pm on the 11th October 2021. It is at this stage that the BCA have published their draft policies and land allocations, and stakeholders (including the general public) are able to make their views on these known. Regulation 18 states that the BCA must take into account any representation (consultation response) made to them.
  • Following the Regulation 18 consultation the BCA will take into account any representations and prepare the Draft Publication Plan – the version of the plan they intend to submit to the Secretary of State for examination. A consultation on the Draft Publication Plan is expected to be undertaken from August to September 2022 (this is referred to as Regulation 19). This consultation is for the purpose of ensuring the Plan has been prepared in accordance with all legal and procedural requirements, and that it meets the prescribed tests of soundness.

What’s in the Draft Black Country Plan?

The Draft Black Country Plan consultation documents can be viewed on the Black Country Plan website.

The Plan is large and complex and comprises a main document (the Draft Black Country Plan (Regulation 18) consultation document), a draft sustainability appraisal and a draft policies map.

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  1. The Draft Black Country Plan consultation document includes:
  • An introduction and background
  • A vision for the Black Country to 2039
  • A wide-ranging set of policies including those on the overarching spatial strategy, infrastructure, housing, transport, health and wellbeing, and the environment
  • Tables listing the draft allocations for housing, traveller sites, employment land, waste management sites and mineral extraction sites (quarries) in each of the four local authority areas
  • A number of appendices including the Wildlife Trust’s Draft Black Country Local Nature Recovery Opportunity Map and component definitions

 

  1. The Draft Black Country Plan Sustainability Appraisal comprises two documents which seeks to inform and influence the Plan to ‘optimise its sustainability performance’ by considering and appraising its social, economic and environmental ‘performance’.

 

  1. The Black Country Draft Policies Map depicts the location of the allocations described in the main consultation document on a Black Country-wide scale. Larger-scale policies maps are available for each of the individual local authority areas. There is also an interactive version of the map available.

In addition, there are a significant number of other documents available to view including Frequently Asked Questions, summaries of the allocations for each local authority area and a wide range of studies, assessments and reports which comprise the Black Country Plan Evidence Base (see How have sites been selected?).

Which sites have been allocated for development?

Using the government’s standard methodology for calculating future housing and employment needs, the BCA have concluded that over the next 20 years the Black Country will need over 76,000 new homes and 560 hectares of land for places of employment. Policy CSP1 – Development Strategy of the BCP states that ‘at least 47,837 net new homes’ and ‘at least 355ha of employment land’ will be delivered in the Black Country. The shortfall of 28,239 homes and 210 hectares of employment land, it states, is to be met in neighbouring local authority areas, though the policy recognises that ‘this approach may only address a proportion of the housing and employment shortfall’.

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The BCP divides the Black Country into two distinct area types 1) the area currently designated as green belt as set out in the National Planning Policy Framework and 2) non-green belt land, termed the urban area. The Black Country covers an area of 356 km2, of which just under 73 km2 is green belt and just over 283 km2 is urban.

In summary, the following have been allocated for development in each of the two area types:

Dudley

Homes in the urban area Homes in the existing green belt Employment land in the urban area Employment land in the green belt Total area of green belt allocated
12,118 1,117 (53.8 hectares of land) 22 hectares 0 53.8 hectares

 

Sandwell

Homes in the urban area Homes in the existing green belt Employment land in the urban area Employment land in the green belt Total area of green belt allocated
8,719 171 (6 hectares of land) 28 hectares of land 0 6 hectares

 

Walsall

Homes in the urban area Homes in the existing green belt Employment land in the urban area Employment land in the green belt Total area of green belt allocated
7,926 5,418 (300 hectares) 128 hectares 47 hectares 347 hectares

 

Wolverhampton

Homes in the urban area Homes in the existing green belt Employment land in the urban area Employment land in the green belt Total area of green belt allocated
11.083 1,013 (38 hectares) 69 hectares 0 69 hectares

 

 

How can I find information about an individual site?

The easiest way to view the land allocations at a glance is the Interactive Polices Map. The map allows you to scroll around and zoom into a particular location and see which areas of land have been allocated for different uses such as housing, employment, traveller sites and mineral extraction. The interactive map does not, however, provide details such as the number of houses or area of land involved.

