Question 11

Support

Representation ID: 1075

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

Policy HC9 - the policy requirement to comply NDSS is generally supported but some flexibility must be allowed in its application.

Object

Representation ID: 1085

Received: 04/02/2022

Respondent: Environment Agency

HC19 - Design green spaces to include more semi-natural habitats.
NB1 - Habitat connectivity will be important in relation to climate change. Mention blue/green corridors.
NB6 - Commit to 110 lp/d.
NB7 - Include requirement for safeguarding land for flood risk management.
NB7 - Take account of latest climate change.
NB7 - Support naturalisation of urban watercourses.
NB7 - No development within 8m of culverted watercourses.
NB7 - Direct development to sites with lowest flooding probability.
NB7 - Seek to provide wider betterment.
NB7 - Provide Surface Water Drainage Strategies for all major developments.
HC8 - Exclude sites within Flood Zone 3. Exceptions test for Flood Zone 2.

Object

Representation ID: 1093

Received: 13/12/2021

Respondent: Lilactame Ltd

Agent: Pegasus Group

Policy EC8 –states it will maintain the existing approach set out in adopted Core Strategy Policy EV13. But proposed approach would not remove the NPPF requirement for PDL sites in the Green Belt to not have a greater impact on the openness of the Green Belt, which could inhibit development options. Proposed approach is more limited than existing policy EV14 which allows for the continued occupation of the site by existing non-aviation uses that support the viability and sustainability of the Airport where it is consistent with national policy. Airport will require a more flexible approach to non aviation employment uses to support the operation of the site as an airport. Continuing with a more restricted version of the previous policy approach in the CS will not deliver the significant investment in the site which is needed. Development offers opportunity to facilitate highways/footway improvements and potential for a Dial A Ride minibus.

Support

Representation ID: 1095

Received: 04/02/2022

Respondent: Environment Agency

NB1 & NB2 Support minimum delivery of 10% net gain.

Object

Representation ID: 1104

Received: 07/12/2021

Respondent: BSA Environmental ltd.

Agent: Advance Land & Planning Limited

BSA Environmental's property (Fishers Farm Garden Centre) and adjacent bungalow should be excluded from proposed green infrastructure proposal adjacent to Site 136.

Support

Representation ID: 1109

Received: 13/12/2021

Respondent: Mr Mark Stephens

Agent: Advance Land & Planning Limited

Generally support Policy HC17.

Object

Representation ID: 1110

Received: 13/12/2021

Respondent: Mr Mark Stephens

Agent: Advance Land & Planning Limited

Concerned with inflexibility pertaining to requirements and site context.
Policy HC17 is particularly prescriptive and doesn't consider on-site constraints. The word 'centrally' [located] should be replaced with 'appropriately' [located].
Location of open space should respect the principles of good urban design, accessibility and public surveillance etc.

Object

Representation ID: 1122

Received: 11/02/2022

Respondent: Lower Penn Parish Council

EQ1 – Green Belt removal is non-complaint with this
EQ3 – Undesignated heritage assets make site 582 non-compliant
EC11 – Policy not followed in site selection
HC14 – Health impacts not examined in any depth
HC1 – 95% of properties should be 3 bedrooms or less
HC3 – Affordable housing should be increased to 40%
HC4 – All developments should include 30% minimum older persons housing
NB5 – Battery Storage Sites and other renewable energy generation sites needed to facilitate decarbonisation should be integrated into the Local Plan
NB6 – The 31% reduction in regulated emissions will not address significant embodied carbon emissions or the performance gap in ‘as built’ dwellings. Low carbon heating systems should be built into the Local Plan.

Object

Representation ID: 1128

Received: 11/02/2022

Respondent: Wombourne Parish Council

HC1 – the proportion of 3 bedroom properties should be 90% and 40% should be affordable

Support

Representation ID: 1130

Received: 10/12/2021

Respondent: Seabridge Development Limited

Agent: Advance Land & Planning Limited

Generally support Policy HC17.

Object

Representation ID: 1131

Received: 10/12/2021

Respondent: Seabridge Development Limited

Agent: Advance Land & Planning Limited

Concerned with inflexibility pertaining to requirements and site context.
Policy HC17 is particularly prescriptive and doesn't consider on-site constraints. The word 'centrally' [located] should be replaced with 'appropriately' [located].
Location of open space should respect the principles of good urban design, accessibility and public surveillance etc.

