Comment

Representation ID: 13453

Received: 11/10/2021

Respondent: Bloor Homes

Agent: Cerda Planning Ltd

Due to the size restriction for accepting emails this representation has been split in to 6 documents sent in 5 emails as follows:

Email Documents
1 1 and 2 of 6 (Forms, Main Representation and Vision Document)
2 3 of 6 (Development Options Document 2021)
3 4 of 6 (LVIA)
4 5 of 6 (LVIA Addendum 2021)
5 6 of 6 (Landscape Sensitivity Review)

These representations are made by Cerda Planning on behalf of Bloor Homes Midlands in relation to a site at Stencils Farm.

1. Executive Summary
1.1. The Black Country Plan fails to deliver anywhere close to its identified housing need,
with a reliance on neighbouring authorities to deliver homes that are needed now within
the Black Country. The reliance on such an approach without a firm commitment from
all of the neighbouring authorities is not considered to be a sound approach to plan
making. Especially when sites such as Stencils Farm are available within the plan area
without any significant constraints to development.
1.2. There are clear errors in the evidence which underpins the plan, in particular within the
individual Site Assessments which themselves justify the proposed housing allocations.
These errors and inconsistency in the application of evidence in the assessments is a
significant and fundamental flaw of the plan.
1.3. The Stencils Farm site is not subject to any ‘Gateway Constraints’ that would prevent its
development. The harms attributed to the site within the evidence are misleadingly
overstated and there are no substantive reasons for the site not to be allocated for
development. The allocation of Stencils Farm site would enable the Black Country
Authorities to reduce its housing delivery deficit and move closer to meeting its critical
need for new homes without any demonstrable negative impacts.