Draft Black Country Plan

Object

Representation ID: 18458

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.3 - "Strategic Allocations identified as Neighbourhood Growth Areas are located immediately adjacent to the urban edge of the conurbation and therefore benefit from proximity to many of the services and facilities that the existing residential areas already have access to." Also goes on to state that these sites are not necessarily unsustainable from a transportation perspective.

Object

Representation ID: 18462

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.4 - Financial viability evidenced in the Viability and Delivery Study is not sufficient to state that there wont be mitigation which could inhibit the ability to sustain the full range of planning obligations.

Comment

Representation ID: 18464

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.5 - "Policy DEL1 should be revised to identify these key tests set out in national policy to ensure all obligations required by DEL1 are properly justified."

Comment

Representation ID: 18465

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.6 - "Similarly, Criterions 4 and 5 refer to viability assessments. These should also reflect paragraph 58 of NPPF which sets out national policy in regard to these
matters and that particular circumstances can justify the need for a viability assessment at the application stage."

Object

Representation ID: 18468

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.7 - Delivery of FTTP "is reliant on the provider delivering the infrastructure and whilst the planning system can facilitate its delivery it cannot ultimately ensure it is provided. The policy needs amendment to reflect this."

Support

Representation ID: 18469

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.1 - "To do this new green and blue infrastructure will be provided and this could include allotments and gardens. L&Q Estates supports this objective."

Comment

Representation ID: 18471

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.2 - Neighbourhood Growth Areas have the opportunity to provide green and blue infrastructure to serve existing provision requirements,

Object

Representation ID: 18473

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.3 - "Contributions towards both the provision of acute NHS services and services provided by the CCG are not, as yet, universally verified as being compliant with the tests set out in the NPPF for lawful planning obligations."

Object

Representation ID: 18482

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.4 - "Criterion 5 refers to infrastructure contributions being sought on-site or its immediate vicinity. It will be wholly impractical for development of 11 dwellings to deliver infrastructure for healthcare on-site."

Object

Representation ID: 18484

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.5 - In relation to healthcare infrastructure "there is some uncertainty as to whether contributions towards such facilities are in accordance with the current CIL Regulations."