Sandwell Local Plan - Reg 19 Publication

4. Habitat Creation.
- Comment: Even with the clarification included, trees and woodland habitats should be encouraged for developers to implement.

10. Canopy Cover
- Suggested change: From the point of view of soundness and clarity, we suggest focusing on the species in practical guidance documents and here focusing on increasing canopy cover expectation or ambition.

Climate Change and Biodiversity
- Comment: Perhaps Construction Environmental and Landscape and Ecological Management Plans could be mentioned here, to provide the PA with reassurances that a) trees are being properly protected during development b) appropriate tree species are being properly planted in optimal conditions on site.

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.

Biodiversity Net Gain
Comment: Biodiversity Net Gain maps should be compiled by applying the appropriate standard (e.g. through use of UKHab for Phase 1).

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) and in order to meet the required criteria for soundness, several suggestions are made below for this section of the local plan. Biodiversity Net Gain maps should be compiled by applying the appropriate standard (e.g. through use of UKHab for Phase 1).

Sandwell Site Allocations and Allocation Changes
Comment: Each allocation needs to be checked for being Potential Sites of Importance (PSI) and evidence reviewed on each case and the need for a local sites assessment to be considered prior to the allocation. Evidence on a number of Potential Sites of Importance (PSIs) suggested local site assessments should be carried out in order to establish whether these meet the local sites criteria threshold. Examples (though not an exhaustive list) are listed below.

Comment: We would object to any housing allocation on a site that has a current local site designation. For example, SH18 and SH43 below. We would also object to the allocation of any PSIs where evidence suggests these could be sites of value locally on the basis that these would require local site assessment prior to an allocation being proposed. For example we would object to SH35 and SH36 on this basis. We are aware that the area to the East of the lagoon supports a sizeable area of kidney vetch and is likely to support a colony of the rare Small Blue butterfly. We understand that other notable species such as Bee Orchids are present on the eastern side of that site (by Macdonald Close) and that this is an area of grassland, open mosaic and scrub which has developed on former colliery/brickworks land which connects to the wider Sheepwash area. The areas have also been identified as core areas in the nature recovery network analysis therefore the need for a local sites assessment in such circumstances is clear.


Please see further notes and objections to specific allocations here:

SH18 - Friar Park, Wednesbury. The site is a Site of Local Importance for Nature Conservation (SLINC) and part of the core nature recovery network/LNRS areas of principal biodiversity importance. We therefore object to it being allocated for housing/development.

SH19 - Land at Horseley Heath, Tipton. Due to its adjacency, we have concerns about the impact of this allocation on Dixons Branch Canal

SH21 - Dudley Road East. As above, but for Gower Branch Canal


SH30 - Land to East of Black Lane, West Bromwich. As above, but for Ridgeacre Branch Canal

These are areas that could be potential sites of importance so evidence should be reviewed and a local sites assessment could be necessary.

SH35 - Rattlechain site - land to north of Temple Way, Tividale.

SH36 - Land between Addington Way and River Tame, Temple Way. Adjacent to Brades Hall SLINC.

Both SH35 and 36 are PSIs We are aware that the area to the East of the lagoon supports a sizeable area of kidney vetch and is likely to support a colony of the rare Small Blue butterfly. We understand that other notable species such as Bee Orchids are present on the eastern side of that site (by Macdonald Close) and that this is an area of grassland, open mosaic and scrub which has developed on former colliery/brickworks land which connects to the wider Sheepwash area. The areas have also been identified as core areas in the nature recovery network analysis therefore the need for a local sites assessment in such circumstances is clear and the allocation reviewed accordingly, as necessary.


SH43 - Land off Tanhouse Avenue, Great Barr. The site is a Site of Local Importance for Nature Conservation (SLINC) adjacent to a SINC (Site of Importance for Nature Conservation) and part of the core nature recovery network/LNRS areas of principal biodiversity importance. We therefore object to it being allocated for housing/development.

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, and the National Planning Policy Framework and guidance) and in order to meet the required criteria for soundness, several suggestions are made below for this section of the local plan.

We would object to any housing allocation on a site that has a current local site designation. See further details in changes suggested below.

12. All applicants, must seek to include additional enhancement opportunities for wildlife and conservation in their proposals in line with the scale and type of development in compliance with relevant legislation and seeking to make a proportionate, significant contribution to nature’s recovery.

Local opportunities for habitats and wildlife.
In order to align with the UK Environment Act 2021 and implement the Biodiversity Net Gain (BNG) law 2024, the requirements for BNG must be made clear here for most developments. Relating to the National Policy Framework and Guidance, all public authorities also have a duty to conserve and enhance biodiversity.