Draft Black Country Plan

Comment

Representation ID: 23076

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

2.1 - 2.12 - Lack of clarity on the current position is the lack of any reference or recognition that the full extent of the York’s Bridge site promoted by St Modwen in fact straddles the Walsall-Cannock Chase District boundary.

Object

Representation ID: 23077

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraphs 3.1-3.9 - The proposed housing provision of 47,837 net new homes is considered to be an over estimate relying too much on strategic centres to deliver housing where there has been an under-delivery since 2006.

Object

Representation ID: 23078

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

4.1 - 4.5 The existing allocations in the Strategic Centres should be reviewed and findings fed into a revised land supply position and housing trajectory. More pressing need to release Green Belt than is being suggested in the dBCP.

Object

Representation ID: 23104

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 4.6 - 4.9 - The 40dph minimum rate is challenged on the grounds that it is inflexible, lower density housing has provided 14% of completes (2011-2020) and to rely on the flexibility of ENV5 might be ambiguous contrary to NPPD requirements.

Object

Representation ID: 23115

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraphs 4.11 - The evidence does not justify a 'minimum 20%' contribution.

Object

Representation ID: 23116

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 4.12 - 4.14 - The reliance on the Black Country Housing Market Assessment 2021 (BCHMA) for evidence of the demand for accessible, adaptable and wheelchair accessible homes over the next 19 years does not take account that the majority of the demand is likely to be from people already housed. It is unclear how the standards set out in the policy have been derived.

Object

Representation ID: 23117

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 4.15 - 4.16 - The policy seeks 5% custom and self build housing on plots with development over 100 dwellings. Current demand is evidenced as being 32 plots for Walsall but the policy would generate 272. The 5% requirement is not justified.

Object

Representation ID: 23118

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 5.1 - 5.2 - "Criteria 3 of the policy indicates that the type of infrastructure, and the prioritisation of resources to fund it, will be set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, masterplans." this deferment is contrary to the NPPF and unjustified.

Object

Representation ID: 23119

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 5.3 - 5.5 - No evidence has been provided to demonstrate that a site-specific viability assessment submitted within the BCP area should only be submitted in exceptional circumstances. Also the policy does not offer any support for proposals that can address barriers caused by inadequate infrastructure.

Object

Representation ID: 23121

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 5.6 - 5.9 - "DEL3 is contrary to national policy, which does not require new housing developments to make provision for FTTP or 5G networks, but instead (at paragraph 114) indicates that planning policies should support the expansion of electronic communications. "