Comment
Draft Black Country Plan
Representation ID: 21296
Received: 11/10/2021
Respondent: Owl Homes
Agent: Barton Willmore
Draft Policy TRAN 8 – Planning for Low Emission Vehicles
Draft Policy TRAN8 sets out how proposals for low emission vehicles will be supported. Whilst we are supportive of the principle of encouraging low emission vehicle use and providing infrastructure to facilitate this, it is considered that the current policy wording is too vague, particularly in relation to the provision of charging infrastructure. Paragraph 16d) of the NPPF states that Plans should contain policies that are unambiguous. Part a) of the Policy states that “adequate” provision for charging infrastructure should be provided as part of new developments, however it is not clear what is meant by this, as there is no indication / guidance as to what may be considered adequate. Without knowing what infrastructure may be required to be provided as part of new developments in relation to charging infrastructure, the viability implications cannot be fully understood. The Council should ensure that all of the anticipated development costs associated with all of the draft policies of the BCP have been taken into account, as required by National Policy (NPPF paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). It is therefore considered that in order to ensure that the policy is realistic and deliverable, it should be amended to be more explicit in terms of what infrastructure will be expected to be delivered.