Draft Black Country Plan

Comment

Representation ID: 18103

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.2 - "It should also reflect on the need to provide a range of housing sites to provide a choice in housing provision."

Comment

Representation ID: 18117

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.5 to 3.10 - Comments in relation to DtC and not explaining how housing shortfall will be met. More explanation on the need to provide a range of housing type and location of sites.

Comment

Representation ID: 18125

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraphs 3.11 to 3.13 - This policy should mention Neighbourhood Growth Areas and have equal importance with Strategic Centres and Core Regeneration Areas. A more balanced approach is needed in accordance with the vision and CSP1.
"the justification for the approach set out in CSP2, focusing growth solely in the Strategic Centres and Core Regeneration Areas" "The narrow focus set out in CSP2 also conflicts to an extent with paragraph 3.15 which acknowledges that Green Belt status should not be the sole criteria in assessing the suitability of a site’s ability to deliver sustainable development." "The justification to CSP2 actually highlights the failings of such a narrow
approach, in that it would only deliver housing on 'poor quality and underused land' which will not deliver a range of housing opportunity sites nor reflect the need to provide choice in both types of accommodation but also location."

Comment

Representation ID: 18130

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.14 to 3.17 - CSP3 should be given equal status with CSP2. It may not be practical to achieve strong and seamless links to regenerated areas in the Core Regeneration Areas and Strategic Centres. Sustainable advantages of new Neighbourhood Growth Areas and the ability of green belt release to provide choice in the housing market.

Comment

Representation ID: 18324

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.19 " references made in criterion 2 to the
use of carbon based products being minimised. It is not understood why the use of renewable timber, for instance, would need to be minimised in the interests of sustainability, energy efficiency and minimising the use of non renewable resources. In addition, referencing is made in criterion 5 to the urban environment being designed in a way to encourage people to act in a ‘civil and responsible manner’. Again, it is difficult to perceive how a development proposal will deliver these specific requirements on the ground."

Support

Representation ID: 18325

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.19 "the general themes identified in CSP4 are supported."

Support

Representation ID: 18328

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.7 "L&Q Estates generally support the approach set out in Policy CSP1, in particular the approach to providing Neighbourhood Growth Areas is supported in that this will deliver the broader range of housing sites necessary to provide choice."

Comment

Representation ID: 18455

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.21 to 3.22 - The policy should reinforce existing boundaries. Compensatory measures can be included within strategic allocation WSA1

Object

Representation ID: 18456

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.1 - Brownfield first approach not supported, broader approach recommended. Considered to undermine the "key part of the BCP which is to maintain a steady supply of housing land"

Comment

Representation ID: 18457

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.2 - "In itself mineral extraction can have significant adverse impacts on the amenity of neighbouring
properties. As set out elsewhere in these representations it is important that the BCP pays regard to this factor."