Black Country Core Strategy Issue and Option Report
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Black Country Core Strategy Issue and Option Report
Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you
Representation ID: 136
Received: 05/09/2017
Respondent: National Trust
This seems an appropriate means for ensuring that the plan remains up to date.
This seems an appropriate means for ensuring that the plan remains up to date.
Object
Black Country Core Strategy Issue and Option Report
Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there
Representation ID: 137
Received: 08/09/2017
Respondent: National Trust
The evidence base proposed contains no reference to heritage assets. Chapter 12 of the NPPF sets out how heritage assets should be considered in development planning and when considering the impacts of specific development proposals.
The evidence base proposed contains no reference to heritage assets. Chapter 12 of the NPPF sets out how heritage assets should be considered in development planning and when considering the impacts of specific development proposals.
Object
Black Country Core Strategy Issue and Option Report
Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
Representation ID: 138
Received: 08/09/2017
Respondent: National Trust
1. The review should consider whether the changes required are such that they would restrain the ability of the Black Country authorities and neighbouring authorities to meet the full extent of the assessed housing need.
2. The review should integrate consideration of compensatory improvements to the environmental quality or accessibility of remaining Green Belt land.
In general terms the proposed approach follows both national policy and the approach set out in the 2017 Housing White Paper. However, we are concerned on two points.
Firstly, the review should address whether the changes to the green belt that would be required are such that they would restrain the ability of both the Black Country Authorities and the neighbouring authorities to meet the full extent of the assessed housing need. DCLG has recognised this as a possibility in its October 2014 statement, "Councils must protect our precious Green Belt land". This statement has been incorporated into National Planning Practice Guidance (ID 3-045-20141006, https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment) and is reiterated in the House of Commons Briefing Paper 'Green Belt' published in January 2016 (http://researchbriefings.parliament.uk/ResearchBriefing/Summary/SN00934)
Secondly, the review should integrate consideration of compensatory improvements to the environmental quality or accessibility of remaining Green Belt land that should be associated with the release of Green Belt land for development, as set out in paragraph 1.39 of the Housing White Paper.
Support
Black Country Core Strategy Issue and Option Report
Question 96 - Do you support the proposed changes relating to nature conservation? Yes/No; If no, do you think that any other changes should be made to Policy ENV1?
Representation ID: 139
Received: 08/09/2017
Respondent: National Trust
We welcome the inclusion of Ancient Woodland in the list of national designations. We also welcome the proposed incorporation of biodiversity features in the list of requirements for new development.
We welcome the inclusion of Ancient Woodland in the list of national designations. We also welcome the proposed incorporation of biodiversity features in the list of requirements for new development.
Object
Black Country Core Strategy Issue and Option Report
Question 97 - Do you support the proposed changes relating to Historic Character and Local Distinctiveness? Yes/No; If no, please provide details of any other changes that should be made to Policy EN
Representation ID: 143
Received: 08/09/2017
Respondent: National Trust
Design and Access Statements are still required in some instances - for example for major developments, new dwellings in Conservation areas and in applications for listed building consent (see Planning Practice Guidance 14-030-20140306). Reference should also be made to the requirements set out in NPPF paragraph 128 regarding the information to be supplied by applicants.
Design and Access Statements are still required in some instances - for example for major developments, new dwellings in Conservation areas and in applications for listed building consent (see Planning Practice Guidance 14-030-20140306). Reference should also be made to the requirements set out in NPPF paragraph 128 regarding the information to be supplied by applicants.
