Question 11
Object
Preferred Options November 2021
Representation ID: 1392
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Pegasus Group
HC1 - housing mix better determined on site by site basis considering market demand. Policy should comment that requirement is subject to viability assessment. Definition of major development should reflect DMPO HC4 -policy does not define older person. Not clear if requirement for 10% bungalows will continue. Evidence needed to justify M4(2) building regs, as level proposed does not seem supported by the evidence and it would not be appropriate to require M4(2) and bungalows. HC9 - requirement for tree lined streets should only be in locations supported by the highways authority. HC11 - requirement for NDSS is not supported or justified by teh SHMA. If pursued then there should be some flexibility in this policy where only some fall below the requirement. HC12 - cost assumption for EV charging should be increased. HC17 - requirement for on site play as default is not supported, or is the requirement for open space to be centrally located, nor is the exclusion of incidental green space from the requirement. Clarification sought on whether attenuation basins are incidental. HC18 - policy should define sports standards expected and considered through the IDP and viability assessment. EC3 - requirement for Employment and Skills Plan not supported as TWs business model relies on sub contracting. NB6 - repetition of 2021 Building Regs Part L interim uplift is unnecessary and should be removed.
Support
Preferred Options November 2021
Representation ID: 1393
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Pegasus Group
HC7 - approach generally supported, but policy should include mechanism for plots to come forward as market housing where lack of demand. HC9 - supports requirement for a requirements for high quality design. HC12 - continuation of existing parking standards supported. HC14- objective of ensuring impact of development does not have impact on health infrastructure is supported but engagement with CCG required. HC15 -approach to education supported but engagement with education authority required. EC9 - policy approach to infrastructure generally supported but engagement with the relevant providers is needed. EC10 - approach supported but detailed list of infrastructure requirements needed in Reg 19 plan. NB6 -policy supported but would need to confirm the threshold to which developments would be expected to submit an energy statement.
Object
Preferred Options November 2021
Representation ID: 1415
Received: 13/12/2021
Respondent: CWC Group - Clowes Developments
Agent: Savills
Do not support all of the proposed policy approaches set out in chapter 6. Further comments below:
HC1 - Housing Mix
Any figures for housing mixes should be quoted
in supporting text only, and not within the policy. The findings of the latest SHMA should be consider as indicative only, and housing mix considered on a site-by-site basis.
HC3 - Affordable Housing
We disagree with the proposed requirement for 50% of the affordable housing to be delivered in the
form of social rent. Paragraph 8.11 of the SHMA, clearly sets out a 50% requirement of the affordable housing provision to be both affordable rented and social rented. A distinction needs to be made between affordable and social rent, and this should be reflected in the policy.
HC9 - Design requirement
Disagree with the proposed requirement of Policy HC9 for all developments to incorporate tree lined streets. The wording should be that tree lined streets should be provided, unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate.
HC13 - Health and Wellbeing
To ensure that this requirement is not unduly onerous the Council should be clear what the basis of this requirement.
NB2 – Biodiversity
Until this requirement is formally enacted through secondary legislation, the chosen target would need to
be appropriately evidenced.
NB6
Any requirements above the Building Regulation standard would need to be robustly justified.
Support
Preferred Options November 2021
Representation ID: 1416
Received: 13/12/2021
Respondent: CWC Group - Clowes Developments
Agent: Savills
HC7 - Self & Custom Build Housing
In general, we support the Council’s approach to self & custom build housing. As set out in our responses to previous consultation stages, we do not support self and custom build housing being required on allocated sites as a proportion of overall housing requirement.
C17 - Open Space
In relation to policy HC17, the consultation document propose to make it clear that small incidental
green infrastructure will not be counted towards on-site open space. This may be justified, but the Council should not overlook the benefits of such areas if appropriately planted and maintained can have for biodiversity.
EC10 - Developer contributions
Any contribution requests should be open to negotiation and based on CIL reg 122 (2) tests.
NB1 - Protecting, enhancing and expanding natural assets
There should be a clear hierarchy of land that the Council will consider for such uses. Land in the ownership of a willing landowner should be considered before other land where ownership issues are unresolved.
Object
Preferred Options November 2021
Representation ID: 1429
Received: 13/12/2021
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.
EC1 – Policy should refer to potential additional growth to support strategic employment sites, such as Auto-Aero and Agri-Tech.
EC9 – Opportunities to utilise rail freight facility infrastructure should be progressed.
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.
Object
Preferred Options November 2021
Representation ID: 1446
Received: 13/12/2021
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.
