Comment

Draft Black Country Plan

Representation ID: 46197

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Representation Summary:

20 Paragraph 16 of the Framework is clear that development plans should contain policies that are clearly written and unambiguous. Draft policy CC2 is not clear in respect of on what grounds applicants will be able to demonstrate that development is not suitable, feasible or viable for district heat or decentralised power networks. Draft policy CC2 needs to provide clear direction in this regard. It is also without justification why the threshold for compliance is ten units/1,000 sq. m and why there are no further thresholds at greater unit numbers/floorspace, which would allow for proportionate consideration of proposals relative to scale. The draft policy should be revised to remove ambiguity and introduce additional trigger thresholds to ensure that it is sound in the context of being clear and positively prepared.