Question 11

Object

Representation ID: 1726

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

Representation ID: 1745

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.

Support

Representation ID: 1749

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips has reviewed the emerging policy directions set out in Chapter 6 and in general support, the Council’s proposed approach to the policies set out in Chapter 6. However, St Philips have the following comments on the below specific policies.

Policy HC1 – Housing Mix
St Philips has some concerns regarding the Council’s proposed direction of travel and in particular the implied inflexibility in the policy. The policy should include wording that defers to alternative mixes should more up-to-date information become available. It would be inflexible and unsuitable to prescriptively apply a District-wide housing mix to all parts of the District when different areas will have differing requirements and demographic
profiles.
Households occupy market housing more in line with their wealth and age than the number of people which they contain. Although some adjustments have been made, this data is not necessarily reflective of South Staffordshire’s market. Adjustments need to take into account the impact of Covid and people wanting more space to live and work from home.

In summary, whilst St Philips would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically-derived District-wide housing mix.

Support

Representation ID: 1750

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC7 - Self & Custom Build Housing

In general, St Philips supports the proposed direction of travel for draft Policy HC7 as it would align with the requirement set out in the NPPF. St Philips consider that the Council’s policy should explicitly set out the evidence against which applicants should establish whether there is an ‘identified need’. In particular, St Philips notes that the Council does not publish annually any data on the
level of demand for SCHB, or how it has met its statutory duty to grant suitable permissions for the SCHB plots within the monitoring year.

Support

Representation ID: 1751

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC11 - Space about dwellings and internal space standards
St Philips supports the need to ensure improved housing standards are delivered by requiring developments to meet Nationally Described Space Standards [NDSS]. As such, St Philips support the principle of the direction of travel for draft Policy HC11.
St Philips would advise the Council that, should the Council wish to proceed with a policy approach that requires the delivery of dwellings to the NDSS.

Policy HC12 - Parking Standards
Largely supportive of the policy. However, St Philips disagrees with the Council’s proposed direction of travel for residential dwellings proposed as a part of draft Policy
HC12. In particular, St Philips considers that the Council should acknowledge the diversity of different charging speeds depending on the type of vehicle and type of charge point. St Philips considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is in place would allow for the proportional expansion of the charging network

Support

Representation ID: 1765

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips has reviewed the emerging policy directions set out in Chapter 6 and in general support, the Council’s proposed approach to the policies set out in Chapter 6. However, St Philips have the following comments on the below specific policies.

Policy HC1 – Housing Mix
St Philips has some concerns regarding the Council’s proposed direction of travel and in particular the implied inflexibility in the policy. The policy should include wording that defers to alternative mixes should more up-to-date information become available. It would be inflexible and unsuitable to prescriptively apply a District-wide housing mix to all parts of the District when different areas will have differing requirements and demographic
profiles.
Households occupy market housing more in line with their wealth and age than the number of people which they contain. Although some adjustments have been made, this data is not necessarily reflective of South Staffordshire’s market. Adjustments need to take into account the impact of Covid and people wanting more space to live and work from home.

In summary, whilst St Philips would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically-derived District-wide housing mix.

Support

Representation ID: 1766

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC7 - Self & Custom Build Housing

In general, St Philips supports the proposed direction of travel for draft Policy HC7 as it would align with the requirement set out in the NPPF. St Philips consider that the Council’s policy should explicitly set out the evidence against which applicants should establish whether there is an ‘identified need’. In particular, St Philips notes that the Council does not publish annually any data on the
level of demand for SCHB, or how it has met its statutory duty to grant suitable permissions for the SCHB plots within the monitoring year.

Support

Representation ID: 1767

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC11 - Space about dwellings and internal space standards
St Philips supports the need to ensure improved housing standards are delivered by requiring developments to meet Nationally Described Space Standards [NDSS]. As such, St Philips support the principle of the direction of travel for draft Policy HC11.
St Philips would advise the Council that, should the Council wish to proceed with a policy approach that requires the delivery of dwellings to the NDSS.

Policy HC12 - Parking Standards
Largely supportive of the policy. However, St Philips disagrees with the Council’s proposed direction of travel for residential dwellings proposed as a part of draft Policy
HC12. In particular, St Philips considers that the Council should acknowledge the diversity of different charging speeds depending on the type of vehicle and type of charge point. St Philips considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is in place would allow for the proportional expansion of the charging network

Object

Representation ID: 1777

Received: 13/12/2021

Respondent: St Philips

HC1 – Have concerns with inflexibility of policy. Market and affordable mixes by dwelling size should be included in policy and should reflect more up-to-date information where available. The approach isn’t flexible to respond to needs of different sub areas.
HC7 – Support the flexible approach adopted in the policy. Policy should explicitly set out evidence against which it would determine an ‘identified need’ to exist. The Council should publish annual data on level of demand and how it has met its statutory duty to provide suitable plots and reflect these in the draft policy.
HC11 – Support the principle of NDSS but only if the Council provides a local assessment evidencing the case for NDSS in accordance with the NPPF/PPG.
HC12 – Disagree with the proposed parking standards. Given the variety in future chargers and the need for flexibility the priority should be for the relevant cabling to be installed, not specific chargers.

