Draft Black Country Plan

Comment

Representation ID: 13582

Received: 27/10/2021

Respondent: Lanpro Services

Comments on Specific Policies
Policy CSP1 - Development Strategy and Policy GB1 - The Black Country Green Belt
For both these policies, the introduction of a caveat is necessary, to stipulate that whilst the general principle that inappropriate
development in the Green Belt will be resisted, this would not be the case where Very Special Circumstances exist. For Policy CSP1 ,
additional wording to point '2e' should be added to cover this. For Policy GB1, similar wording should be added to point '3'. Clarity on
National Policy requirements in this regard is important to guide decision makers in applying the policy.

Comment

Representation ID: 13583

Received: 27/10/2021

Respondent: Lanpro Services

Comments on Specific Policies
Policy CSP1 - Development Strategy and Policy GB1 - The Black Country Green Belt
For both these policies, the introduction of a caveat is necessary, to stipulate that whilst the general principle that inappropriate
development in the Green Belt will be resisted, this would not be the case where Very Special Circumstances exist. For Policy CSP1 ,
additional wording to point '2e' should be added to cover this. For Policy GB1, similar wording should be added to point '3'. Clarity on
National Policy requirements in this regard is important to guide decision makers in applying the policy.

Comment

Representation ID: 13584

Received: 27/10/2021

Respondent: Lanpro Services

Policy CC7 - Renewable and Low Carbon Energy and BREEAM Standards
Part 1 of the Policy outlines that 'Proposals involving the development of renewable or low carbon energy sources will be permitted where
the proposal accords with local and national guidance and would not significantly harm the natural, historic or built environment or
have a significant adverse effect on the amenity of those living or working nearby, in terms of visual, noise, odour, air pollution or other
effects...'. The use of the 'and' clause following 'national guidance' has the effect of stipulating that proposals which have any element of
significant harm will not be permitted. This is contrary to the principle of planning balance that is required of decision takers by the
NPPF. In practical terms, a proposal for renewable energy may have a single significant harmful impact, but this may be outweighed
by the benefits of the proposal. The policy should allow for such circumstances. We would suggest rewording the policy and adding
text to the effect of 'unless material considerations state otherwise'. We would also suggest additional wording is added to the policy
to encourage independent renewable proposals to be brought forward separately from other development, to be clear that the
Council is committed to meting Net Zero by 2041 and will work with applicants to achieve this.
We welcome the narrative in the supporting text that acknowledges that many types of renewable and low carbon energy generation
is considered to be appropriate on the Black Country.