Sandwell Local Plan Main Modifications Consultation

Comment

Representation ID: 1730

Received: 27/03/2026

Respondent: Mrs Sara Lovell

We would suggest that for the sake of longevity and robustness of the policy, the wording should simply state '...protect the openness, integrity and function of Sandwell’s designated green belt by resisting inappropriate development in line with national guidance'.

Comment

Representation ID: 1731

Received: 27/03/2026

Respondent: Mrs Sara Lovell

We believe that any new development proposals should demonstrate how they've been designed to maximise climate change resilience opportunities. The policy should be unambiguous about that and therefore not include terminology such as wherever possible. Though it will take varying forms depending on the nature and circumstance of individual developments, the policy requirement should be there and suitable proposals made. We therefore suggest the following changes: : '... Proposals for development will need to demonstrate how they have been designed to maximise resistance and resilience to climate change through addressing the following requirements in accordance with other policy obligations: …

Comment

Representation ID: 1732

Received: 27/03/2026

Respondent: Mrs Sara Lovell

The insertion of 'where practicable' is in our view an unnecessary and undesirable weakening of the policy and the requirement for utilising sustainable drainage solutions unambiguously reinstated. We therefore suggest the removal of the wording 'where practicable' as practical solutions which are appropriate to each case can and should be sought in all circumstances.

Comment

Representation ID: 1733

Received: 27/03/2026

Respondent: Mrs Sara Lovell

It is critical to recognise the multiple benefits and opportunities that greenbelt provides, especially in heavily urbanised areas such as Sandwell so nature recovery and the maintenance of (rare) agricultural landscapes should be explicitly stated.as per the following suggestion: '...Sandwell Council will maintain a green belt boundary around Sandwell, to limit urban sprawl, protect natural and agricultural landscapes, and provide recreational and environmental benefits such as to mitigate climate change impacts, nature recovery and easy access to the countryside for residents.'

Comment

Representation ID: 1734

Received: 27/03/2026

Respondent: Mrs Sara Lovell

comment relating to 3.2.b - We are concerned by the use of terminology such as 'providing facilities' This could be interpreted in a number of ways that imply the policy is encouraging built infrastructure. This feels unnecessary and may give rise to potential conflicts to arise in the context of this policy more broadly. We suggest alternative wording such as '...b. by encouraging active and passive recreation (if this preserves the openness of the Green Belt and does not conflict with the purposes of including land within it2);' could be a suitable alternative.

Comment

Representation ID: 1735

Received: 27/03/2026

Respondent: Mrs Sara Lovell

We suggest a more explicit reference to and alignment with the mitigation hierarchy principles and terminology: '…a local nature conservation site (Sites of Local Importance for Nature Conservation), protected or priority species, habitat, or geological feature damage must be avoided, minimised and/or mitigated/compensated in line with the UK mitigation hierarchy principles and framework.'

Object

Representation ID: 1736

Received: 27/03/2026

Respondent: Mrs Sara Lovell

Legally compliant? Yes

Sound? No

We are concerned that the policy clarification unnecessarily focuses and emphasises the possibility of de-notifying sites. However it is also possible that ecological value increases and therefore new designations may be appropriate, necessary and relevant. Therefore we suggest the proposed wording isn't appropriate or sound and an alternative, more balanced, clearer alternative considered as follows: '… and will amend existing designations in accordance with this evidence. Consequently, sites may receive amended levels of protection over the Plan period.'

Comment

Representation ID: 1737

Received: 27/03/2026

Respondent: Mrs Sara Lovell

Though we welcome the intention to expand BNG ambitions through this policy, we are concerned that the proposed wording may inadvertently encourage loss of biodiversity in the borough due to the lack of readily available habitat banks. Therefore we suggest the addition of wording to reflect the preference for biodiversity gains that benefit the local area such as: '...Proposals that offer more than 10% BNG on development sites will be welcomed and the additional ecological value, where it benefits Sandwell, will be considered positively when a decision is made on the relevant planning application.'

Comment

Representation ID: 1738

Received: 27/03/2026

Respondent: Mrs Sara Lovell

The amendment states: NB – Ray Hall pastoral land and Hill Farm Bridge Fields will be treated as a single site.
We don't think the mapping presented make this clear/appears consistent with that statement?

Comment

Representation ID: 1739

Received: 27/03/2026

Respondent: Mrs Sara Lovell

Ecological value of trees must be considered in addition to amenity value, both in terms of the value of existing but also that of replacement specimens (specimen groups). The policy should encourage maximisation of Biodiversity enhancements in all circumstances as this is a good mechanism for supporting nature's recovery and in urban areas and contribute to the delivery of the local nature recovery strategy.