Question 11

Object

Representation ID: 847

Received: 13/12/2021

Respondent: Mr Richard Williams

Inappropriate

Support

Representation ID: 885

Received: 13/12/2021

Respondent: Cannock Chase Council

Support the general direction of travel for Policy NB3 – Cannock Chase SAC and Policy NB10 – Canal Network. Would wish potential impacts and opportunities of the proximity of the Cannock Extension Canal SAC and SSSI, including any impacts upon the protected habitats from increased road traffic emissions to be considered. Opportunities should be taken to improve and connect to the existing infrastructure and the existing network of canal towpath and public footpaths/bridleways in the area and around Grove colliery, Little Wyrley

Object

Representation ID: 891

Received: 10/12/2021

Respondent: Bilbrook Parish Council

The more specific policies including design, need more quantification and weight.

Object

Representation ID: 923

Received: 22/12/2021

Respondent: Natural England

HC13 - reference the positive impacts on health from the natural environment.
HC17 - Are designated sites/local wildlife sites affected by recreation or water quality impacts. Can these be mitigated through creation/enhancement of green/blue infrastructure. Avoid building on open space of public value. Make provision for appropriate quantity and quality of Green Space to meet identified need. Ensure protection and enhancement of PRoW & national trails - seek to provide linkages. Reference contribution to health and well-being.
HC19 - set out clear strategy for delivery of Green Infrastructure - targets, standards, requirements, opportunity areas. Plan should identify deficiencies and opportunities for new green infrastructure.
EC8 - HRA has noted growth could lead to potential likely significant air quality impacts.
EC11 - Assessment of potential air quality impacts on European designated sites is needed.
NB1 - Include European designated sites and reference to green/blue infrastructure. Include within the policy the hierarchy of designated sites in line with NPPF. Soils & Agricultural land not adequately in lie with NPPF; should be valued as a finite resource. Decisions should take full account of impact on soils
NB2 - Approach should be compliant with mitigation hierarchy (NPPF 175). Biodiversity net gain not to be applied to irreplaceable assets. Net gain should be additional to mitigation/compensation habitat creation. Need to highlight how losses and gains will be measured and how net gain will be delivered and managed. On-site provision preferred. Possible linkages with other objectives such as Green Infrastructure.
NB3 - Mitigation must be fully secured. Consider a separate policy for air quality impacts on European designated sites.
NB4 - Reference AONB and the aim of conserving and enhancing character. Reference AONB Design Guide & Management Plan. New Development to minimise and mitigate visual impacts in character areas & landscape setting. Visual should include light pollution. Noise pollution should be included. Areas of tranquility should be identified and protected.
NB5/NB6 - Recognise the role of natural environment to deliver measures to reduce climate change effects. Avoid exacerbating climate change and protect resilience of the natural environment. Promote the role of Green Infrastructure and ecological networks in aiding climate change adaptation - expand tree cover; restore/create priority habitats; retrofit green/blue infrastructure. Suggest set ambitious target for reducing emissions; protect and restore peatland; increase tree and woodland cover; identify nature based solutions and protect sites vulnerable to climate change. Actions should be integrated into strategic approach alongside Green Infrastructure, health and well being, biodiversity net gain, natural flood management, air and water quality.
NB7 - Consider the strategic impacts on water quality and resources (NPPF 170), address flood risk management (155-165). River Basin Management Plans should inform development proposals. Policy should protect habitats from water related impacts and seeks enhancements. Positively contribute to reducing flood risk using natural processes, Green Infrastructure and SUDs.

Support

Representation ID: 924

Received: 22/12/2021

Respondent: Natural England

HC17 - Welcome policy direction. Opportunity to engage and create green and blue infrastructure and to link with geology and heritage assets, provide climate change adaption and improve ecological connectivity.
HC19 - Support inclusion of this policy.
EC1 - Welcome the inclusion of multifunctional green spaces and enhancement of the Green Infrastructure network.
NB1 - Support the policy direction.
NB2 - Support this policy.
NB3 - Support policy direction.
NB5/NB6 - Support policy direction.
NB10 - Support measures to integrate canal network into green infrastructure network.