Object
Preferred Options November 2021
Representation ID: 1450
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy HC1 – Housing Mix
Do not support applying a blanket requirement across the
District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site, it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals. Additionally, we also request that when determining housing mix for a site, consideration is given to the size of properties.
Policy HC2 – Housing Density
Do not support a blanket approach to density being taken. Housing density should be determined on a site by site basis and consideration should be given to site context and its accessibility.
Policy HC3 – Affordable Housing
Object to the proposed requirement for 50% of the affordable housing to be delivered in the form of social
rent. A distinction needs to be made between
affordable and social rent, and this should be reflected in the policy.
Policy HC4 – Homes for Older People
Any proposed standards in the Local Plan Review will need to accord with the requirements of the NPPF and
PPG and ensure that they do not negatively impact on the viability of a site. We consider that the policy should
be worded flexibly and allow proposals to be determined on a site by site basis
Object
Preferred Options November 2021
Representation ID: 1451
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy HC9 – Design Requirements
We consider that the policy should be worded as set out in the NPPF. We consider that input should be had by developers to ensure that the design codes are market facing and deliverable.
Policy HC11 – Space about dwellings and internal space standards
The Council should provide justification on the requirement to meet the NDSS and provide further information on the potential impact on viability.
Policy HC12 – Parking Standards
Across the plan period, it is likely that electric vehicles and supporting infrastructure are likely to change /
advance therefore this policy should allow for flexibility.
Policy HC14 – Health Infrastructure
We do not consider that contributions should be sought from health providers for any allocations within the plan as they will be known developments.
Policy HC17 - Open Space
There is no justification as to why the open space needs to be ‘centrally located’.No definition of what constitutes ‘small’ is provided nor how applicants can demonstrate that it serves a purpose. Further clarity is sought on this matter as landscape buffers identified as ‘semi natural / natural open space’ can play an important role in connecting green infrastructure and pedestrian links.
Object
Preferred Options November 2021
Representation ID: 1454
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy NB1
As stated in our response to Policy HC9, we consider that any reference to tree lined streets should be compliant with the NPPF.
Policy NB4 - Landscape Character
We do not consider that Category C or U trees should be afforded any specific protection within the policy
Policy NB6
This requirement should therefore be monitored throughout the plan-making period and only included
within the plan if the Building Regulations are update.
Support
Preferred Options November 2021
Representation ID: 1455
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy HC7 – Self & Custom Build Housing
We support the proposed wording within this policy in relation to determining the provision of self-build and
custom plots as part of major developments on a site by site basis.
Policy HC15 – Education
As part of any proposed development of site 500, financial contributions could be provided towards the provision of the new primary school.
Policy NB2 – Biodiversity
We consider that the Council should also allow the Applicant to offer off-site land too, particularly if it is in the same landownership and / or in close proximity to the application site
Policy NB10 - Canal Network
We support measures to integrate the canal network into the wider Green Infrastructure network through biodiversity net gain.
Object
Preferred Options November 2021
Representation ID: 1466
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy HC1 – Housing Mix
Do not support applying a blanket requirement across the
District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site, it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals. Additionally, we also request that when determining housing mix for a site, consideration is given to the size of properties.
Policy HC2 – Housing Density
Do not support a blanket approach to density being taken. Housing density should be determined on a site by site basis and consideration should be given to site context and its accessibility.
Policy HC3 – Affordable Housing
Object to the proposed requirement for 50% of the affordable housing to be delivered in the form of social
rent. A distinction needs to be made between
affordable and social rent, and this should be reflected in the policy.
Policy HC4 – Homes for Older People
Any proposed standards in the Local Plan Review will need to accord with the requirements of the NPPF and
PPG and ensure that they do not negatively impact on the viability of a site. We consider that the policy should
be worded flexibly and allow proposals to be determined on a site by site basis
Object
Preferred Options November 2021
Representation ID: 1468
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy HC9 – Design Requirements
We consider that the policy should be worded as set out in the NPPF. We consider that input should be had by developers to ensure that the design codes are market facing and deliverable.
Policy HC11 – Space about dwellings and internal space standards
The Council should provide justification on the requirement to meet the NDSS and provide further information on the potential impact on viability.
Policy HC12 – Parking Standards
Across the plan period, it is likely that electric vehicles and supporting infrastructure are likely to change /
advance therefore this policy should allow for flexibility.
Policy HC14 – Health Infrastructure
We do not consider that contributions should be sought from health providers for any allocations within the plan as they will be known developments.
