SNE1.5 The policy should be amended to require enhancements to wildlife corridors, for example by improving their connectivity, rather than merely prohibiting development from impeding them. This may be limited to sites lying in proximity to wildlife corridors and other such sites.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

N.B As part of this submission and including objections of soundness for SH35 and SH36, please find enclosed a petition of those named supporting these comments which should be used as a barometer of public opposition to residential development in this location. Please also refer to attached FOS evidence PDF which cites relevant material in numbered parentheses.

WE make the following comments in regard to each numbered paragraph of this policy. Some points we consider sound and support, others need to be reworded to be sound and some deleted to be sound.

1 Not needed as no direct connection to these areas. The Fens pool site is poorly managed and its continued status should be investigated by Natural England given the angling activities and destruction which take place there.
2 SUPPORT AS SOUND BUT REWORD
“Development will not be permitted where it would alone or in combination with other plans or projects, have an adverse impact or harm on the integrity of nationally (Sites of Special Scientific Interest and National Nature reserves) or regionally (Local Nature Reserves and Sites of Importance for Nature Conservation) designated nature conservation sites.
N.B SMBC failed to consider existing Nature conservation policy with planning application DC_15_58580 in the officer's report stating that planning policy stated it was not a SINC! (29). An FOI request to SMBC stated that Sheepwash had already been designated some 15 years previous in 1999 as a SINC and provided a map if the whole site of designation. (30)

Therefore

INSERT LINE “PLANNING POLICY WILL KEEP UP TO DATE RECORDS OF ALL DESIGNATED SITES NATIONALLY, REGIONALLY AND WITHIN SANDWELL. “

3 SUPPORT AS SOUND.

4 UNSOUND. This paragraph contradicts the previous one making protection meaningless. Not justified as how and who decides on what is a “strategic benefit”? Reducing areas of designation in line with policy SNE2 10% net gain increase makes this policy a joke and contradiction. Not effective as new designations for protection may evolve over the next 17 years of the plan and may be too late for some species/habitats if not protected from development. REMOVE PARAGRAPH.

5 SUPPORT AS SOUND

6 SUPPORT AS SOUND

7 CONCERN ON THE WORDING OF THIS PARAGRAPH. We support evidence being updated to protect existing designated sites but are concerned about the word “amend” if this means taking away designations. We do not support ANY area having its status rescinded as this implies collusion with developers to delete designated sites they consider having “strategic benefits”. We would welcome increased protections. To make justified and sound reword
"Over the plan period, Sandwell will update evidence on designated nature conservation sites and Local Nature Reserves as necessary in conjunction with the Local Sites Partnership and Natural England and will amend existing designations in accordance with this evidence. INSERT “NO SITE ALREADY DESIGNATED WILL BE LOST OR DELETED”. Consequently, sites may receive new, or increased, protection over the Plan period."
Paragraph 4.2 page 83 still refers to “the black country” and not Sandwell, and this should be amended to comment on the nature conservation in our borough, including designating more local nature reserves and extending existing ones to improve the poor record mentioned in further paragraphs.

Policy SNE1 - Nature Conservation
Suggested change: For soundness for points 3 and 4, it should be clarified that “Development will be refused where it will negatively impact or contribute to the decline of protected species, habitats or geological features. Any impacts must follow the principles of mitigation hierarchy.” Additionally, “Development that will negatively impact any areas of principal biodiversity importance (in line with the Local Nature Recovery Strategy) will be rejected. Where there is evidence that a site or area could be of significant potential importance, relevant assessments must be conducted prior to a landuse change/land allocation decision.

Point 5: “The movement of wildlife within Sandwell and into / out of adjoining areas, through both linear habitats (e.g., wildlife corridors) and the wider urban matrix (e.g., stepping-stone sites) must not be impeded by development. Developers must take account of the Local Nature Recovery Strategy (Policy SNE2) when preparing their schemes and must plan for the maintenance and where possible enhancement of such linkages.”