Object

Representation ID: 926

Received: 10/12/2021

Respondent: Codsall Parish Council

Where the dph is proposed at 35 to ensure that the rural character and the edge of new settlements has a softer transition into the open countryside, these should be accompanied by a design brief that loosens the urban grain towards the edge and provides that softer transition through natural landscaping.

Object

Representation ID: 940

Received: 13/12/2021

Respondent: Essington Parish Council

Relating to Policy HC15 and school infrastructure, there are concerns about the adequacy of school provision on the Linthouse Lane site. Concerns about the extent to which some of the EC policies rely on encouragement rather than instruction. Not clear from EC11 how the implementation of new walking and cycling routes will happen. The approach to climate change is too weak when accounting for the long-term impacts on climate change of such unsustainable development patterns.

Support

Representation ID: 960

Received: 01/02/2022

Respondent: Highways England

Welcome the commitment to sustainable transport and active travel set out in Policy HC19 and Policy EC11, but further detail will be required as these are developed further.

Object

Representation ID: 965

Received: 13/12/2021

Respondent: Gavin Williamson CBE MP

Concerns with Policy HC8 - I believe that this policy should be far stronger and more explicit about the enforcement measures that the council will take upon non-compliance with its stated planning policy for Gypsy and Traveller sites. Concerns with Policy EC2 - I do not agree with the policy’s inclusion of the phrase that there should be a ‘strong presumption in favour of retaining strategic employment sites for employment uses.’ Rather, I believe that the council should have sufficient flexibility to ensure they can adapt to substantial changes in the planning landscape and deliver on all the employment and housing needs of residents.

Support

Representation ID: 971

Received: 01/02/2022

Respondent: Ministry of Defence

Some renewable energy development (e.g. wind turbines and solar photovoltaic panels) can impact upon military aviation. Planning guidance advises LPAs to consult the MoD where turbines have a proposed tip height of or exceeding 11m or a rotor diameter of 2m or more.

Object

Representation ID: 979

Received: 01/12/2021

Respondent: Kinver Parish Council

Need a clear policy on windfall allowance and maximum build densities. Should develop climate change initiatives to contribute to economic growth via e.g. retrofit or renewable energy projects.

Support

Representation ID: 984

Received: 12/11/2021

Respondent: National Grid C/O Avison Young

To ensure future Design Policies are consistent with national policy we would request the inclusion of a policy strand such as:
“x. taking a comprehensive and co-ordinated approach to development including respecting existing
site constraints including utilities situated within sites.”

Support

Representation ID: 986

Received: 10/12/2021

Respondent: Severn Trent Water

Support the council’s views around the urgency of climate change and acknowledge the commitment to green infrastructure (Policy HC19) as a toolset towards mitigating the impact.The plan could go along way in its aspiration for development to contribute towards flood risk reduction by limiting any new connections of surface water made to the combined sewerage system through careful allocation and/or planning policy. Another mechanism could be an ask that development discharges its surface water at a flow rate lower than current greenfield runoff rates

Object

Representation ID: 1008

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy HC1 - wording not sufficiently clear or flexible. Not clear if applications need to strictly accord with the SHMA. Requirement for 75% of homes to be less than 4 beds not flexible enough as evidence/viability may justify a different mix. Policy HC2 - blanket approach to density unlikely to be effective. Policy HC3 - term 'major residential development' should be defined. Policy should allow for clusters of 6-8 dwellings on medium sized sites. Reference to not supporting grant funding for Affordable housing coming through S106 should be removed. Policy HC4 - not clear if this policy requiring 10% bungalows. Not clear how the 30% requirement for M4(2) is evidenced/justified. Not appropriate to require 10% bungalows and M4(2). HC11 -requirement that all homes meet NDSS not supported as not currently evidenced/justified. If introduced will need to be some flexibility in the policy. Policy HC17 - the default requirement for on site play or the requirement for centrally located open space on all sites is not supported. The exclusion of small incidental green infrastructure (GI) without a clear recreational purpose from on-site open space provision is not supported. Policy HC18 - sports facilities standards should be defined in the policy itself.