Object

Representation ID: 1144

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be reflected on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of infrastructure and other policy requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC7 – Consider the policy direction proportionate to the level of evidence.
HC9 – Support the introduction of new requirements.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC12 –The viability assessment should use a figure of £974 per charge point to reflect Department for Transport consultation figures.
HC17 – To avoid blanket inappropriate provision, distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
HC19 – Support as part of strategic development
EC3 – Object to this, as it fails to reflect that major housebuilders business plans rely on sub contractors.
NB2 – Policy should only require net gain in line with government policy which is not yet in place.
NB3 – Emerging evidence should inform policy.
NB6 – The Council does not need to set local energy efficiency standards to achieve net zero goal because of the 2021 Part L Interim Uplift and 2025 Future Homes Standard.

Object

Representation ID: 1157

Received: 12/12/2021

Respondent: Lovell Homes

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be determined on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC7 – Consider the policy direction proportionate to the level of evidence.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC14 & 15 - Recommend engagement with the CCG and SCC Education in refining the IDP.
HC17 – To avoid blanket inappropriate provision, distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
EC3 – Question the purpose of this policy.
NB2 – Policy should only require net gain in line with government policy which is not yet in place.
NB3 – Emerging evidence should inform policy.

Object

Representation ID: 1180

Received: 12/12/2021

Respondent: Keon Homes

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be reflected on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of infrastructure and other policy requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC7 – Consider the policy direction proportionate to the level of evidence.
HC9 – Support the introduction of new requirements.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC12 –Support the proposed approach.
HC14/15 – Recommend engagement with the CCG and SCC Education to inform future IDPs.
HC17 – Distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
EC3 – Question the purpose of this policy
NB2 – Policy is noted.
NB3 – Emerging evidence should inform policy.

Object

Representation ID: 1226

Received: 13/12/2021

Respondent: Barberry

Agent: RCA Regeneration Ltd

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous .
HC11 – Suggest flexibility to indicate most development should meet NDSS
HC14 – Amend policy to clarify that development should not solve existing infrastructure problems.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1239

Received: 13/12/2021

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be reflected on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of infrastructure and other policy requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC7 – Consider the policy direction proportionate to the level of evidence.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC14/15 – Recommend engagement with the CCG and SCC Education to inform future IDPs.
HC17 – Distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
EC3 – Question the purpose of this policy
NB2 – Policy is noted.
NB3 – Emerging evidence should inform policy.

Support

Representation ID: 1247

Received: 15/02/2022

Respondent: Historic England

HC9 - Supportive of appropriate reference to historic environment within this policy. Suggest SPD to enhance advice.
Para 6.12 - supportive of sentiment in this paragraph.
Policy NB4 - support inclusion of policy relating to landscape character.
Policy NB5 - Support policy. Clarify how climate change and heritage interrelate.

Object

Representation ID: 1249

Received: 15/02/2022

Respondent: Historic England

Para 6.13 - Set out list of masterplan expectations.
EC4 - Include reference to heritage tourism.
NB1 - Welcome reference to heritage landscapes and landscape character. Unclear on meaning of 'historic parkland'.
NB9 - Rename - suggest 'Protection and enhancement of the historic environment and heritage assets'. Use hierarchical approach as set out in NPPF. Not supportive of clause supporting enabling development. Consider archaeology. Support clause supporting recording of assets as a minimum.
NB10 - Would welcome reference to heritage within the canal network policy and need to protect this asset.

Object

Representation ID: 1265

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be reflected on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of infrastructure and other policy requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC14/15 – Recommend engagement with the CCG and SCC Education to inform future IDPs
HC17 – To avoid blanket inappropriate provision, distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
EC3 – Concerns such plans will fail to reflect the business models of major housebuilders and reliance on sub contracting
NB2 – Policy should only require net gain in line with government policy which is not yet in place and should reflect government exemptions.
NB3 – Emerging evidence should inform policy.
NB6 – The Council does not need to set local energy efficiency standards to achieve net zero goal because of the 2021 Part L Interim Uplift and 2025 Future Homes Standard.

Object

Representation ID: 1274

Received: 09/12/2021

Respondent: Deborah Aulton

When planning developments, properties should be designed to help disabled people and many changes can be made at early stages of developments which could later save costs adapting properties.

Organisations should consult with an actual disabled person when planning developments with a title “disability suitable”.

All it takes is a little extra thought outside the box, if I can offer any help on advising how to make disabled access and suitability better going forward, please contact.

Object

Representation ID: 1283

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1295

Received: 13/12/2021

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Goldfinch TPS view the proposed planning policy HC1 are developed through out of date data and insufficient technical evidence.