Policy HC17 - Open Space
There is no justification as to why the open space needs to be ‘centrally located’. No definition of what constitutes ‘small’ is provided nor how applicants can demonstrate that it serves a purpose. Further clarity is sought on this matter as landscape buffers identified as ‘semi natural / natural open space’ can play an important role in connecting green infrastructure and pedestrian links.
Object
Preferred Options November 2021
Representation ID: 1470
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy EC6 - Retail
We do not support the findings of the RSFA and the identification of Kinver as just a ‘village centre’ rather than a ‘large village centre’ given the significant range of shops, services and facilities provided in the village.
Policy NB1
As stated in our response to Policy HC9, we consider that any reference to tree lined streets should be compliant with the NPPF.
Policy NB4 - Landscape Character
We do not consider that Category C or U trees should be afforded any specific protection within the policy
Policy NB6
This requirement should therefore be monitored throughout the plan-making period and only included
within the plan if the Building Regulations are updated.
Support
Preferred Options November 2021
Representation ID: 1471
Received: 13/12/2021
Respondent: Barratt West Midlands
Agent: Savills
Policy NB2 – Biodiversity
We consider that the Council should also allow the Applicant to offer off-site land too, particularly if it is in the same landownership and / or in close proximity to the application site
Policy HC7 – Self & Custom Build Housing
We support the proposed wording within this policy in relation to determining the provision of self-build and
custom plots as part of major developments on a site by site basis.
Object
Preferred Options November 2021
Representation ID: 1514
Received: 10/12/2021
Respondent: Amadis Holdings Ltd
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
Preferred Options November 2021
Representation ID: 1571
Received: 13/12/2021
Respondent: Mr Nigel Babb
HC1 – 80% of properties on major development.
HC2, the 35 dph minimum should be extended. There are ways of doing this without going to high-rise. The council’s current 21% norm is wasteful of greenbelt.
HC3, Given that developers are being given the privilege of building on agricultural land they should provide a higher proportion of social rent homes. Starter homes are only affordable for the first buyer.
Support
Preferred Options November 2021
Representation ID: 1582
Received: 13/12/2021
Respondent: Bellway Homes Limited (Hyde Lane site)
Agent: Turley
Policy HC1 (housing mix) – we have no objection to any housing mix reflecting that in the latest Housing Market Assessment. Any policy should however allow for some flexibility in the mix.
Policy HC17 (open space) – whilst there is no objection in principle to open space being provided centrally, the policy should allow some flexibility if the design rationale for a site justifies locating it elsewhere.
Object
Preferred Options November 2021
Representation ID: 1583
Received: 13/12/2021
Respondent: Bellway Homes Limited (Hyde Lane site)
Agent: Turley
Policy HC2 (housing density) – as set out in our representations to the Preferred Options consultation, whilst seeking for new development to achieve 35 dwellings per hectare, any policy should include sufficient flexibility as when determining factors specific to each site at the
development management stage
Object
Preferred Options November 2021
Representation ID: 1600
Received: 13/12/2021
Respondent: Trebor Developments
Agent: Avison Young
Policy HC11 - the Council should provide evidence of justifiable need for application of Nationally Described Internal Space Standards to all new housing developments in the District.
Policies HC14, HC15 and HC18 should make specific reference to CIL Regulation 122 tests for planning obligations to ensure all requests for financial contributions are lawful and comply with national policy.
Policy HC17 should 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 financial contribution.
Support
Preferred Options November 2021
Representation ID: 1602
Received: 13/12/2021
Respondent: Rigby Estates LLP
Number of people: 2
Agent: Frank Whittle Partnership Limited
No outright objections or issues with any of the policies at this stage, reserve rights to make further comments once the intended policy wording is confirmed.
Support
Preferred Options November 2021
Representation ID: 1611
Received: 06/01/2022
Respondent: Four Ashes Road LTD
Agent: Miss Rebecca Allen
FAR Ltd agree with the proposed policy approaches set out in Chapter 6 and do not anticipate any changes are needed.
Support
Preferred Options November 2021
Representation ID: 1634
Received: 13/12/2021
Respondent: Jaguar Land Rover UK
Agent: WSP
Yes.
The draft Local Plan’s proposed direction of travel for sustainable economic growth includes continued support for the delivery of strategic employment sites, including the i54 site.
Agree with supporting text stating that alternative uses must not prejudice continued operation and viability of existing/allocated employment areas.
Jaguar Land Rover supports this and considers it important to ensure additional development of the i54 site does not undermine existing businesses and their prospects. Therefore, Jaguar Land Rover also supports the proposed direction of focusing growth at the currently identified employment areas but considers it significant to ensure that it is economic growth and employment land.
