Comment

Representation ID: 21616

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy DEL1: ‘Infrastructure Provision’
Draft Policy DEL1 at Limb (2) states that: ‘development proposals will only be permitted if all necessary infrastructure improvements, mitigation measures and sustainable design requirements and proposals are provided and/or can be phased to support the requirements of the proposed development.’
Limb 3 (a) of draft Policy DEL1 states that the Black Country Authorities (BCAs) will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, the infrastructure that is to be provided or supported.
Therefore, as currently drafted, this policy encapsulates both known infrastructure requirements (that should be reflected in the viability study undertaken by Aspinall Verdi underpinning the draft BCP to date), but also, future/emerging requirements that at this stage are unknown but could be brought forward in the future.
Therefore, it is appropriate Limb 4 of draft Policy DEL1 acknowledges that there will be circumstances where site specific viability concerns mean that some of these infrastructure requirements cannot be delivered. However, draft Policy DEL1 limits this to ‘exceptional’
circumstances. We therefore propose that the word ‘exceptional’ is removed from draft Policy DEL1
in order to provide sufficient flexibility to reduce the level of infrastructure requested at the planning application stage (either as the infrastructure requirement was
not envisaged (or known) at the time that the BCP viability evidence was prepared, or that there are site specific issues which impact on viability, and hence the ability to deliver the identified infrastructure).
This will also ensure that other proposals for other forms of residential development across the Black Country (such as 100% affordable housing schemes which have not been tested by the viability study undertaken by Aspinall Verdi) can come forward, by ensuring that the infrastructure requirements on such schemes can be ‘flexed’ appropriately.