Read more

To find more detailed information you will need to view section 13 (from page 357) of the Draft Black Country Plan consultation document. This provides lists of the sites allocated in each local authority area with information such as site address, indicative development capacity (e.g. number of houses), site area in hectares and indicative delivery (development) timescale.

Further information on sites put forward through the Call for Sites process (both those selected and rejected for inclusion in the allocations) can be found in the Black Country Plan Site Assessment Report and appendices (see "How have sites been selected?").

How have sites been selected?

The Black Country Plan Site Assessment Report describes the methodology and process which was applied by the BCA to assess and select sites for allocation for development in both the urban area and green belt (a different methodology and process were followed for each of these area types)

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The Site Assessment process comprised a number of stages:

  • The four areas defined in the plan as ‘Strategic Centres’ (Brierley Hill, Walsall, West Bromwich and Wolverhampton) were not subject to the site assessment process as ‘Instead, broad targets for housing, retail and office floorspace have been provided for each Strategic Centre’.
  • Sites with existing planning permission for 50+ homes were put through without assessment.
  • Sites allocated for development in existing Development Plans (e.g. the Dudley Borough Development Strategy and the Walsall Site Allocation Document) were ‘carried forward into the Draft BCP using a “light touch” review process’. Only if there was new evidence to consider or they were proposed for a different use to that currently allocated were they assessed further. The BCA state this is appropriate because ‘the allocations have been tested at examination in recent years’.

For all other sites a Site Assessment Form was completed where the following information was collated:

  • Sites were initially assessed against a number of ‘gateway constraints’. These are considered, in most cases, to be an absolute constraint on development. Sites which are subject to such constraints were ‘filtered out’ at this stage and not subject to further assessment. The gateway constraints are:

Filter 1:

Urban area Green belt area
  • Site of Special Scientific Interest, Special Area of Conservation, Site of Importance for Nature Conservation*
  • Ancient Woodland / Veteran Trees
  • Local Nature Reserve
  • Flood Risk Zone 3
  • Registered Park & Garden
  • Scheduled Ancient Monument
  • Operational Burial Ground
  • Common Land
  • Health and Safety Executive Zone 1 (for residential)
  • Sites withdrawn by the landowner, unless ‘a significant site where a Site Assessment would clarify the suitability of the site for development
  • Site of Special Scientific Interest, Special Area of Conservation, Site of Importance for Nature Conservation*
  • Ancient Woodland / Veteran Trees
  • Local Nature Reserve
  • Flood Risk Zone 3
  • Registered Park & Garden
  • Scheduled Ancient Monument
  • Operational Burial Ground
  • Common Land

Notably Sites of Local Importance for Nature Conservation (SLINCs) are not a gateway constraint.

Sites without a gateway constraint were further assessed:

  • For sites in the green belt the Green Belt Harm and Landscape Sensitivity Assessment results (see Green Belt Study and Landscape Sensitivity Assessment section) were entered into the form.
  • A more detailed site assessment process in both the urban and green belt area was then undertaken:

Site Assessment Process

Urban area Green belt area
  • Incorporate evidence findings e.g. ecological surveys, accessibility modelling, utilities capacity, flood risk, health and education needs
  • Review housing density assumptions
  • Incorporate Sustainability Appraisal
  • Collate planning evidence e.g. ecological surveys, historic value, flood risk, transport and seek further evidence / advice if required
  • Establish key planning constraints
  • Determine developable area (given constraints) and select appropriate housing density in line with new BCP Policy / accessibility modelling
  • Establish mitigation necessary to outweigh harm caused to planning constraints
  • Contact landowner if not submitted through “call for sites” and establish willingness
  • Feed in Sustainability Appraisal outputs

 

  • A second filtering process was then undertaken for all sites in the urban and green belt area:

Filter 2:

Urban area Green belt area
  • Where the landowner is expressly unwilling to develop (including withdrawn sites)
  • With one or more significant planning constraints which cannot be mitigated
  • Existing residential
  • Operational sites (education, leisure, utilities, places of worship, canal network, transport infrastructure)
  • Open Space not surplus against current
  • standards
  • Sites <0.25 ha with no “call for site” submitted
  • Local authority land with no “call for site” submitted
  • Health and Safety Executive Zone 1 (for residential)
  • Sites withdrawn by the landowner, unless ‘a significant site where a Site Assessment would clarify the suitability of the site for development

 

  • A third filtering process was then undertaken for all sites in the green belt area:

Filter 3:

Green belt area
  • Where the landowner is expressly unwilling to develop (including significant withdrawn sites)
  • Substantially detached from the edge of the urban area and not capable of being attached through another suitable site
  • Where development would cause very high harm to remaining green belt and moderate-high or high harm to landscape sensitivity
  • With one or more significant planning constraints which cannot be mitigated

 

  • A Viability and Delivery Study was then undertaken on all sites in the urban and green belt area, including those that were carried forward from existing Development Plans and with existing planning permission for 50+ homes.

