Draft Black Country Plan

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Draft Black Country Plan

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Representation ID: 19390

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 6.8 - The approach to affordable housing provision is supported.

Object

Draft Black Country Plan

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Representation ID: 19391

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 6.10 - The 15% requirement for wheelchair user homes is too high and would result in an excess in provision, the figures for which are only accounted for by BCP allocated sites and do not take account of development outside of these allocations.

Object

Draft Black Country Plan

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Representation ID: 19392

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 6.11 - The requirement of 5% custom or self build housing for sites with 100 houses or more is too high, as demonstrated in paragraph 6.29 which references the self build and custom build registers which indicate low demand in the area for such development.

Comment

Draft Black Country Plan

Policy HOU5 – Education Facilities

Representation ID: 19393

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 6.12 - The requirement for developer contributions for education as set out in HOU5 is supported, however the policy should recognise that the local education authority or free schools will deliver these facilities.

Comment

Draft Black Country Plan

7 The Black Country Economy

Representation ID: 19394

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 7.1 - Supports the balanced approach to delivering employment land, but with the following caveat "the plan should recognise the changing nature of much employment, including following the Covid-19 pandemic which has seen a shift towards home working, alongside the Government’s ambition to allow for more flexible working patterns and potentially consider the inclusion of local employment 'hubs' which would allow for working in close proximity to residents' homes whilst allowing for the more social aspects of office working."

Comment

Draft Black Country Plan

Policy CEN5 - Provision of Small-Scale Local Facilities

Representation ID: 19395

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 8.1 - "As currently drafted Policy CEN5 is likely to weigh against the delivery of local retail and similar facilities envisaged in the Neighbourhood Growth Areas and which are requirements within chapter 13.
The policy should also reflect on the potential to deliver small scale office type facilities (as local working 'hubs') which would be both appropriate and add to the facilities provided in Neighbourhood Growth Areas in particular."

Support

Draft Black Country Plan

Policy TRAN1 Priorities for the Development of the Transport Network

Representation ID: 19396

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 9.2 - "generally support the approach identified in TRAN1 which includes safeguarding land needed for the implementation of priority transport networks, providing adequate access to all modes of travel in association with new developments, key transport corridors being prioritised through the delivery of new infrastructure to support various transport improvements and the various identified specific transport improvements."

Comment

Draft Black Country Plan

Policy TRAN1 Priorities for the Development of the Transport Network

Representation ID: 19397

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 9.2 - "it is unclear how paragraph 9.220, which predicts that bus services will have recovered at a faster rate than even rail or metro by 2026, has been evidenced. In addition, the emphasis on bus services should recognise that congestion is likely to be a significant factor both on patronage, attractiveness of the bus and journey times."

Comment

Draft Black Country Plan

Policy TRAN3 Managing Transport Impacts of New Development

Representation ID: 19398

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 9.3 - Policy TRAN3 should be revised to take account of physical or design barriers which may exist at sites which could prevent bus penetration through a site.

Comment

Draft Black Country Plan

Policy TRAN5 - Creating Coherent Networks for Cycling and for Walking

Representation ID: 19399

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Representation Summary:

Paragraph 9.4 - Policy TRAN5 should be amended to allow for more flexible transport infrastructure for multiple users, for example "combined pedestrian/cycle routes and other routes which could be shared by bus services but not car users."

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