Comment

Representation ID: 21242

Received: 11/10/2021

Respondent: Newlands Developments

Infrastructure and Delivery (Section 4)
Strategic Policies should make sufficient provision for infrastructure, as confirmed in parts b) and c) of NPPF Paragraph 20, which states:

“Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for infrastructure for:
b) transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
c) community facilities (such as health, education and cultural infrastructure)”

Draft Policy DEL1 (Infrastructure Provision) of the Draft Black Country Plan emphasises that all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impacts on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area. We are therefore generally supportive of this policy, owing to its conformity with national planning policy.

It is however noted that Part 3 of Draft Policy DEL1 advises that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents and, where appropriate, masterplans:

a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure provision.

Whilst generally supportive of this approach, it is considered that the Site can be suitably delivered without significant upgrades to the supporting infrastructure. We would therefore be grateful to be included as part of any future consultation on the Infrastructure Delivery Plan. Indeed, we would expect the Infrastructure Delivery Plan to support the emerging Black Country Plan through Examination.