Draft Regulation 18 Sandwell Local Plan

Comment

Representation ID: 657

Received: 07/12/2023

Respondent: Mr Alexander Lane

- Ambition 1: consider changing 'equality' to 'equity'
- Ambition 7: Opportunities for biodiversity need to be integrated into these new developments and will be key in creating the 'attractive neighbourhoods' this ambition aspires to.
- Ambition 8: Design and inclusion of greenspaces will, again, be key in making the Borough a place where people choose to bring up their families. Having access to good natural space is, in itself, a form of leisure and entertainment.
- Ambition 10: This ambition doesn't really say anything meaningful, and could be removed from this list.

Comment

Representation ID: 658

Received: 07/12/2023

Respondent: Mr Alexander Lane

- Objective 3: Could be revised to '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 6: Should include wording on ensuring new development should aim to maximise biodiversity benefit and ensure they tie into wider ecological networks.
- Objective 7: Clarity is sought on what 'resilience' means in this context? Presumably resilient to climate change?

Comment

Representation ID: 659

Received: 07/12/2023

Respondent: Mr Alexander Lane

Ensuring that new development helps to contribute positively to the Local Nature Recovery Network should be mentioned in this Policy.

Comment

Representation ID: 660

Received: 07/12/2023

Respondent: Mr Alexander Lane

Well-designed spaces should help to contribute to the wider Local Nature Recovery Network, as well as providing maximum biodiversity benefit.

Comment

Representation ID: 661

Received: 07/12/2023

Respondent: Mr Alexander Lane

- This policy should make mention of the Local Nature Recovery network, as green and blue infrastructure are integral parts of this.

Comment

Representation ID: 662

Received: 07/12/2023

Respondent: Mr Alexander Lane

- Section 3c: This would be an opportunity to mention the Local Nature Recovery Network, and how realising this will aid in movement of species across Sandwell and the wider Black Country
- Section 3d: This reads like developments will be expected to deliver priority habitats exclusively. This point requires some more nuance.

Comment

Representation ID: 663

Received: 07/12/2023

Respondent: Mr Alexander Lane

Section 14: This part of the policy seems quite weakly worded. All development should aim to deliver ecological enhancement in some form. Whilst a minimum BNG requirement goes some way to delivering ecological enhancement, valuable enhancement features (such as bird/ bat boxes, insect hotels, etc) are not accounted for in BNG measurements. There should be support in planning policy to ensure that these features are still being provided in new developments.

Comment

Representation ID: 664

Received: 07/12/2023

Respondent: Mr Alexander Lane

Section 4.21: Suggest revising the third paragraph for clarity. Sealed surfaces don't provide any BNG units, true, but this paragraph reads like a site with sealed surfaces is exempt from BNG requirement (which isn't the case).
Sections 4.27 & 4.28: Sensitive lighting plans can't be included with optional enhancement measures (like insect hotels, hedgehog gates). They are often a mitigation measure to ensure important linear habitats for bats are retained post- development. This could should be taken out of this list.

Comment

Representation ID: 665

Received: 07/12/2023

Respondent: Mr Alexander Lane

We would encourage Sandwell MBC to consider requiring more than the minimum 10% biodiversity net gain in new developments.

Comment

Representation ID: 666

Received: 07/12/2023

Respondent: Mr Alexander Lane

Section 10: Which trees are classified as 'large-canopied' for the purposes of this policy? A list should be provided either here or in the Tree Strategy document.