Preferred Options November 2021

Object

Representation ID: 1869

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Inconsistencies between the draft policy and national planning policy.
Reference to 'development within the Green Belt must retain its character and openness' is inconsistent with wording of NPPF and should be removed or amended.
Draft policy approach provides specific guidance on "infill development" and 'affordable housing' but GB policy in next round of consultation should reflect Paragraph 149 of NPPF and offer guidance within supporting text.

Object

Representation ID: 1873

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Lack of consistency with the protection being afforded to employment sites.
Land at Hobnock Road is included within the employment land at Table 9 but is not proposed for allocation - there is uncertainty as to whether these sites are allocated as employment land.
Policy EC2 does not acknowledge the importance of allocating other employment sites that are available and deliverable during the plan period such as Land at Hobnock Road.

Support

Representation ID: 1874

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Policy EC2 - support the approach to protect existing designated employment sites.

Object

Representation ID: 1875

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Do not agree with the conclusions made in the Site Assessment Topic Paper 2021 and Sustainability Appraisal 2021.
Land at Hobnock Road has an extensive history of employment use and therefore should be allocated.
Land at Hobnock Road benefits from a Certificate of Lawful Use confirming employment use.
Land at Hobnock Road was presented to committee for approval as employment use (16/01000/FUL) but overturned by members.
Land at Hobnock Road continues to form part of the employment land supply.
The EDNA 20212 concluded Land at Hobnock Road was 'good quality' employment land.
EDNA 2019 identified Land at Hobnock Road as 'good quality' employment land whilst wider site was considered to be "potentially suitable for employment development".
GB Asessment Stage II identifies Land at Hobnock Road as having 'high' harm but this is inconsistent with LPA assessment of site during determination of 16/01000/FUL.
Land at Hobnock Road should be allocated for employment use.