Draft Black Country Plan

Object

Representation ID: 23316

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 6.21 - 6.22 - Evidence and justification is required in the strategic policies.

Object

Representation ID: 23324

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 7.3 - 7.5 - "The dBCP now proposes to reduce the discount applied to sites with planning permission but not yet started (at April 2020) to just 5%." - "the research has only considered the rate of development in a single BCP authority area (Wolverhampton) " An assessment of Wolverhampton's AMR demonstrates that the lapse rates have stayed the same or decreased.

Object

Representation ID: 23325

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 7.6-7.8 - "RPS objects to the proposed increase in the density standards in the dBCP and recommends that the addition of 476 dwellings should be discounted from the overall supply included in Table 3 of the BCP." Minimum densities are not flexible enough and contrary to the NPPF para 125a in locations outside of the main city and town centres.

Support

Representation ID: 23326

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 7.9 - The dBCP considers there is no or minimal additional housing supply likely to arise from sites currently occupied by employment uses, which is agreed..

Object

Representation ID: 23327

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 7.10 - 7.13 - Funding for housing development in Strategic Centres needs to be evidenced. The viability study determines such areas as unviable, but the Black Country Urban Capacity Report suggests a capacity for 1300 houses in strategic centres. The additional supply of 1300 dwellings should be reconsidered.

Object

Representation ID: 23346

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.4 - In relation to Yorks Bridge the housing numbers and net developable between the Sustainability Appraisal, Site Assessment Report and St Modwen Vision Document do not tally.

Object

Representation ID: 23347

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.8 - 8.12 - Contrary to the finding of the Sustainability Appraisal, a historic assessment of the Site and its surroundings has bene prepared on behalf of St Modwen, which concluded that no intervisibility exists between the Site and the Grade II Listed Pelsall Works Bridge or the Grade II Listed Wyrley & Essington Canal Footbridge at Pelsall Junction.

Object

Representation ID: 23351

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.11 - 8.15 The SA scores York's Bridge a minor negative score because it lies adjacent to an area of High Historic Townscape Value. This relationship according to the SA methodology should score a 0.

Object

Representation ID: 23352

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.16 -8.17 - Table H.2.1, "Only one of these sub-criteria, 'listed building', has been scored as minor negative, the other 7 have all scored neutral. RPS contends that the overall score of minor negative is unduly harsh and does not reflect the overall neutral effect of the site on cultural heritage as a whole."

Object

Representation ID: 23353

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.18 - 8.20 - The SA relies on the Landscape Sensitivity Assessment and the site is small within a much larger parcel and none of the identified constraints affect Yorks Bridge. Also "the SA places significant emphasis on the importance of views of the site, which is not reflected in the LSA appraisal findings"