Comment

Representation ID: 22567

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

The justification of the policy also appears to be short given the policy itself is so detailed. Paragraph 10.83 states “To ensure that heritage assets make a positive contribution towards the wider economic, social and environmental regeneration of the Black Country, it is important that they are not considered in isolation but are conserved and enhanced within their wider context. A holistic approach to the built and natural environment maximises opportunities to improve the overall image and quality of life in the Black Country by ensuring that historic context informs planning decisions and provides opportunities to link with other environmental infrastructure initiatives.” . We agree that a holistic approach is needed, but it needs to be clearer what this approach includes, as well as actually being explicit in the policy wording itself. This does not mention the need to look at physical site constraints, viability, the public benefits a development could bring or even a reference to developments being of high quality.