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".