Comment

Draft Black Country Plan

Representation ID: 44949

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Representation Summary:

Policy ENV2 - Development Affecting
Special Areas of Conservation (SACs)

18.1Taylor Wimpey’s Mob Lane site lies within the 15km Zone of Influence for the Cannock Chase
SAC, shown in Figure 11 of the Draft BCP.

18.2 Policy ENV2 states that an appropriate assessment will be carried out for any development that leads to a net increase in homes or creates visitor accommodation within 15km of the boundary of the SAC. If the appropriate assessment determines that the development is likely to have an adverse impact upon the integrity of the SAC, then the developer will be required to demonstrate that sufficient measures can be provided to either avoid or mitigate the impact. The policy notes that acceptable mitigation measures will include proportionate financial contributions towards the current agreed Cannock Chase SAC Partnership Site Access Management and Monitoring Measures (SAMMM).

18.3 The Black Country Plan Interim Regulation 18 HRA Report31 notes that appropriate assessment will now be undertaken and a HRA Report will then be prepared at the Regulation 19 stage of the plan making process.

18.4 Taylor Wimpey considers that any adverse impacts on the SAC and the measures required to mitigate impact need to be clearly identified in the appropriate assessment so it is clear to developers what the implications will be and any associated costs can be factored into the BCP viability work.

18.5 Any guidance produced to set out the detailed procedure and the level of financial contributions required needs to be consulted upon as part of the emerging BCP and should not be produced following the adoption of the Plan as this will not allow the viability implications to be properly considered through the BCP.