Comment

Draft Black Country Plan

Representation ID: 44847

Received: 11/10/2021

Respondent: Ruskin Properties

Representation Summary:

However, concerns are raised regarding the ability of development to achieve 10% when balanced against other competing needs of the plan (affordable housing, planning obligations and densities) and the practicalities of delivering 10% in relation to residential development within urban areas. Clarity is required on what ‘measured against baseline site information’ means.
Whilst the policy states that provision on site is preferred, it does not define what is meant by ‘practicable.’ Does this mean in terms of viability/land-take or the ability for land to be managed and maintained for the long-term?
No information is given in terms of potential costs associated with an off-site contribution to sites within the local area. This will be required for developers to consider on and off-site options and to help inform negotiations on development values with landowners.