Object
Publication Plan November 2022
Representation ID: 4991
Received: 20/12/2022
Respondent: Barratt West Midlands
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The policy states that “smaller areas of incidental green infrastructure without a clear recreational purpose (e.g. landscape buffers, highways verges) and areas without public access will not count towards meeting the quantitative on-site open space standard”. No definition is provided as to what constitutes ‘small’ nor how applicants can demonstrate that it serves a purpose. SSDC has also not provided any information to justify why small areas of green infrastructure will not be regarded as part of the open space provision. Landscape buffers, highways verges and other small areas of green space, may not be ‘useable’ from a recreation perspective but they provide visual benefits for residents and place-making as well connecting green infrastructure across sites and with the wider network. This policy will just encourage applicants to provide green infrastructure across sites. Barratt request that Policy HC17 be amended to remove reference to smaller areas of incidental green infrastructure not forming part of the on-site open space standard.
Although there is no specific policy proposed, SSDC is proposing to allocate Local Green Space (‘LGS’). The Local Green Space Topic Paper (2022) sets out three proposed LGS, two of which are located within the Parish of Kinver. Barratt has no comments on the proposed LGS and wishes to support the Council’s thorough approach to assessing whether the sites meet the NPPF criteria for LGS (paragraph 102). We consider that SSDC should require all Parish Councils / Neighbourhood Plan Forums to follow the same approach taken by the District Council. The emerging Kinver Neighbourhood Plan, proposes a blanket approach to designating Local Green Space across Kinver Parish. We have objected to the proposals as part of the Regulation 14 Neighbourhood Plan consultation process but wished to raise this concern with SSDC.