Point 6: "Adequate information must be submitted with applications for proposals that may affect any designated site or important habitat, species, or geological feature, to ensure that the likely impacts of the proposal can be fully assessed. Where the necessary information is not made available, there will be a presumption against granting planning permission. Proposals that affect designated site or important habitat will be rejected except under extraordinary circumstances."

Justification:
4.3 “Development in Sandwell must contribute positively to the protection, enhancement and expansion of the natural environment across the wider Black Country by…”

Reiterating from our previous response submitted in December 2023 as our suggested changes have not been included yet.

In order to be legally compliant with existing relevant policies (e.g. UK Environment Act 2021, the Biodiversity Net Gain law 2024, the National Planning Policy Framework, the Sandwell Local Plan goals for green and blue infrastructure, and the 2023 Natural England Green Infrastructure Framework on the delivery and enhancement of green infrastructure) and in order to meet the required criteria for soundness, several suggestions are made below for this section of the local plan.

5. All public authorities have a duty to conserve and enhance biodiversity and must “have regard” to relevant local nature recovery strategies in the process.

6. It should be made clear here that proposals that affect designated site or important habitat will be rejected.

We are pleased that the Plan includes the natural environment in its long-term vision and objectives for the plan area. These are based on local characteristics and circumstances and include locally specific goals for nature recovery and enhancement, supported by policies and proposals in the plan.

We consider that as an overall strategy to guide development and allocate land the Plan should:
• Conserve and enhance the natural environment, including landscapes and green infrastructure (GI)
• make as much use as possible of previously developed or ‘brownfield’ land
• allocate land with the least environmental or amenity value.

Natural England strongly supports a number of your plans’ priorities, strategic objectives and policies including:

Objective 1: Ensure new development takes a proactive approach to climate change mitigation, adaptation and carbon reduction, and that development is resilient to climate change.

Objective 2: Deliver sustainable development in locations where people can access jobs and services, delivering wider positive social and economic outcomes and protecting and enhancing local built and natural environments.
Objective 3: To protect and enhance Sandwell’s natural environment, natural resources, biodiversity, wildlife corridors, geological resources, countryside and landscapes, whilst ensuring that residents have equitable access to interlinked green infrastructure.

Objective 10: To provide a built and natural environment that supports the making of healthier choices through provision for physical activity and recreation, active travel, encouraging social interaction and discouraging harmful behaviours.
Objective 11: To ensure new development and open spaces support health and wellbeing for all, reduce health inequalities and encourage active and healthy lifestyles.

Objective 12: To provide a built and natural environment that protects health and wellbeing through minimising pollution (air, noise and other forms), providing healthy homes, reducing the negative health effects of climate change and providing streets safe for active, low emission travel for all.
Objective 14: To encourage the effective and prudent use of previously developed land, including the efficient use of land and buildings and the use of sustainable and climate-aware construction techniques within new developments, as well as providing for waste management and disposal.

Objective 16: To prioritise sustainable and active travel and seek to improve transport infrastructure, to ensure efficient and sustainable accessibility within an integrated network.
Objective 18: To ensure development is supported by essential infrastructure and services and promotes safe movement and more sustainable modes of travel, through promoting greener travel networks for walking, cycling and public transport.

Spatial Strategy
We note that your authority has identified a need for 26,350 homes by 2041 and has a suitable supply of land for 10,434 with 15,916 homes unmet. We note your Duty to Co-Operate discussions have yielded an additional contribution to the Greater Birmingham and Black Country Housing Market of 4,240 of which none are currently apportioned to Sandwell. This leaves a significant remaining shortfall. There is the potential for this development to come forward in other authorities which may have knock effects on important environmental assets in those areas. As we previously