Viability & Delivery Study:

Urban area Green belt area
  • Remove or apply discounts to types of sites shown not to be viable, where necessary
  • Constrain delivery where clusters of sites are not considered deliverable, in total, by 2039
  • Determine phases of large sites / clusters of sites which are not wholly deliverable by 2039 and adjust supply accordingly
  • Those sites determined to not be deliverable by 2039 were then filtered out

 

Once the above process was completed and the Site Assessment Form finalised a conclusion on the suitability of each site for development was reached and added to the bottom of the form. Example conclusions include Not suitable for residential or industrial purposes; Part of the site is considered suitable for release from the green belt; Site suitable for allocation.

  • The spatial strategy was then reviewed and adjusted if necessary to take account of the sites that had been concluded to be suitable for allocation.
  • The final stage of the process was to draft the allocations and proposed green belt boundary changes as below:

Draft allocations and green belt boundary changes:

Urban area Green belt area
  • Draft Plan Housing Allocations of 10 homes or more
  • Draft Plan Employment Allocations of 0.4 ha or more
  • Draft Plan Green Belt Boundary Changes
  • Draft Plan Housing Allocations of 1 home or more
  • Draft Plan Employment Allocations of 0.4 ha or more

 

The Black Country Plan Site Assessment Report appendices list all of the sites considered for inclusion in the Draft Plan. For each local authority area there are tables which show which sites have been selected, rejected and not assessed. The completed Site Assessment Forms are also included in the appendices.

The evidence

The BCA are required to produce an Evidence Base to demonstrate how and on what basis the decisions in the Plan have been made. The Evidence Base has been provided on the Black Country Plan website in 12 sections including Housing, Environment, Green Belt and Site Assessment. In each section a number of documents have been published.

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All the documents in the Evidence Base are important in informing the plan, however, amongst these there are some which are of particular significance to how sites have been allocated for development:

Green Belt Study and Landscape Sensitivity Assessment:

The BCA commissioned two studies to inform the review of the green belt boundaries and to assess which sites within the green belt were most suitable for new development. The results of the studies have been used to complete the Green Belt Harm and Landscape Sensitivity Assessment section of the Site Assessment Forms (described above).

  • Black Country Green Belt Study: The aim of this study was to undertake an assessment of the performance of green belt land against the five green belt purposes as set out in the National Planning Policy Framework (NPPF):
  1. To check the unrestricted sprawl of large built-up areas
  2. To prevent neighbouring towns merging into one another
  3. To assist in safeguarding the countryside from encroachment
  4. To preserve the setting and special character of historic towns
  5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The study divided the green belt into parcels and assessed each of these against their contribution to the purposes of green belt and assigned one of the following values to each:

  • Strong contribution
  • Moderate contribution
  • Weak / no contribution

This assessment was then used to identify the ‘potential harm’ of releasing land from the green belt. A four stage process was followed:

Step 1: Considered contribution ratings in more depth.

Step 2: Assessed potential impact of release on the integrity of the remaining Green Belt, including consideration of the strength of residual Green Belt boundaries.

Step 3: Assessed overall Green Belt harm.

Step 4: Considered harm resulting from alternative Green Belt release ‘scenarios’.

The output of the process was to assign each parcel of land a ‘harm rating’ of Very High, High, Moderate-High, Moderate, Low-Moderate, Low or Very Low. The results of the study are presented as a series of maps and tables.

  • Black Country Landscape Sensitivity Assessment: The aim of this study was to provide an assessment of the extent to which the character and quality of the landscape abutting the West Midlands conurbation within the Black Country and around settlements in South Staffordshire is, in principle, susceptible to change as a result of development. The study highlights likely landscape and visual sensitivities within each assessment area and provides a broad landscape character based assessment.

