Other

ID sylw: 107174

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

“The Policy will cover … Local Wildlife Sites, including potential, and in certain instances rejected ones.”

The subsequent policies need to maintain a distinction between adopted and rejected sites (depending on the reason for rejection) to ensure a distinction is maintained between the two in the hierarchy. Without this, the importance of adopted sites would be diminished if both allocated and unallocated sites were treated as carrying the same weight.

“… Sites not yet subject to formal designation but known to make a positive contribution to biodiversity and/or geodiversity”

Policy needs to be very clear about what making a contribution would look like in the absence of a formal allocation – lack of definition could make it difficult to establish what weight to give this aspect when decisions are made at application stage.

Other

ID sylw: 107178

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

Need to ensure reference is made to the wider role of LNRS in providing a regional and national network of sites and linkages to protect and promote biodiversity.

The reference to the relationship between the LNRS and BNG needs to be explained a little further – while there are benefits in the form of multipliers for the co-location of BNG provision and LNRS, this will not always occur depending on whether BNG can be delivered on-site or what type of off-site BNG is required.

Other

ID sylw: 107179

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

“Under the mandatory system, developments (with some exceptions) are required to deliver 10% BNG. This will be achieved by delivering habitat on-site or, if that is not possible, through buying off-site biodiversity units.”

Developers may have access to their own BNG units and may not have to buy them.

“The purchase of registered offsite biodiversity units using the Local Nature Recovery Strategy as a guide and in line with the below locational hierarchy:
- Within the Local Planning Authority area where the impact occurs
- Within a neighbouring Local Planning Authority area
- Within Warwickshire, Coventry and Solihull
- Elsewhere in England”

The policy might also include reference to the provision of BNG units within the wider West Midlands before extending to the rest of the country.

Other

ID sylw: 107180

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

It will be interesting to see how this policy is worded and delivered. At the moment, there is no detail of what it might cover apart from broad references to BNG, air / water quality, carbon sequestration and climate change. To cover several essentially different environmental issues in one policy could result in something extremely complex. It will also have implications for other policy areas. It is not clear how this policy area will support or direct following DPDs.

Other

ID sylw: 107181

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

Draft Policy Direction 40 for green and blue infrastructure will cover many of the same broad areas with similar goals. Care must be taken to ensure each policy area is distinct and has its own clearly delineated and monitorable aims and objectives that do not duplicate each other.

Other

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.

Yes

ID sylw: 107183

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

This DPD is welcomed. There is no mention of the role trees play in delivering BNG nor of the importance of retaining them on development sites, where layouts should be designed around the retention of existing mature trees.

Yes

ID sylw: 107184

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

The issues covered in DPD 43 are welcomed and supported.

Yes

ID sylw: 107185

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

The issues covered in DPD 43 are welcomed and supported.

Yes

ID sylw: 107186

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

The issues covered in DPD 43 are welcomed and supported.