Goldfinch express concerns into data collected pre Covid-19 for the Local Plan review which changed the economic conditions which will effect the deliverability of the Local Plan which is believes needs flexibility of policies for adjusting to Covid-19 effects on the economy and believes the existing/proposed affordable housing policy threshold should be reduced to reflect the sustainability change set of long term adverse economic conditions.

Object

Representation ID: 1300

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

HC1 - housing mix better determined on site by site basis considering market demand - policy approach is too prescriptive as drafted. HC3 - viability study supports only 20% affordable housing requirement from specialist housing provision, so the Council should consider a differentiated policy. HC4 - regarding requirement for 30% of homes to meet M4(2) building regs, the evidence base has not yet been provided to demonstrate a clear and demonstrable need for the introduction of such optional technical standards. HC11 - do not support standards for space about dwellings - does not allow for pragmatism and creative design solutions. Consider an inflexible approach to NDSS will impact on affordability and affect customer choice; currently no evidence has been prepared to support requiring NDSS. HC12 - requirement for electric charging should be removed as now required through building regs; viability study makes insufficient allowance for the cost of charging points. NB3 - if SANGs are required for Cannock Chase SAC mitigation then these need to be properly considered through the viability study. NB6 - The Council does not need to set local energy efficiency standards to achieve the shared net zero goal, because of the higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and proposals for the 2025 Future Homes Standard. A case to introduce the optional water efficiency standards has yet to be provided and South Staffordshire is an area of only moderate water stress.

Support

Representation ID: 1301

Received: 13/12/2021

Respondent: Miller Homes

Agent: Pegasus Group

HC2 - proposed approach supported. HC5 - Miller will work alongside the Council and specialist providers to deliver this specialist elderly accommodation on the allocation site at Holy Lane, should the need be confirmed through the evolving evidence base. HC7 - Support the flexible approach to self build provision. HC9 - reference to tree lined streets should reflect footnote 50 of the NPPF.

Object

Representation ID: 1319

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1331

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC14 – Policies should clarify that new development should not solve existing infrastructure issues.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1341

Received: 13/12/2021

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC14 – Policies should clarify that new development should not solve existing infrastructure issues.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1348

Received: 09/12/2021

Respondent: Seven Homes

Agent: RCA Regeneration

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC14/HC15 – Policies should clarify that new development should not solve existing infrastructure issues.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1358

Received: 10/12/2021

Respondent: Mr - Cox & Jenks

Agent: PlanIt

HC1 - do not support direction of travel for HC1. 75% of houses to be 3 bedrooms or less is too prescriptive, policy needs to more flexible.
Object to the principle of refusal of schemes with a disproportionate amount of larger homes. Disproportionate is not clear and disregards the demand for executive style housing in South Staffordshire to retain and attract higher income households.
HC11 - there is no evidence to support the proposal to meet nationally described space standards.
The imposition cannot be justified in policy terms and are not appropriate in South Staffordshire..

Object

Representation ID: 1371

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

HC1 – Is not sufficiently clear or flexible with expectations and should be subject to viability assessment. Major development should be defined using DMPO, not NPPF.
HC2 –Blanket approach is unlikely to be effective.
HC3 – Should justify why social rent (rather than affordable rent) is the preferred tenure. Registered providers do require a degree of clustering for affordable housing. Funding mechanisms for affordable housing delivery are not a planning matter.
HC4 –Unclear justification for use of M4(2) and for the proportion sought, which does not reflect SHMA.
HC7 – Smaller dedicated self/custom build sites should be identified, rather than a blanket requirement and should include flexibility if no demand.
HC9 – Tree-lined streets should only be required with highways authority agreement. Design codes should be limited to strategic sites.
HC11 – M4(2) dwellings should have smaller gardens. NDSS is only supported by the SHMA on accessible/adaptable homes, not all properties.
HC12 – Standards (including EV chargers) are supported.
HC14/15 – SSDC should engage with CCG and SCC education to ensure all likely costs are known and assessed through viability.
HC17 – On-site equipped play is not supported where existing provision exists nearby. Requirements for centrally located greenspace and exclusion of small incidental green infrastructure is not supported.
HC18 – Should define standards expected from development.
EC3 – Blanket requirement is not supported and fails to recognise the benefits of modular methods of construction.
EC9 – Engagement with providers should be taking place now.
EC10 – A detailed list of infrastructure requirements should be included in plan.
NB3 – Studies should influence policy approach
NB6 – Policy should confirm threshold for sites requiring energy statement.