Comment

Draft Black Country Plan

Representation ID: 44931

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Representation Summary:

Policy HW2 - Healthcare Infrastructure

9.1 Part 3 of Policy HW2 states that proposals for major residential developments which would have unacceptable impacts upon the capacity of these facilities, developers will be required to contribute to the provision or improvement of such services, in line with the requirements and calculation methods set out in local development documents.

9.2 Part 7 notes that for strategic sites, the likely requirement for on-site provision for new health facilities is set out in Chapter 13. In this regard we note that Policy WSA.2 suggests that a local health centre will be required on the allocation.

9.3 The justification text to Policy HW2 [§5.32] states that depending on the extent of other planning obligations required, such contributions may not be viable on some sites. This appears to be inconsistent with §4.21 of the Draft BCP which states that greenfield sites and most brownfield sites will be able to sustain the full range of planning obligations required.

9.4 As this policy requirement will affect allocations in the BCP and will be used to inform infrastructure provision on these sites, Taylor Wimpey considers that these requirements and calculation methods should be identified in the BCP. This is the only way to ensure that the requirements of the policy are transparent and justified and can be appropriately tested through
the viability work which accompanies the plan.