Comment

Draft Black Country Plan

Representation ID: 23172

Received: 11/10/2021

Respondent: Environment Agency

Representation Summary:

Point 9c) States that a FRA will be required for minerals or waste development. As this is not a requirement of the NPPF we query the reason for including this, and the evidence base to support its inclusion. The Environment Agency would not look to
review such information under our role as a statutory consultee and as such would likely fall to the LLFA to undertake such review. Such sites would be regulated under the Environmental Permitting Regulations with a mind to preventing pollution. Surface drainage is addressed within these permits. Any such FRA would need to take this into account and ensure any consideration of drainage issues are complementary and no duplication of the planning and permitting regime occurs.