Publication Plan April 2024

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Comment

Publication Plan April 2024

1.18

Representation ID: 7381

Received: 31/05/2024

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

Representation Summary:

There are discrepancies with the extent of the ‘Green Infrastructure’ boundary in relation to the ROF Featherstone site on Inset Plan 51 “ROF Featherstone”. To ensure consistency, we ask that the authority amend Inset Map 51 so that the boundary of the ‘Green Infrastructure’ reflects the extent of the outline and reserved matters planning approval (references: 20/01131/OUT and 23/00378/REMM) for the ROF Featherstone site.

We also note that the access road has not been included on Inset Map 51 which would extend into parts of the Green Infrastructure area to the west and across to the A449. This access route is currently shown in the adopted Site Allocations Document, and we therefore ask that the position of the access road is reinstated on Inset Map 51.

Any changes made to Inset Map 51 to address our above comments should also be reflected on the plans included at Page 223 and Page 246 of the Publication Plan Regulation 19 document.

Comment

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 7382

Received: 31/05/2024

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

Representation Summary:

Policy DS5 sets out the spatial strategy approach for delivering development during the plan period to 2041. In relation to the wording within the policy, which refers to the district’s freestanding strategic employment sites, the policy wording for this element should make it clear that any proposals for alternative uses would be determined against the provisions of Policy EC2.

Comment

Publication Plan April 2024

Policy SA5 - Employment Allocations

Representation ID: 7383

Received: 31/05/2024

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

Representation Summary:

The policy includes the following wording:
“… The above sites represent those within the district’s pipeline supply of sites as at April 2023 without a full or reserved matters planning permission, in addition to West Midlands Interchange...”

This sentence is irrelevant to the purpose of the policy wording and as demonstrated in the case of ROF Featherstone which has since received Reserved Matters Approval, will become immaterial with the passage of time. The inclusion of this sentence is not therefore necessary in the policy wording.

Comment

Publication Plan April 2024

Policy EC2: Retention of employment sites

Representation ID: 7384

Received: 31/05/2024

Respondent: ST FRANCIS GROUP

Agent: Carneysweeney

Representation Summary:

We agree with the Council’s view to provide a policy mechanism to allow employment land, sites and/or allocations to come forward with alternative uses. However, the specific criteria within Policy EC2 does not fully reflect this latter part of Paragraph 10.5. The period of marketing required should be focused on preventing the loss of existing sites, as opposed to allocations. Suggested wording to address this is contained within the representation.

Concerns with the paragraph that starts with “There is a strong presumption...” This paragraph states there is a strong presumption that the strategic employment sites will be retained for employment use. Request that the following wording is added to end of this paragraph: “ Development proposals for alternative uses on strategic employment sites will also be considered against the provisions of this policy.”

This reflects that there may specific circumstances where strategic sites may be required to be considered for an alternative use.

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