Sandwell Local Plan Main Modifications Consultation
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Sandwell Local Plan Main Modifications Consultation
SNE3.1
Representation ID: 1740
Received: 27/03/2026
Respondent: Mrs Sara Lovell
Legally compliant? Yes
Sound? No
Though we recognise the intention is to seek alignment with current NPPF terminology. We believe that the proposed wording introduces ambiguity as there is no clarity regarding what may constitute wholly exceptional reasons and what a suitable compensation strategy would look like. We suggest that suitably aligned wording could be ' ... refused unless wholly exceptional reasons to allow it and a suitable compensation strategy both exist. The council will seek to develop guidance regarding what constitutes wholly exceptional circumstances consist and suitable compensation strategy.'
Comment
Sandwell Local Plan Main Modifications Consultation
SNE3.2 Paragraph 4.62
Representation ID: 1741
Received: 27/03/2026
Respondent: Mrs Sara Lovell
We suggest an explicit reference to the standing/joint advice should be made in the policy wording as follows: '... Development adjacent to ancient woodland and / or groups of ancient or veteran trees will be required to provide an appropriate landscaping buffer, with a minimum depth of 15m and in line with Natural England/Forestry Commission joint advice (including link/reference https://www.gov.uk/guidance/ancient-woodland-ancient-trees-and-veteran-trees-advice-for-making-planning-decisions).
Comment
Sandwell Local Plan Main Modifications Consultation
SHW4.2
Representation ID: 1742
Received: 27/03/2026
Respondent: Mrs Sara Lovell
The increased loss of open space provision should lead to a greater requirement for new, increased provision so the council should be urgently and ambitiously seeking a more ambitious target not reducing the expectation of open space provision. The heavily urbanised nature of the borough as well as the further demands relating to housing and employment land, make it the more important that new greenspace provision is appropriately equitable and of a good standard across all areas of the borough. We are keen to see a more ambitious target and certainly not a reduction in the requirement.
Comment
Sandwell Local Plan Main Modifications Consultation
SHO1.1
Representation ID: 1743
Received: 27/03/2026
Respondent: Mrs Sara Lovell
We are concerned with the lack of explicit references to affordable housing targets in the policy.
Comment
Sandwell Local Plan Main Modifications Consultation
Paragraph 7.4
Representation ID: 1744
Received: 27/03/2026
Respondent: Mrs Sara Lovell
We remain concerned with the impact the plan proposals and high/increased housing targets on locally designated sites and locally important habitats, species and ecological networks as well as the council's ability to commit to and deliver on local nature recovery ambitions in the borough.
Comment
Sandwell Local Plan Main Modifications Consultation
STR5 Paragraph 11.51
Representation ID: 1745
Received: 27/03/2026
Respondent: Mrs Sara Lovell
We welcome the references to ecological sensitivity in the policy wording. We suggest a further amendment is important as follows: '... Where cycle routes and associated facilities are located in areas of heritage, archaeological or ecological sensitivity, their design should take this into account, appropriate safeguards put in place and enhancement opportunities sought.
Comment
Sandwell Local Plan Main Modifications Consultation
Glossary Appendix O (now Appendix N)
Representation ID: 1746
Received: 27/03/2026
Respondent: Mrs Sara Lovell
The policy should recognise and include explicit reference to green infrastructure provision in line with GI framework and standards https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework
Comment
Sandwell Local Plan Main Modifications Consultation
Paragraphs 16.1 – 16.5
Representation ID: 1747
Received: 27/03/2026
Respondent: Mrs Sara Lovell
Alongside the annual monitoring report on delivery of allocations with respect to this policy area, a corresponding annual monitoring report of impact and record of land use changes. We are especially concerned that any changes to and loss of, (including partial loss) habitats and land designated for nature conservation are appropriately recorded.
Comment
Sandwell Local Plan Main Modifications Consultation
New policy SSH1
Representation ID: 1748
Received: 27/03/2026
Respondent: Mrs Sara Lovell
We would seek reassurances that the area currently designated as SLINC and ecological connectivity will be retained and enhanced. This should be made explicit in the policy wording.
Object
Sandwell Local Plan Main Modifications Consultation
New policy SSH2
Representation ID: 1749
Received: 27/03/2026
Respondent: Mrs Sara Lovell
Legally compliant? Yes
Sound? No
We continue to object to the loss of the area designated as Site of Local Importance for Nature Conservation. Any development proposals in the area should ensure the SLINC is safeguarded and appropriate open space provision levels are met. The quantum and type of development should be in line with those principles/requirements.