Object
Draft Black Country Plan
Representation ID: 45868
Received: 11/10/2021
Respondent: St Modwen Developments Ltd
Agent: Planning Prospects Ltd
Comments on: Policy ENV9 – Design Quality
Nature of comment: Objection
5.6 The references to compliance with the Building Regulations at parts 1d) and 3) of this policy are superfluous and should be removed. There is no need for planning policy to direct compliance with separate legislation.
5.7 The requirement for all new residential development to meet the NDSS (except where it would cause heritage harm) at part 4) of the policy is inappropriate. Whilst the NDSS might be targeted in many instances, there will also be circumstances (other than where heritage is an issue) in which it is desirable to deviate from them. One example of this is the development of “micro-homes” which have been successfully deployed in many locations to meet specific housing needs, such as providing “move on” accommodation to
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help people transition back into the wider housing market. As currently framed the policy would frustrate this and indeed other innovative approaches to meeting the full range of housing needs.
5.8 To remedy this, part 4) of the policy should be amended to include as a further exception the provision of housing types to meet a particular need where deviation from the NDSS can be justified.
DRAFT BLACK COUNTRY PLAN REGULATION 18 CONSULTATION