Policy HC17: Open Space

Comment

Representation ID: 4084

Received: 13/12/2022

Respondent: Staffordshire Police

Play areas should be located where they will have natural surveillance, from the community and residents (if appropriate), the play area should not be positioned away from the natural footfall of the dog walkers and joggers. An evaluation of the needs of the community should be addressed prior to implementation of this area. Consideration should be given to increase the availability of allotments to encourage growing their own produce, as well as improving their health and wellbeing.

Support

Representation ID: 4141

Received: 21/12/2022

Respondent: Kinver Neighbourhood Plan Group

We note the requirement for public on-site spaces. We urge the council to ensure that these are actually provided on-site, unless discussion with the local community indicates a preferable option.

Comment

Representation ID: 4225

Received: 20/12/2022

Respondent: Penkridge Parish Council

The open space requirements have been reduced to 0.006ha from 0.01ha per dwelling. This effectively nearly halves the provision of amenity and usable open space and green spaces throughout all the new estates .

Object

Representation ID: 4410

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
See supporting representations for further details.

Object

Representation ID: 4494

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
See supporting representations for further details.

Object

Representation ID: 4524

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
See supporting representations for further details.

Object

Representation ID: 4550

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.

Object

Representation ID: 4575

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide little flexibility with regards to a site’s context.
See supporting representations for further details.

Object

Representation ID: 4607

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.

Object

Representation ID: 4639

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to policy HC17, because it is not effective or justified. 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 of what constitutes ‘small’ is provided 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 always be ‘useable’ from a recreation perspective but they can still provide visual benefits for residents and place-making as well connecting green infrastructure across sites with the wider network.

We 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. This blanket requirement is too restrictive and does not allow enough flexibility.

Object

Representation ID: 4663

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
See supporting representations for further details.

Support

Representation ID: 4689

Received: 12/12/2022

Respondent: Mr Mark Stephens

Agent: Advance Land & Planning Limited

Support the open space requirement of 0.006ha/dwelling.
Some flexibility should be allowed for whether on-site open space should include equipped play provision, especially where good quality provision is accessible nearby.

Object

Representation ID: 4703

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.

Comment

Representation ID: 4830

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

The policy should be amended to allow for equipped play provision off-site in circumstances where there is existing public open space or play facilities available within walking distance of the site that would benefit from either; new equipped play provision, or the expansion and/or improvement of existing play equipment though financial contributions.

Comment

Representation ID: 4891

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The approach of this policy is welcomed, which provides flexibility in terms of the location of any open space – to respond to a site’s characteristics to ensure any
development maximises recreational use. This is a more appropriate approach than being specific about the potential location of open space, as had been previously
proposed by the preferred options consultation.

Comment

Representation ID: 4930

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The approach of this policy is welcomed, which provides flexibility in terms of the location of any open space – to respond to a site’s characteristics to ensure any
development maximises recreational use. This is a more appropriate approach than being specific about the potential location of open space, as had been previously proposed by the preferred options consultation.

Comment

Representation ID: 4944

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Policy far too prescriptive and will lead to developments
of too similar character and blandness. There should be more flexibility built into the policies to allow for the individual circumstances of each site and its context.

Object

Representation ID: 4951

Received: 23/12/2022

Respondent: Churchill Retirement Living

Agent: Planning Issues

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Housing designed for a range of potential occupiers requires greater outdoors space to accommodate children's place, light exercise space and socialising. In contrast occupiers in specialist elderly schemes tend to use garden space in a passive way (i.e. sitting out). Specialist schemes also tend to incorporate internal communal facilities such as lounges or coffee bars to promote social interaction, which are valued far more than large grassed areas.


A requirement of 60m2 per dwelling substantially exceeds the needs of residents of older persons' housing and should be determined on a case-by-case basis, to ensure an efficient use of land in sustainable locations.

Object

Representation ID: 4969

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.

Object

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.

Object

Representation ID: 5095

Received: 19/12/2022

Respondent: Barberry

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy or in an Annex to the main document. This should be made available before the plan is submitted for examination.

Support

Representation ID: 5133

Received: 13/12/2022

Respondent: Seven Homes

Agent: RCA Regeneration

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy.

Object

Representation ID: 5146

Received: 19/12/2022

Respondent: St Philips

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy or in an Annex to the main document. This should be made available before the plan is submitted for examination.

Support

Representation ID: 5158

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy.

Object

Representation ID: 5182

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Adopt a more flexible approach. High quality equipped play provision may not be required where such provision already exists in the locality. It is not appropriate to require open space on all sites to be centrally located, this does not take account of specific site characteristics/constraints.

Green Infrastructure provision should be based on quality rather than quantity. The exclusion of small incidental Green Infrastructure such as landscape buffers is not supported. Policy should be revisited and clarified with reference to national guidance to ensure that open space and green infrastructure is properly and clearly defined and to recognise the contribution which a range of spaces will bring to a development.

Comment

Representation ID: 5243

Received: 21/12/2022

Respondent: Richborough Estates

Agent: RCA Regeneration Ltd

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy.

Comment

Representation ID: 5255

Received: 21/12/2022

Respondent: CCB Investments

Agent: RCA Regeneration

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy.

Object

Representation ID: 5309

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not fully justified as currently drafted and should be amended as suggested.

The policy should acknowledge that the type of open space provision, including formal play equipment, should be considered on a site by site basis and take account of on-site circumstances and existing provision in the wider area (for example, play equipment may not work within the wider open space strategy on an individual site and may not be required if there is an existing play area nearby).

Object

Representation ID: 5321

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

No principle objection, some clarifications required.

Object

Representation ID: 5343

Received: 19/12/2022

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst there is no in principle objection to the requirements of the policy or the provision of open space within developments, some clarifications are required in order to ensure that the Policy is sound.
The policy requirement for on-site equipped play provision as default is not supported as it will not be appropriate for every site, for example where there is already high-quality equipped play provision in the locality it would not make sense to duplicate this provision.
In addition, it is not appropriate to require open space to be centrally located on all sites as this does not take into consideration differences in development sites opportunities and constraints. It is requested that the Council amend the policy to allow a more flexible
approach to achieve the right design solution for each site.
The focus of Green Infrastructure provision should be based on quality rather than quantity or ‘useability’ and the exclusion of small incidental green infrastructure (GI) without a clear recreational purpose from on-site open space provision is not supported. The policy text
cites landscape buffers as an example of incidental GI which may be excluded. This is not appropriate as landscape buffers can be of a significant size and clearly make a contribution towards open space provision on a site. They should therefore be included in these calculations. Planning Practice Guidance acknowledges that 'Green infrastructure can embrace a range of spaces and assets that provide environmental and wider benefits.
The policy should therefore be revisited and clarified, with clear reference to national guidance ensure that open space and green infrastructure is properly and clearly defined and to recognise the contribution that a range of spaces and uses will bring to a development.
The policy as drafted is unsound as it is inconsistent with national policy and is unjustified for the reasons set out above.