Comment

Draft Black Country Plan

Representation ID: 23129

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Representation Summary:

Paragraph 5.19 - 5.23 - Objection to criteria 1 and 11. ENV4 is contrary to the NPPF paragraph 180c which states: “…development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists..." (RPS emphasis)."