The assessment divided the green belt into Landscape Areas and assessed each of these against the following criteria, assigning a value of either Low, Moderate or High to each:

  • Scale (the scale of the landscape)
  • Landform (the topographical complexity of the landscape)
  • Landscape pattern and time depth (the complexity of landscape pattern and the extent to which the landscape has ‘time depth’ – a sense of being a historic landscape)
  • Natural character (the presence of natural or semi-natural features that are important to landscape character)
  • Built character (the extent that built character contributes to landscape character)
  • Recreational value (the value of the area for recreation in which experience of the landscape is important)
  • Perceptual aspects (qualities such as rurality, traditional land uses with few modern, human influences, sense of remoteness or tranquillity)
  • Settlement setting (the extent to which the area relates or contributes to the form and pattern of existing adjacent settlement, and the character of the adjacent settlement edge)
  • Visual prominence (visual prominence of the area and the character of skylines); and
  • Inter-visibility (the degree of inter-visibility with surrounding designated landscapes and the role the area plays in contributing to valued views)

The output of the process was to assign an overall landscape sensitivity value to each Landscape Area of High, Moderate – High, Moderate, Low – Moderate or Low. The results of the process are presented as a series of maps and tables.

Historic Landscape Characterisation Study:

The purpose of this study was to carry out a strategic assessment of locally distinctive places, landscapes, buildings and structures of historic quality and character in the Black Country, covering both urban and green belt areas. The assessment reviewed existing evidence to help identify areas of historic environment significance (historic environment area designations).

The outcome of the study is the identification of several specific historic landscape typologies:

  • Archaeological Priority Areas: areas likely to have high archaeological and historic interest.
  • Areas of High Historic Townscape Value: areas where built heritage makes a significant contribution to local character and distinctiveness.
  • Designed Landscapes of High Historic Value: landscape areas that make an important contribution to local historic character but do not meet the criteria for inclusion on the national Register for Parks and Gardens
  • Areas of High Historic Landscape Value: The significance of these areas is likely to be derived from their archaeological and historic interests

The results of the process are presented as a series of descriptions and maps of the areas and features, and have been used in the Site Assessment process (described above).

Evidence the Wildlife Trust have provided to inform the Draft Black Country Plan

The Wildlife Trust for Birmingham and the Black Country and the Local Environmental Records Centre (EcoRecord) have been commissioned by the BCA to provide a number of studies and reports as evidence to inform the Draft Plan and the development allocations made within this:

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1. Draft Local Nature Recovery Opportunity Map:

BCP map

The Wildlife Trust and EcoRecord have produced a Draft Local Nature Recovery Opportunity Map (and a description of the components of this) which has been published as Appendix 18 in the Draft Black Country Plan. You can view the map and the component descriptions here.

This was commissioned by the BCA as there is a requirement in the Environment Bill to produce a Local Habitat Map that identifies the existing distribution of different habitat types and the location of areas already important for biodiversity, overlaid by locations considered suitable for delivering the outcomes and measures identified in a Statement of Biodiversity Priorities.

The Draft Black Country Local Nature Recovery Opportunity Map has been produced through analysis of local and national data sets including designated sites, Priority habitats, species distribution, land use and ecological connectivity. The map comprises a number of components which depict the areas of current high ecological value, ecological connectivity between these areas, and prioritises opportunities for investment in nature’s recovery on a landscape scale.

Although commissioned by the BCA and published in the BCP, the map was not used in the Site Assessment process (described above).

2. An Ecological Evaluation of the Black Coutry Green Belt:

In 2019 the Wildlife Trust and EcoRecord were commissioned by BCA to undertake an Ecological Evaluation of the Black Country Green Belt. This comprehensive study analysed a wide range of datasets and assigned a relative ecological value from 1 (low) to 5 (very high) to individual parcels of land (landscape units). Datasets used in the analysis included land use, habitat features, existing nature conservation designations and position in the landscape.

This work formed the basis for the Draft Local Nature Recovery Opportunity Map in the green belt and it is the Wildlife Trust and EcoRecord’s position that the results of the evaluation are valid and significant.

Although commissioned by the BCA and published as part of the Evidence Base, the results were not used in the Site Assessment process (described above).

