Comment

Representation ID: 45876

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

6.0 Policy DEL1 - Infrastructure Provision
6.1 Taylor Wimpey objects to Part 3 of Policy DEL1. Whilst the need to bring forward sufficient
infrastructure to support new development is recognised, the proposed approach set out in the
policy is considered to be flawed as it fails to clearly identify what the infrastructure
requirements will be to deliver and fund the allocations.
6.2 The Financial Viability Assessment Report (May 2021) claims that it is a full viability
assessment of the draft policies and proposed site allocations in the emerging Black Country
Plan (BCP) (which will replace the Black Country Core Strategy (BCCS)). It states that the
viability assessment is also sufficiently robust to be able to be used as the basis for a review of
the Community Infrastructure Levy (CIL) within each of the BCA areas with a view to future
alignment (§1.6).
6.3 Part 3 of the policy states that:
“The BCA will set out in Development Plan Documents, Infrastructure Delivery Plans,
Supplementary Planning Documents, and where appropriate, masterplans:
a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure
provision”.
6.4 Taylor Wimpey considers that all of the above information and the associated costs need to be
provided in the BCP at this stage. This is the only way to provide certainty on what is required
and for the requirements to be tested through the viability evidence accompanying the plan to
ensure that development within the plan area will be deliverable, in accordance with the
Framework. It is also noted that a key requirement of the Framework [§11 a] requires that
growth and infrastructure are aligned. As currently drafted the Plan fails to identify the
infrastructure needed to deliver the plan and the funding mechanisms that will deliver them.
This needs to be provided to ensure that the Plan can be found sound as it progresses. We are
concerned that the CIL and any required financial contributions in combination could lead to
developments being unviable. Certainty needs to be provided as to what will be provided
through the Infrastructure Funding Statement so there is no double counting.