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ID sylw: 107182

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

DPDs 39, Draft Policy Direction 40 and Draft Policy Direction 41 - Carbon Sinks and Sequestration all reference the same issue – it needs to be made clear what the relationship between the policies is in terms of how they use / measure carbon sequestration. Assuming DPD 39 represents a strategic policy approach to how and where sequestration would occur, the other two policy directions would need to translate that strategy into requirements on site and ensure any targets for the sub-area were reflected in site-specific outcomes. This seems unnecessarily repetitive in theory. Subsequent policies will need to be very clear which aspects of the issue they cover and ensure there is no overlap between them.

As the justification states, the role of planning in carbon sequestration is limited and the process itself is effectively addressed through those policies that seek to protect open spaces and ecologically important sites. On that basis it is not clear why a separate policy on sequestration is required when existing policies could be drafted to include reference to the role of open spaces, the LNRS etc. in delivering it.