Object

Representation ID: 43857

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

5.0 INFRASTRUCTURE AND DELIVERY
Delivery Constraints
5.1 The supporting text to the chapter on Infrastructure and Delivery highlights that the Plan adopts a 'brownfield first' approach to development. It also identifies that this approach is significantly constrained as a consequence of the Black Country's mining and industrial past and that intervention is likely to be necessary if these constraints are to be overcome. This clearly highlights the difficulty with developing brownfield land in the Black Country and in particular the inappropriateness of highlighting this as the top priority, rather than promoting a broader approach to delivering development. It also undermines a key part of the Plan which is to maintain a steady supply of housing land, as to do this will require a broader approach to the allocation of land than prioritising previously land, which the Plan already recognises is highly constrained.
5.2 Paragraph 4.7 refers to mineral resources and the benefit this may accrue if it is viable to extract them as part of a remediation scheme. The promotion of mineral extraction raises a number of issues which go beyond merely assisting in the remediation of despoiled/degraded industrial land. In itself mineral extraction can have significant adverse impacts on the amenity of neighbouring properties. As set out elsewhere in this Representation, it is important that the Plan has regard to this.
Transport and Access to Residential Services
5.3 Paragraph 4.10 recognises that most new housing development in the urban area will enjoy good accessibility, including access to sustainable modes of transport, centres of employment, schools, shops and other residential services. It goes on to suggest that new development on sites removed from the Green Belt will require careful consideration in terms of sustainability and that transport improvements may be required on and off site. This phrasing is questionable bearing in mind that the Strategic Allocations identified as NGAs are located immediately adjacent to the urban edge of the conurbation and therefore benefit from proximity to many of the services and facilities that the existing residential areas already have access to. In addition, whilst the land identified as NGAs may necessitate transport improvements to offset the impact of the development proposals, it does not follow that they are necessarily unsustainable from a transport perspective as is suggested in paragraph 4.10.
Planning Obligations
5.4 Paragraph 4.21 refers to the financial viability that has impacted on the extent of planning obligations that can be secured in the Black Country. It states that greenfield sites and most brownfield sites will be able to sustain the full range of planning obligations required, as evidenced by the Viability and Delivery Study. However, this is clearly dependent on the sites' specific obligations that can come forward relative to each particular proposal. Should an individual allocation be identified as having a particular impact requiring mitigation, such as a significant upgrade to a major road junction, this will inhibit the ability to sustain the full range of planning obligations.