Draft Regulation 18 Sandwell Local Plan

I support SNE2 item relating to integrated nesting bricks, but at the moment it is not clear - more detail is required to ensure that the bird boxes installed are long-lasting, low maintenance, and relevant to the local area and target species, and an appropriate number and location.

As a minimum please amend to: "All major development proposals with an eaves height or roof commencement height of 5m and above are required to provide integrated swift bricks / boxes or house martin cups, and integrated bat boxes as appropriate, to help preserve endangered species and urban biodiversity in Sandwell, with numbers and locations in accordance with best-practice guidance such as BS 42021".

Ideally add this paragraph as further explanation: "Swift bricks are considered a universal nest box for small bird species, and are significantly more beneficial than external bird boxes for reasons of longevity, maintenance, aesthetic integration, and improved thermal regulation. Therefore, the type of bird boxes specified should be swift bricks unless it can be demonstrated that this is not practically feasible (in which case, external swift boxes may instead be specified). House martin cups may alternatively be specified where an ecologist recommends them.

In more detail, the reason for this is because swift bricks are the only type of bird box specifically mentioned as valuable to wildlife in national planning guidance (NPPG Natural Environment 2019 paragraph 023). Swift bricks are considered a universal nest brick suitable for a wide range of small bird species including swifts, house sparrows and starlings (e.g. see NHBC Foundation: Biodiversity in New Housing Developments (April 2021) Section 8.1 Nest sites for birds, page 42:
https://www.nhbcfoundation.org/wp-content/uploads/2021/05/S067-NF89-Biodiversity-in-new-housing-developments_FINAL.pdf ).
Swift bricks are significantly more beneficial than external bird boxes as they are a permanent feature of the building, zero maintenance, are aesthetically integrated with the design of the building, and have improved thermal regulation with future climate change in mind. Therefore, swift bricks should be included in all developments following best-practice guidance (which is available in BS 42021:2022 and from CIEEM).

Many other Local Authorities are including detailed swift brick requirements, such as Wiltshire Local Plan Regulation 19 stage which requires an enhanced number of 2 swift bricks per dwelling (policy 88: Biodiversity in the built environment, page 246: "As a minimum, the following are required within new proposals: 1. integrate integral bird nest bricks (e.g., swift bricks) at a minimum of two per dwelling;"
https://www.wiltshire.gov.uk/article/8048/Current-consultation-Reg-19 )

Also, please add that existing nest sites for building-dependent species such as swifts and house martins should be protected, as these endangered red-listed species which are present but declining in Sandwell return annually to traditional nest sites. Mitigation should be provided if these nest sites cannot be protected.