Support

Representation ID: 1010

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy HC7 -approach of agreeing self build on a site by site basis having regard to the register, with greater emphasis on strategic sites, is supported; however should allow for plots to come forward for market housing if there is a lack of demand (after 12 months of marketing). Policy HC9 - aspiration of improving design requirements is supported, but requirement for on street trees will needs to be subject to agreement from the highways authority. Policy HC11 - continuing existing approach to external space standards generally supported, but properties built to M4(2) may require smaller gardens. Policy HC12 - approach to parking standards supported. Policy HC14 - approach on health infrastructure generally supported. Policy HC15 - approach to education infrastructure generally supported.Policy EC9 - policy on infrastructure broadly supported. Policy NB3 - approach to Cannock Chase SAC and mitigation measures should be informed by emerging evidence. The aspirations of this policy to reduce carbon emissions is generally
supported. Policy NB6 - should set out threshold at which developments are required to submit an energy statement.

Object

Representation ID: 1028

Received: 10/12/2021

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Policy HC1 - policy should be worded with more clarity to allow for flexibility in its application, especially in respect to town center settings. Housing mix should guided by market signals. Approach of 75% of properties being less than 4 beds itoo restrictive. Policy should comment that all is subject to viability assessment. Policy HC3 - 'major residential development' needs defining. Unsure if grant funding is a matter for the Local Plan to consider. Policy HC4 - no definition of 'older people' provided, clarity needed.Policy HC6 - need to work with both the PC and a housing needs enabler should not be an ‘and’ but should be an ‘or’. Helpful if allowance for market housing on non-Green Belt RES was clarified. Policy HC9 - provision of tree lined streets should be subject to highways agreement. Policy HC14 - policy fails to define what impact is deemed unacceptable, the policy should imply that new development should meet CIL regulation tests. Policy EC11 - should reflect requirement for EV charging points. Policy NB2 - should reflect Environment Act. Policy NB3 - Not supported - questions as to whether this Policy is sufficient to meet the statutory duty to protect the SAC. NB6 - unclear where 31% reduction target has come from.

Object

Representation ID: 1030

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

HC1 Housing Mix
Gladman are concerned that the direction of travel for Policy H1 is overly prescriptive, in seeking to achieve 75% of market housing to have 3 bedrooms or less. Further flexibility is required in the final wording of policy H1.

Support

Representation ID: 1031

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

HC3 Affordable Housing
Gladman can confirm that its allocation at Land at Weeping Cross (036c) can deliver the emerging policy requirement of 30% affordable homes, or the adopted policy at the time any future planning application is determined.

Support

Representation ID: 1032

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

HC4 Homes for Older People
Gladman contend that Policy HC4 should consider the nature and scale of provision for older people on a site-by-site basis depending on demand in a particular area and site suitability. There should not be a blanket requirement across all major residential development schemes. The supporting text to Policy H4 should also contain further guidance on the types of provision that would meet this policy requirement.

Support

Representation ID: 1033

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

HC7 Self and Custom Build Housing
Gladman would broadly support the inclusion of a policy in respect of self-build and custom-build housing in line with current government thinking and objectives. Gladman recommend that the final policy wording also states that once a self-build and/or custom-build plot has been marketed for 12 months but failed to be sold, it
will revert to consideration by the Council to be built out as conventional market housing.

Support

Representation ID: 1034

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

HC9 Design Requirements
Gladman are broadly supportive of the direction of travel for policy H9. Nonetheless, the final policy wording for H9 should not be overly prescriptive and should also
reflect that, whilst it is important, good design should be considered at the most appropriate stage of the planning process (the detailed application stage) to avoid
unnecessary delay on matters of detail at the outline stage.

Support

Representation ID: 1035

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

NB2 Biodiversity
Gladman would support a development management policy which aligns with the Governments proposals within the Environment Bill 2019-2021. However, Gladman suggests the Council should not look to set a requirement over and
above the 10% biodiversity net gain that the Government is seeking to legislate,

Support

Representation ID: 1036

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman are supportive of the current Local Plan Review allocation, and consider that the allocation of the site for a minimum of 180 dwellings would best reflect the evidence-based constraints and opportunities of the site and the wider area, and its capacity to absorb growth. Gladman can confirm that the site can deliver the emerging policy requirement of 30% affordable homes, or the adopted policy at the time any future planning application is determined.

