Draft Black Country Plan

Object

Representation ID: 23551

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.21 - 8.22 - Objection in relation to J13.12.7 of the SA which refers to the loss of over 20ha of undeveloped land when the developable area is just 13.47ha.

Object

Representation ID: 23552

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.23-8.24 - The major negative score in relation to the MSA should take account that the economic extraction of fireclay is only viable if extracted concurrently with coal, which in the supporting evidence for the MSA approach "prepared by Wood Environment & Infrastructure Solutions UK Ltd" is confirmed to be unlikely during the plan period.

Object

Representation ID: 23553

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 8.25 - 8.27 - "The SA assessment scores the Site as minor negative; however, no explanation is given in the commentary as to why the Site has been scored in this way."

Support

Representation ID: 23554

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 9.4-9.7 - RPS agree that exceptional circumstances exist to justify the redrawing of green belt boundaries. "Political pressures to alter this position must be avoided, otherwise the result will inevitably result in the plan being found unsound through the Examination process."

Object

Representation ID: 23555

Received: 11/10/2021

Respondent: St Modwen SL&R

Agent: RPS

Paragraph 9.11 - 9.20 - "The findings of the site-specific Green Belt Assessment undertaken by RPS indicate that LUC have erred in the application of their methodology through identifying the Site as part of the wider parcel B117A as a result of the stage 1 process, having not taken account of the differences in contribution to the purposes of the Green Belt between the Site and land further to the north. "