3. Ecological assessment of sites put forward through the Call for Sites process:

Local Sites are areas of high nature conservation and geological value which are designated by local authorities following assessment against locally agreed criteria. While Local Sites do not receive statutory protection, they are protected by Policies in Local Plans and the National Planning Policy Framework, and are crucial in maintaining sites of value that are not statutorily protected.   

In Birmingham and the Black Country Local Wildlife and Geological Sites encompass what are termed Sites of Importance for Nature Conservation (SINCs) and Sites of Local Importance for Nature Conservation (SLINCs). This two-tier system aims to ensure that all sites of substantive local nature conservation and geological value are selected by assessing sites in both a sub-regional (i.e. Birmingham and the Black Country) and metropolitan borough or city context (either Birmingham, Dudley, Sandwell, Walsall or Wolverhampton). Local Sites Assessment Reports are completed to determine if a site should be designated as a SINC or SLINC.

In the BCP Site Assessment process SINCs are considered a ‘gateway constraint’ on development, whereas, unfortunately, SLINCs are not.

During the preparation stage of the BCP the Wildlife Trust was commissioned by Sandwell, Walsall and Wolverhampton councils to undertake approximately 50 Local Sites Assessments, whilst Dudley Council undertook these themselves. The Local Site Assessment Reports have been endorsed by the Local Sites Partnership and redacted versions of these are available to view in the Black Country Plan Evidence Base.

The recommendations of the Local Site Assessment Reports have been used in the Site Assessment process (described above). For those sites designated as SINC and SLINC that have not been assessed during the preparation stage of the BCP the existing site designations have been used in the Site Assessment process.

When can I see the Wildlife Trust’s consultation response?

We are currently analysing the plan’s vision, policies and allocations and intend to make available our full consultation response to our members and supporters once this has been submitted. We expect to be able to do this approximately two weeks before the consultation deadline on the 11th October 2021.

If you would like to be notified when our response has been published please sign-up to our e-newsletter.

How to have your say 

There are two ways you can submit your consultation comments to the BCA:

  1. Complete a comments form. You can download a copy of the form from the website and return it by email to blackcountryplan@dudley.gov.uk or by post to Black Country Plan, Planning and Regeneration, Dudley Council, Council House, Priory Road, Dudley, DY1 1HF.

The form has three sections:

  • Section 1: Personal details
  • Section 2: Your representation/comments on the Draft Plan or Sustainability Appraisal
  • Section 3: A declaration which you will need to read and sign

Section 2 of the form states that you can use the form to comment on more than one site and/or policy and asks that you provide details of the site or policy so that this can be identified.

  1. Comment via the online portal. You will need to register to sign-in.

On the portal you can add comments to the various sub-sections of the Draft Plan by clicking on the comment icons. When you click on a comment icon you will be asked to select one of the following options: Support, Object or Comment. When you click next you will be prompted to outline your reasons for supporting, objecting or commenting. If your response is over 100 words an additional box will open and you will be asked to provide a summary of your comments in 100 words or fewer.

The majority of the housing and employment land allocations are presented on the portal in tables, some of which are very long. You cannot comment on individual lines in the tables so you need to add a separate comment to the table for each site that you want to comment on. You should use the BCP Site Reference and name in the comment so that the BCA can link this to the individual allocation.

The larger allocation sites (the ‘Strategic Allocations’) each have a separate policy in the BCP. At the top of each Strategic Allocations policy you can add a comment.

The consultation ends at 17:00 on Monday 11th October 2021 and your comments must be submitted before this time. Late responses will not be accepted under any circumstances.

What comments should I make?

Object to or comment on an individual site:

If you would like to object to or comment on an individual site that has been allocated for development, we recommend that you follow the approach described below:

