Object

Draft Black Country Plan

Representation ID: 43886

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

Representation Summary:

11.39 Policy CC6 deals with sustainable drainage and surface water management. It states all new development should incorporate SuDS which should be designed in line with the Black Country Local Standards for SuDS.
11.40 Whilst Taylor Wimpey supports the utilisation of SuDS, there are circumstances where SuDS are not feasible, such as ground conditions. In view of this the policy requires amendment to allow for such exceptional circumstances. Furthermore, Taylor Wimpey does not support cross reference to 'design standards'. Any standards should be contained within the Plan for clarity.
11.41 Criterion 3 states for major development surface water flows must be reduced back to an equivalent greenfield rate. It goes on to state that if greenfield run¬off rates are not considered to be feasible for viability reasons, then this must be evidenced by the developer. However, there are circumstances where, for reasons other than viability, such as location or size of development or other site constraints, where greenfield rates could not be achieved unrelated to viability. The Policy should be amended to reflect this.