Draft Black Country Plan

Comment

Representation ID: 19400

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 9.4 - In relation to cycle parking the policy should require parking to be located within the rear gardens or shared communal space not public parking areas due to inadequate maintenance or poor surveillance.

Object

Representation ID: 19401

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.2 - "It is not clear how development could similarly contribute towards improvements in geodiversity if the sites themselves had limited geological interest. The policy should be amended to make this more apparent."

Object

Representation ID: 19402

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.3 - "The PPG states that appropriate assessments will be required if a project is likely to be a significant effect on a protected habitats site. The policy would appear to suggest a single dwelling 14.5KM from the Cannock Chase SAC would have a significant effect."

Object

Representation ID: 19403

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.4 - "The justification to the policy identifies that development proposals can increase levels of nitrous oxide deposition that may affect designated SACs" The policy refers to a partnership approach to address this matter but there is a reliance on a partnership which does not yet exist.

Support

Representation ID: 19404

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.5 - "generally support the approach to improving biodiversity in conjunction with development proposals"

Object

Representation ID: 19405

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.6 - "Paragraph 10.39 identifies that the Black Country authorities have commenced work on a Local Nature Recovery Network Strategy but this is yet to be concluded." "It would appear that the approach in the plan is making an attempt to predict a policy context which is at the early stages of development and when the ultimate policy context may be significantly different."

Object

Representation ID: 19406

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.7 - Comments in relation to the reference map appendix 18 - Poor resolution of the map due to the scale and a concern expressed about how the plan will reconcile new housing schemes against the need to create enhanced ecological networks. "In addition, much of the evidence relating to these matters has not yet been published and at present it remains an untested map produced by the Wildlife Trust for Birmingham and the Black Country and the local Environmental Records Centre. This is not a sufficient basis for what could be a significant Plan policy which has ramifications for strategic and local development."

Support

Representation ID: 19411

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.8 - "Supportive of the principles set out in the policy and to delivering new tree planting in association with development proposals."

Object

Representation ID: 19412

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.8 - The requirement for large canopy trees a minimum contribution of 20% tree canopy cover and recommended 30% tree canopy cover would have a significant impact on the capacity for development, could conflict with highway requirements and sports/recreation spaces.

Comment

Representation ID: 19413

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.9 - Criterion 14 needs more justification and clarification.