mentioned in relation to your HRA this could have impacts on sites such as Cannock Chase. A similar issue exists in relation to employment use.
Natural England is pleased to note that the Plan aims to address:
• nature conservation
• nature recovery network and biodiversity net gain
• provision, retention and protection of trees, woodlands and hedgerows
• historic character and local distinctiveness of the Black Country
• geodiversity and the Black Country UNESCO Global Geopark
• canals
• green belt
Natural England supports the desire to prevent the loss of open and green spaces across the
district. We understand that will mean development elsewhere contributing to Sandwell’s needs but believe in the importance of access to green infrastructure and open space.
Natural England largely supports the Balanced Green Growth approach (2.29 and 2.30) Policy SDS1 – Spatial Strategy for Sandwell
Natural England supports the parts of this policy which requires new development to address access to green space including,

• increased access to green spaces;
• active and passive recreation;
• active travel; opportunities for people to make healthier choices.
• minimise and mitigate the likely effects of climate change, recognising the multifunctional benefits that open spaces, landscaping, trees, nature conservation habitats and both green and blue infrastructure can deliver in doing so;
• create new public open spaces to serve new housing developments
• protect and improve parks, woodland and tree planting, open spaces, landscapes and habitats across the borough;
• protect the openness, integrity and function of Sandwell's designated green belt by resisting inappropriate development in it;
• protect habitats and areas of ecological value;, and
• protect areas with geological and landscape value; Policy SDS2 – Increasing efficiency and resilience
Natural England supports this policy which should contribute to climate change mitigation and adaptation

Policy SDS3 – Regeneration in Sandwell

Natural England supports the desire to provide new green links squares and parks as part of the West Bromwich regeneration and the use of Garden City principles for the regeneration of Dudley Port.

Policy SDS4 – Towns and Local Areas
Natural England strongly supports the desire for an integrated and where possible, an integrated continuous network of green infrastructure and walking and cycling routes.
Policy SDS5 - Achieving Well-designed Places – Natural England supports this policy, especially with regard to the integrated and well-connected multifunctional open space network will be pursued throughout Sandwell (linking to opportunities in the wider Black Country where possible), including through the design and layout of new developments. You may wish to consider the linkages beyond the wider Black Country and consider Birmingham, Staffordshire and the wider countryside

additionally.

Policy SDS8 - Green and Blue Infrastructure in Sandwell

Natural England strongly supports the desire to incorporate multi-functional green and blue and blue infrastructure. We are pleased to see that your authority has incorporated Natural England’s guidance on the delivery of green infrastructure.

Policy SNE1 Nature Conservation

4.1 The protection and improvement of Sandwell's biodiversity and geodiversity will safeguard and improve the environmental attractiveness and value of the borough for residents and visitors. At the same time, this approach will also enhance the physical and natural sustainability of communities within the conurbation in the face of climate change. Doing so will directly contribute to delivering Strategic Objective 11, which is also associated with supporting the physical and mental wellbeing of residents.

Policy SNE1 – Nature Conservation

Natural England supports all aspects of this policy. We are pleased to see the recognition of Sandwell as an important place within Britain and the Birmingham and Black Country conurbation for species movements.

We are pleased to see reference to Local Nature Recovery Strategies (LNRS). Natural England is already working with your authority on an LNRS for the West Midlands and look forward to continuing to do so. We are also pleased to see the amount of work you have undertaken with regard to Biodiversity Net Gain including potential sites for habitat creation.

Policy SNE3 – Provision, Retention and Protection of Trees, Woodlands and Hedgerows

Natural England is pleased to see this policy incorporated into your plan. We welcome the element of habitat creation and the recognition that trees can have to climate change mitigation and air quality issues.

Policy SNE4 – Geodiversity and the Black Country UNESCO Global Geopark

Natural England is pleased to that your authority has recognised the importance of geodiversity and the Black Country’s important role in it

Policy SHW3 Air Quality

Natural England supports elements of this policy, especially with regard to the integration of walking, cycling and public transport provision and the provision and protection of green and open space and additional tree cover.

Policy SHW4 – Open Space and Recreation

Natural England strongly supports this policy.