Showing comments and forms 1 to 2 of 2

Object

Part One: Spatial Strategy and Policies (Regulation 19)

Representation ID: 1341

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Similarly to Policy DLP55, these policies seek to protect non-designated heritage assets. The protection proposed would go over and above the level of protection afforded to such assets through the Framework. Furthermore, the policies as currently drafted are ambiguous as to how proposals are expected to respond to these designations, and how they will be assessed by the authority. Contribution to local character and distinctiveness are subjective matters, and it is a concern that this would be used by decision-makers to object to development proposals. In the context of unmet housing needs and significant environmental challenges and aspirations, it is considered that these policies represent an additional layer of policy that may challenge the delivery of development required to meet local needs. The Council must consider how these policies relate to national policy and guidance, and whether they are justified or necessary to remain in the emerging Plan, as these will likely be scrutinised in respect of consistency with national policy and other tests of soundness, through the plan examination process.

Object

Part One: Spatial Strategy and Policies (Regulation 19)

Representation ID: 1396

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Similarly to Policy DLP55, these policies seek to protect non-designated heritage assets. The protection proposed would go over and above the level of protection afforded to such assets through the Framework. Furthermore, the policies as currently drafted are ambiguous as to how proposals are expected to respond to these designations, and how they will be assessed by the authority. Contribution to local character and distinctiveness are subjective matters, and it is a concern that this would be used by decision-makers to object to development proposals. In the context of unmet housing needs and significant environmental challenges and aspirations, it is considered that these policies represent an additional layer of policy that may challenge the delivery of development required to meet local needs. The Council must consider how these policies relate to national policy and guidance, and whether they are justified or necessary to remain in the emerging Plan, as these will likely be scrutinised in respect of consistency with national policy and other tests of soundness, through the plan examination process.