Comment
Draft Black Country Plan
Representation ID: 23131
Received: 11/10/2021
Respondent: St Modwen SL&R
Agent: RPS
Representation Summary:
Paragraph 5.29 - 5.33 - The policy does not link to the site allocations and should set out how the criterion would be applied. Disputes the requirement for sites in an MSA to consider future extraction potential. The policy is worded so that there is a presumption for extraction contrary to the NPPF which seeks to safeguard whilst not creating the presumption that the resources defined will be worked. Criteria 4 doesn't take account of permitted development due to the reference to "other forms of development".