Draft Black Country Plan

Comment

Representation ID: 19380

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.6 - "The policy and its supporting text refer to the 'sequential test'. It is unclear why the sequential test is being referred to in the context of the delivery of contributions towards healthcare whether it be on-site or off-site."

Comment

Representation ID: 19381

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.7 - Paragraph 5.32 in relation to viability of healthcare provision contradicts the claims in DEL1 about the sites being tested for viability and able to deliver policy requirements.

Comment

Representation ID: 19382

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.1 - In relation to the introduction. "text does not refer to the need to provide a range of housing sites in differing locations in order to meet all housing needs. This factor is a key part of providing a balanced range of housing and should be referred to explicitly in the text."

Support

Representation ID: 19383

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.2 - L&Q Estates supports the reference to both net new homes and also that the housing land supply will deliver 'at least' 47,837 new homes.

Comment

Representation ID: 19384

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.2 - "Policy HOU1 does not refer to the significant shortfall in housing land supply that the BCP is proposing. Reference should be made to the shortfall and the means where this housing supply shortfall could be made up."

Object

Representation ID: 19385

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Table 4 - "It is unclear how the Council identified that 800 dwellings would be delivered by 2039, as it is L&Q Estates position that a significantly greater proportion could be delivered before the end of the plan period (see Appendix B for projected trajectory for Home Farm). Similarly, it is unclear why other sites which involved Green Belt release would also provide limited amounts of housing by the end of the plan period"

Comment

Representation ID: 19386

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.4 - Paragraph 6.4 of the plan sets out a balanced range of sites had been provided in terms of size, location and market attractiveness, which will help to maximise housing delivery over the plan period. This recognition of the need for variety in location and market attractiveness should be integral to the housing strategy."

Comment

Representation ID: 19387

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.5 - "Paragraph 6.7 states the Viability and Delivery study has indicated that housing capacity is likely to be limited by market delivery constraints. When reviewing the conclusions of the Viability and Delivery study, it notes that the larger the size of the development, the higher the delivery rate. It also states that the BCA had concluded that 1,715 homes on Green Belt release sites will not be delivered by 2039, rather than the evidence in the Viability study. This appears to be an inherent conflict."

Comment

Representation ID: 19388

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.6 - Recommends that the policy also explains where the evidence comes from for determining the range of houses and sizes.

Comment

Representation ID: 19389

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.7 - Table 5 and in relation to accessibility "In order to provide suitable flexibility in the market and in particular to reflect the location of specific sites, the supporting text and policy should both make clear that these figures are a guideline and will be informed by other evidence dependent on site location and specifics applying at the time that planning applications are determined."