  • Find the name or reference number of the site on the Interactive Polices Map or the PDF versions of the Draft Black Country Policies Map.
  • Most sites have been allocated for development on the basis of the completed Site Assessment Forms (see How have sites been selected?). It is the information included in the forms which should be referred to first in any objection or comment. You can find the form for an individual site in the respective local authority area Site Assessment Report appendix.
  • Check the Constraints section of the form to see if the BCA have followed their own process for ‘filtering out’ sites as described above and in the BCA’s Black Country Plan Site Assessment Report. The process should filter out sites which have certain designations or features (for example, Sites of Importance for Nature Conservation, Ancient Woodlands, Scheduled Ancient Monuments and those where the landowner is expressly unwilling to develop).
  • For sites where no Site Assessment Form has been completed (i.e. those ‘carried forward’) from previous Development Plans) you will need to find this information on the Interactive Polices Map or elsewhere (see How can the Wildlife Trust help you?).
  • If a site with one or more of these designations or features has been allocated for development your comment or objection should clearly state that this is a material reason why the allocation should be reviewed or removed.
  • If the site is in the green belt you should then look at the Green Belt and Landscape Sensitivity section of the form. The BCA’s process should filter out sites where it has been concluded that development would cause very high harm to remaining green belt and moderate-high or high harm to landscape sensitivity.
  • If a site has been allocated which meets the above harm threshold, then your comment or objection should clearly state that this is a material reason why the allocation should be reviewed or removed.
  • The following sections of the form (Environmental, Economic and Social) consider a wide range of criteria. The criteria are useful prompts and may result in you considering issues you hadn’t previously thought about.
  • The BCA have assessed the site against each criteria and given a RAG rating (i.e. red, amber or green) which is shown in the right-hand column. There is also a Blue category to indicate that there isn’t enough evidence to assign a RAG rating. You should read the comments given against each of the criteria and understand how the RAG rating was assigned.
  • If there are a number of red or amber ratings given which you conclude should have resulted in the revision or removal of the allocation then you should make this point in your comment or objection, making it clear which criteria you are referring to.
  • If you conclude that the RAG rating is inaccurate or underestimates an impact or constraint, or if you are aware of other evidence which would alter the rating, then you should make this point in your comment or objection, making it clear which criteria you are referring to and providing any evidence.
  • Towards the bottom of the form there is a section called Sustainability Appraisal. Here a RAG rating is given against the objectives in the BCP Sustainability Appraisal. These are:
  1. Cultural heritage
  2. Landscape
  3. Biodiversity, flora, fauna and geodiversity
  4. Climate change mitigation
  5. Climate change adaptation
  6. Natural resources
  7. Pollution
  8. Waste
  9. Transport and accessibility
  10. Housing
  11. Equality
  12. Health SA Objective
  13. Economy
  14. Education, skills and training
  • If you conclude that the RAG rating is inaccurate or underestimates an impact of the allocation on the objectives then you should make this point in your comment or objection, making it clear which objective you are referring to and providing any evidence.
  • If there are other points or issues you feel have not been considered in the form, then state this in your comment or objection and provide any evidence.
  • The final section of the form is the Conclusion where a summary is provided and a statement as to whether the site is suitable for development given. If you disagree with the statement, make this point in your comment or objection. 

Object to or comment on the Introduction; Spatial Vision, Strategic Objectives and Strategic Priorities; a Policy:

The BCP Introduction; Spatial Vision, Strategic Objectives and Strategic Priorities; and various policies provide the framework for decisions on all planning applications during the Plan period. It is therefore critical that these elements of the final Plan ensure protection and enhancement of the Black Country’s natural environment.

Once the Wildlife Trust have published our consultation response we will encourage you to support our comments in your response. Some of the comments we will be making include:

  • That all Local Sites (SLINCs as well as SLINCs) should be considered a ‘gateway constraint’ in the Site Assessment process. We will be strongly advocating that no sites with a Local Site designation should be allocated for development.
  • For the evidence provided in the Ecological Evaluation of the Black Country Green Belt to be used in the Site Assessment process, with an ecological value higher than Medium-Low to be a ‘gateway constraint’.
  • For the evidence provided in the Draft Local Nature Recovery Opportunity Map to be used in the Site Assessment process. We will be stating that areas of high value should be considered a ‘gateway constraint’, and that no allocations for development should be made in areas where they will create ‘bottlenecks’ in the ecological network shown on the map.
  • The Plan should strike a balance between the release of new land and increased density of housing, recognising that new developments in the existing urban area with less open space and green infrastructure could have as detrimental impact on wildlife and people as developments on greenfield sites.

How can the Wildlife Trust help you?

The Wildlife Trust are able to provide support to individuals and groups who wish to submit a response to the Draft Black Country Plan consultation.

We will be able to advise you on what to include in your comments and provide information about local species records and sites designated for their nature conservation value. We will also be able to explain the evidence we have produced (see above) as part of the Draft Plan preparation process and tell you how you can use this in your consultation response.

Please contact us by emailing planning@bbcwildlife.org.uk and one of our colleagues will be in touch.