Draft Black Country Plan

Support

Representation ID: 20971

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.22 to 10.23 - Generally supportive but proposes an amendment for the preference of a fabric first method.

Object

Representation ID: 20974

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.24 - "L&Q Estates support the need to minimise energy usage but question the approach taken in Policy CC2 which is requiring a number of specific energy elements to be analysed in an environment where much of both the technology and in particular ability to deliver items such as combined heat and power are at tentative early stages."

Support

Representation ID: 20982

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.25 - Supports a diverse approach to dealing with air quality.

Object

Representation ID: 20984

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.25 - Identifies conflict between Criterion 2 and 4, and suggests that Criterion 2 should be amended so that in overall terms air quality is not diminished by development rather than "an in principle objection to any proposal that could have even the slightest degradation of air quality." Also concludes that Criterion 1 is also amended.

Object

Representation ID: 20987

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.26 - "The policy needs to be clearer and that the sequential test referred to in Criterion 2 only applies to the specific circumstances set out in the NPPF."

Object

Representation ID: 20991

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.27 - There are circumstances where SuDS are not suitable and where there are circumstances other than viability which prevents greenfield rates being achieved.

Object

Representation ID: 20992

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.28 - 10.29 - No evidence to support a 19% carbon reduction improvement over part L of building regulations and reference to separate legislation not in force is not appropriate for a development plan document. The justification acknowledges viability issues before site specific circumstances are known and it is not sound to include a blanket requirement.

Comment

Representation ID: 20993

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 11.1 - Not clear why only Walsall has mineral safeguarding. The policy itself should take account of site specific factor such as surrounding residents.

Comment

Representation ID: 20994

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 12.2 - "The supporting text should also be amended to make clear that these areas have been identified through a number of specific studies looking at such matters as the Green Belt, landscape sensitivity, ecological impact and other environmental factors." Also commented is that these areas can also provide additional facilities to support existing communities.

Comment

Representation ID: 20995

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 12.3 - "It is envisaged that the Sandhills site could deliver a significantly larger amount of housing by 2039 than that assumed by the Council in Table 31 as is set out in Appendix B."