Object
Preferred Options November 2021
Representation ID: 1642
Received: 13/12/2021
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.
Object
Preferred Options November 2021
Representation ID: 1643
Received: 13/12/2021
Respondent: Bradford Estates
Agent: Berrys
Policy HC6:
Fails to meet the need for both affordable and open market housing arising in Tier 5 settlements, thus failing to maintain and enhancing the vitality and of communities and services in these settlements. This is in conflict with NPPF Paragraph 79. Current pandemic has highlighted demand for countryside dwellings. Approach should be amended to enable the provision of small-scale open market housing development on sites within or adjacent to built form of Tier 5 settlements.
Policy EC4:
Approach fails to recognise many rural employment and tourism developments are appropriately located outside of development boundaries. NPPF Paragraph 85 states that policies should recognise that sites to meet local needs in rural areas may have to be found outside existing settlements that are not well served by public transport. Proposed policy approach fails to meet employment and tourism needs in Tier 5 settlements - in conflict with NPPF Paragraph 79. Policy should be amended to enable provision of rural employment and tourism developments within or adjacent to Tier 5 settlements.
Rural Building Conversion Policy should be added to enable the conversion of rural buildings to dwellings in line with PD Rights facilitating conversion of rural buildings to employment and residential use.
"Whole Estate Plans" Policy should be added to identify criteria that would need to be provided for the Council to endorse a Whole Estate Plan as a material consideration in determining relevant planning applications.
Object
Preferred Options November 2021
Representation ID: 1653
Received: 13/12/2021
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.
Object
Preferred Options November 2021
Representation ID: 1682
Received: 13/12/2021
Respondent: Mr J Barnes
Site 582 Langley Road - No.
EQ1 and EQ3 are of particular concern as a resident of Radford Lane. You cannot simply disregard natural assets in the vicinity. There are plenty of empty properties and the data shows that these houses are not needed.
Object
Preferred Options November 2021
Representation ID: 1691
Received: 13/12/2021
Respondent: Mrs Vicky Barnes
Site 582 Langley Road - No.
EQ1 and EQ3 are of particular concern as a resident of Radford Lane. You cannot simply disregard natural assets in the vicinity. There are plenty of empty properties and the data shows that these houses are not needed.
Object
Preferred Options November 2021
Representation ID: 1704
Received: 14/03/2022
Respondent: Taylor Wimpey UK Ltd
Agent: Pegasus Group
HC1 - housing mix better determined on site by site basis considering market demand. Policy should comment that requirement is subject to viability assessment. Definition of major development should reflect DMPO HC4 -policy does not define older person. Not clear if requirement for 10% bungalows will continue. Evidence needed to justify M4(2) building regs, as level proposed does not seem supported by the evidence and it would not be appropriate to require M4(2) and bungalows. HC9 - requirement for tree lined streets should only be in locations supported by the highways authority. HC11 - requirement for NDSS is not supported or justified by teh SHMA. If pursued then there should be some flexibility in this policy where only some fall below the requirement. HC12 - cost assumption for EV charging should be increased. HC17 - requirement for on site play as default is not supported, or is the requirement for open space to be centrally located, nor is the exclusion of incidental green space from the requirement. Clarification sought on whether attenuation basins are incidental. HC18 - policy should define sports standards expected and considered through the IDP and viability assessment. EC3 - requirement for Employment and Skills Plan not supported as TWs business model relies on sub contracting. NB6 - repetition of 2021 Building Regs Part L interim uplift is unnecessary and should be removed.
Support
Preferred Options November 2021
Representation ID: 1705
Received: 14/03/2022
Respondent: Taylor Wimpey UK Ltd
Agent: Pegasus Group
HC7 - approach generally supported, but policy should include mechanism for plots to come forward as market housing where lack of demand. HC9 - supports requirement for a requirements for high quality design. HC12 - continuation of existing parking standards supported. HC14- objective of ensuring impact of development does not have impact on health infrastructure is supported but engagement with CCG required. HC15 -approach to education supported but engagement with education authority required. EC9 - policy approach to infrastructure generally supported but engagement with the relevant providers is needed. EC10 - approach supported but detailed list of infrastructure requirements needed in Reg 19 plan. NB6 -policy supported but would need to confirm the threshold to which developments would be expected to submit an energy statement.
Object
Preferred Options November 2021
Representation ID: 1714
Received: 13/12/2021
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.
EC1 – Impact of growth at strategic employment sites and ability of Featherstone housing growth to support delivery should be acknowledged
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.