Draft Regulation 18 Sandwell Local Plan

The RSPB welcomes the inclusion of a Swift-specific measure within Sandwell Local Plan (Policy SNE2, Item 13) of the Local Plan and suggests some refinements to ensure maximum benefit for wildlife and to follow established precedent from other Local Plans.

• The policy should extend to 'All' development proposals rather than being limited to 'Major' development proposals. This follows established precedent, for example Brighton and Hove City Plan which states:

"Swift boxes should be provided in all new developments (residential and commercial) across the city of 5m or greater in height to the eaves."

Installing Swift bricks is cheap and straightforward, so should not be limited according to the type and scale of developments. Detail on how to apply this policy according to different developments based on best practice guidance could be incorporated within a Supplementary Planning Document. This has also been done by Brighton and Hove City Council.

• It is recommended that the policy refers to 'universal integral nesting bricks' instead of 'integrated nesting bricks / boxes.' Universal integral Swift bricks are designed for Swifts but will also provide nesting opportunities for other Red-Listed Birds of Conservation Concern including House Martins, House Sparrows and Starlings. The term 'boxes' often refers to externally mounted nest boxes, which can work well as a retrofit option, however integral bricks are preferable to external swift boxes in new developments as they are integrated into the building, cannot be removed, provide better temperature control and require less maintenance.

• Whilst we also welcome the inclusion of Bats within this Policy, we suggest that provision for Bats is a separate item within the Policy as they have specific requirements which differ from the provision for birds. There is some good guidance available from the Bat Conservation Trust on how to provide bat roost opportunities which could inform this item.

The RSPB also suggest that a Supplementary Planning Document is produced to complement this Policy, which will provide detailed guidance on how to incorporate nesting opportunities for Swifts and other Red-Listed bird species within development proposals. We would very much welcome the opportunity to work with Sandwell Metropolitan Borough Council on this, as it presents a brilliant opportunity to improve the fortunes of Swifts and other birds in Sandwell, which are in urgent need of help.