Support

Representation ID: 1037

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Gladman is committed to contributing towards providing solutions to address Climate Change, Energy efficiency, Open Space and Green Infrastructure. Gladman suggest
the Land at Weeping Cross can deliver numerous
environmental commitments to assist the Council in meeting its climate related strategies.

Support

Representation ID: 1039

Received: 13/12/2021

Respondent: Gladman

Agent: Gladman

Highways and Sustainable Transport
Gladman recognise the benefits from the connectivity to Stafford Town and the suburb of Weeping Cross, and the wide range of local amenities and facilities which can be accessed on foot, by cycle or by public transport.

Support

Representation ID: 1040

Received: 10/12/2021

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The Policy requirement to comply NDSS is generally supported but some flexibility must be allowed in its application. Policy NB10 - policy supported

Object

Representation ID: 1044

Received: 13/12/2021

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Policy HC1: level of prescriptiveness may turn out to be counter-productive. No justification for all development to have mixture of property sizes, types and tenures - smaller schemes or specialist development more suitable to singular type/tenure. Onset of Covid-19 justifies larger percentage of large properties to accommodate home-working. Flexibility in the interpretation of the requirement for affordable housing to conform to Housing Market Assessment depending upon prevailing economic circumstances.
Policy HC2: proposes relatively high density for suburban/rural district. Density should be determined to reflect local circumstances with no 'target' or 'limit'.
Policy HC3: level of AH provision should reflect local circumstances and viability studies and should be negotiated from this.
Policy HC7: Do not agree with proposed approach - allocation of a number of smaller scale self-build sites should be preferred over quotas of plots upon allocated sites where self-build doesn't fit with management, security and timescales.
Policy HC9: policy needs to be applied flexibly to ensure scope for variety and avoid mediocrity.

Support

Representation ID: 1054

Received: 08/02/2022

Respondent: Staffordshire County Council

- P49: HC4: consideration of 2 storey units and aspirational design should be considered to encourage older persons to move.
- P49: HC5: policy leans towards older persons accommodation and doesn’t address wider population needs (disabilities across all ages)
- P27: HC9 - 2018 Design Guide should be updated to reflect cycling requirements (LTN1/20)
- P27 & P48/9: HC13 & HC19 - may require Green Infrastructure SPD and Health and Wellbeing SPD to give further detail on addressing physical inactivity/obesity, providing opportunities for local food growing/allotments and to give detailed guidance on specific design interventions to benefit health.
- P27/28: EC1 – Policy needs to make mention to public transport access to employment land. HGV parking should be included as an example of necessary infrastructure in Policy EC1.
- P28/29: EC9 – Suggest Staffordshire Freight Strategy 2019 is referred to in key evidence and that options for provision of facilities for HGV parking considered and identified in the next Local Plan iteration.
- P29: EC11 – policy needs to identified Staffordshire’s Bus Service Improvement Plan, Brinsford Parkway SOBC and Integrated Transport Strategy in key evidence
- P54: NB5 – should clarify if whole District is suitable for on-shore wind subject to criteira. Should give further detail on what constitutes very special circumstances for Green Belt projects.
- P53: NB7 – support policy and reference to SuDS Handbook, which should be carried into final policy.
- P54: Additional policy is required to ensure development is catered for by gigabit-capable connectivity

Support

Representation ID: 1071

Received: 08/02/2022

Respondent: Cannock Chase AONB

Policy HC9 - Would welcome signposting to the AONB Design Guide in relation to proposed development within the AONB.
Policy NB1 - The AONB would welcome reference to protecting and enhancing the Cannock Chase AONB as habitats and wildlife comprise and intrinsic part of natural beauty. The Policy should seek to maximise opportunities to reduce and mitigate for potential pressure from additional footfall in the AONB as a result of nearby housing development.

Object

Representation ID: 1073

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

Policy HC1 - policy should be worded with more clarity to allow for flexibility in its application. Policy HC3 - 'major residential development' needs defining. Unsure if grant funding is a matter for the Local Plan to consider. Policy needs to ensure evidence is provided when considering viability. Policy HC9 - provision of tree lined streets should be subject to highways agreement.