Object

Draft Black Country Plan

Representation ID: 43885

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

Representation Summary:

11.38 Policy CC5 deals with flood risk, of which Criterion 2 indicates that the sequential test will be applied to all developments to ensure that it takes place in areas with the lowest flood risk. This does not accord with the NPPF or PPG, which only requires a flood risk assessment to be provided in respect of major developments or developments within areas of defined flood risk. The Policy needs to be clearer and that the sequential test referred to in Criterion 2 only applies to the specific circumstances set out in the NPPF. Paragraph 167 of the NPPF is clear that only certain applications will be subject to site specific flood risk assessments and this in turn can lead to the application of the sequential test for flood risk. The Policy should reflect this.