Policy HC19: Green Infrastructure

Comment

Representation ID: 4085

Received: 13/12/2022

Respondent: Staffordshire Police

Public Rights of Way (PRoW) and cycle routes must be maintained to encourage the community to walk and enjoy the local environment. The PRoW should have good natural surveillance, with properties frontages overlooking the PRoW, and should not run behind residential or businesses properties. Paths should allow the users to have a clear line of sight in front of them, therefore reducing the fear of crime. Landscaping along the paths, should be dense low lying shrubs or planting. Suitable car parking provisions should be considered for those who travel to the area to enjoy the facilities.

Comment

Representation ID: 4339

Received: 23/12/2022

Respondent: The British Horse Society

Cycling and walking are mentioned in this policy although equestrians are omitted. Excluding horse riders where connections are made for walkers and cyclists will further fragment the network and disadvantage this group. Infrastructure design should seek to be inclusive to comply with the ethos of the Equality Act 2010. For maximum public benefit and fairness, new green infrastructure should be for all vulnerable road users unless there is a specific, unresolvable reason not to do so. Any newly constructed paths should be integrated/physically linked with the existing public rights of way network where possible and needed, clearly waymarked and recorded on either the definitive map or another publicly accessible map as appropriate. Equestrian activity contributes to health targets.

Comment

Representation ID: 4479

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
Bloor Homes supports the provision of multi-functional greenspace as part of strategic developments.
Again, the illustrative masterplan included at Appendix 2 demonstrates the delivery of multi-functional, interconnected, accessible green and blue spaces
as part of the comprehensive proposal for East of Bilbrook.

Comment

Representation ID: 4513

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
The sketch layout included at Appendix 1 demonstrates the delivery of multifunctional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land East of Wolverhampton Road, including the provision of new recreation space and SuDS.

Comment

Representation ID: 4541

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.

The sketch layout included at Appendix 1 demonstrates the delivery of multifunctional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land at Saredon Road, including the provision of new recreation space and SuDS.

Comment

Representation ID: 4567

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
The sketch layout included at Appendix 1 demonstrates the delivery of multifunctional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land at Landywood Lane, including the provision of a new Country Park.

Comment

Representation ID: 4595

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
Taylor Wimpey supports the provision of multi-functional greenspace as part of strategic developments.
Again, the Development Framework Plan included at Appendix 3 demonstrates the delivery of multi-functional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Cross Green.

Comment

Representation ID: 4624

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces is supported.
The illustrative masterplan included within the Promotional Document at Appendix 1 demonstrates the delivery of multi-functional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land at Four Ashes Road.

Comment

Representation ID: 4653

Received: 19/12/2022

Respondent: Woodland Trust

The plan should set standards for high-quality green infrastructure, such that everyone should be able to see three trees from their home, everyone should be no more than 300m from the nearest natural greenspace with safe and accessible routes and consideration should be given to the Woodland Trust's Access to Woodland Standard which aspires that everyone should have a small wood of at least two hectares in size within 500m of their home and a larger wood of at least 20 hectares in size within four kilometres of where they live

Comment

Representation ID: 4680

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces

Comment

Representation ID: 4720

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
The illustrative masterplan Appended demonstrates the delivery of multi-functional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land at Pool House Road, including the
provision of allotments.

Comment

Representation ID: 4892

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The policy will require that all development proposals maximise on-site green infrastructure. The aim of the policy and for the maximisation of on-site green infrastructure is to enhance biodiversity, improve connectivity to existing habitats and enhance the quality of the area for the benefit of residents.
An enhancement in the provision of green infrastructure can be achieved on both sites with buffers to the Green Belt to the north and west.
Whilst the broad themes of the policy are understood and achievable, the policy is not clear on whether this requirement will be triggered where sites are also providing compensatory green infrastructure on sites which have been taken out of the Green Belt. There is uncertainty over whether green infrastructure requirements can be combined with the compensatory measures and be provided off site. This should be
clarified within the policy or supporting text. In this regard, there is a need for the policy wording to be revised to ensure that it is unambiguous (as required by NPPF paragraph 16) so that it is evident how a decision
maker should react to development proposals.

Comment

Representation ID: 4932

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The policy will require that all development proposals maximise on-site green infrastructure. The aim of the policy and for the maximisation of on-site green infrastructure is to enhance biodiversity, improve connectivity to existing habitats and enhance the quality of the area for the benefit of residents.
An enhancement in the provision of green infrastructure can be achieved on both sites with buffers to the Green Belt to the north and west.

Object

Representation ID: 5057

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Green Infrastructure evidence being used by the Council is far too vague, provides a meaningless planning policy framework, is insufficiently robust, and fails to respond effectively to deliver requirements of green infrastructure guidance expected by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The Council is taking forward an unsound policy (based on highly questionable, vague, totally meaningless and insufficiently robust evidence) which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021).
position is perfectly clear, the Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform critically important housing-led spatial planning policy considerations across the district. The Council is taking forward an unsound policy which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021).
By encouraging destruction to sensitive wildlife corridors by promoting huge levels of new housing development immediately alongside the sensitive South Staffordshire Railway walk natural green space corridor within the Lower Penn area of the district (and other wildlife corridors in other parts of the district), the Council is failing to promote the most sustainable patterns of development, in direct conflict with the ‘Sustainability’ tests of ‘Soundness’ as reinforced in paragraph 35 (indent d) of the Revised NPPF (2021).

Object

Representation ID: 5311

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 consistent with national policy as currently drafted and should be amended as suggested.

Miller are committed to the delivery high-quality green infrastructure within their schemes. The only point we wish to reiterate from the comments on Policy HC10 above is that the reference to a requirement for all developments to incorporate tree lined street should be refined to reflect the NPPF.

Object

Representation ID: 5399

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Reference to requiring for all developments to incorporate tree lined streets should be refined to reflect NPPF.