Support

Representation ID: 1792

Received: 13/12/2021

Respondent: WM Housing Associations

Agent: Tetlow King Planning

HC1 - Support
HC2 - Support. A minimum density requirement should also be set for other areas to ensure an adequate supply of housing
HC3 - Support for 30% affordable housing, must be rigorously viability tested. Council should request affordable housing contributions or on site provision on smaller schemes where viable. Smaller sites for 100% affordable housing should be considered. Shared ownership should continue to be supported. Clusters of 10-15 affordable units on larger sites. Support for SPD to be adopted.
HC6 - Support for policy but more flexible approach to demonstrating local need, should accept housing register and government data returns as evidence.
NB2 - Support, but this should not prejudice affordable housing delivery. Guidance should be provided on how biodiversity net gain can be achieved in development. Does not need to be higher than 10% due to potential impacts on viability.

Object

Representation ID: 1793

Received: 13/12/2021

Respondent: WM Housing Associations

Agent: Tetlow King Planning

HC11 - No published evidence which shows the Council's need for adopting NDSS, policy is incompatible with national planning guidance.

Support

Representation ID: 1794

Received: 13/12/2021

Respondent: McCarthy Stone

Agent: Planning Issues

HC5 – Support for dedicated policy. Wording should acknowledge need and stipulate circumstances in which Council will support delivery of housing suitable to be adapted to the elderly. See Bassetlaw Policy ST31.
HC13 –The role of specialist older persons housing in improving health and wellbeing should be acknowledged in wording of policy. Suggested clause provided.
NB6 – Requirements of policy in terms of carbon emission reductions are aligned with those of government. Question why a bespoke energy efficiency target is required – should be aligned with emerging targets of Government being delivered through Building Regulations Part L and F.

Object

Representation ID: 1795

Received: 13/12/2021

Respondent: McCarthy Stone

Agent: Planning Issues

HC3 – Local Plan Viability Assessment has not been published. Have not ascertained whether policies are deliverable and scrutiny of assessment is limited if only available at Regulation 19 consultation. This could undermine soundness of the Plan. Council should reconsult on Regulation 18 Local Plan with Viability Assessment made available for comment. Specialist older persons’ housing typologies should be robustly assessed.
HC17 – Imposing generic design standards on specialist accommodation is problematic. Occupiers of retirement living apartments need less outdoor space. Indoor amenity space is valued more than outdoor space. Requirements of policy substantially exceed needs of residents of older persons housing. Appeal decisions support this. Specialist housing should be exempt from this policy requirement, should be determined on case by case basis. Level of amenity of all housing developments near town or district centres should be determined on case-by-case basis to allow for most efficient use of land.

Support

Representation ID: 1796

Received: 13/12/2021

Respondent: Churchill Retirement Living

Agent: Planning Issues

HC5 – Support for dedicated policy. Wording should acknowledge need and stipulate circumstances in which Council will support delivery of housing suitable to be adapted to the elderly. See Bassetlaw Policy ST31.
HC13 –The role of specialist older persons housing in improving health and wellbeing should be acknowledged in wording of policy. Suggested clause provided.
NB6 – Requirements of policy in terms of carbon emission reductions are aligned with those of government. Question why a bespoke energy efficiency target is required – should be aligned with emerging targets of Government being delivered through Building Regulations Part L and F.

Object

Representation ID: 1797

Received: 13/12/2021

Respondent: Churchill Retirement Living

Agent: Planning Issues

HC3 – Local Plan Viability Assessment has not been published. Have not ascertained whether policies are deliverable and scrutiny of assessment is limited if only available at Regulation 19 consultation. This could undermine soundness of the Plan. Council should reconsult on Regulation 18 Local Plan with Viability Assessment made available for comment. Specialist older persons’ housing typologies should be robustly assessed.
HC17 – Imposing generic design standards on specialist accommodation is problematic. Occupiers of retirement living apartments need less outdoor space. Indoor amenity space is valued more than outdoor space. Requirements of policy substantially exceed needs of residents of older persons housing. Appeal decisions support this. Specialist housing should be exempt from this policy requirement, should be determined on case by case basis. Level of amenity of all housing developments near town or district centres should be determined on case-by-case basis to allow for most efficient use of land.

Support

Representation ID: 1835

Received: 10/12/2021

Respondent: Wollaston Properties Ltd

Agent: First City Limited

In regards to policy HC1: Housing mix, understanding the need to provide a greater number of 2- and 3-bedroom properties, however, it is also important to note that each
development should be assessed on a case by case basis with the merits of each proposal taken into consideration. Also, there is the requirement for the key
considerations and characteristics of the site and the area/settlement in which the development is to take place to be considered. Therefore, consider a level of flexibility should be applied to housing mix to ensure diversity and prevent all development looking the same and lacking any distinctiveness.

In support to policy HC3: introduction of 30% affordable housing which is considered an improvement on 40% as set out in the existing adopted Local Plan.

Emphasis on the increase of 2 and 3 bedroomed properties on developments throughout the District in conjunction to the requirement for a contribution to meeting the needs of the District’s ageing population in policy HC4- Homes for Older People, important to ensure that there is a level of flexibility and diversity on sites so there is individuality and uniqueness achieved.

Object

Representation ID: 1845

Received: 13/12/2021

Respondent: Peveril Securities ltd.

Agent: Mr Simon Chadwick

Policy EC1 - should repeat the existing Core Strategy policy allowing modest extensions of strategic employment sites to be permitted subject to a robust case.

Support

Representation ID: 1861

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

St Philips has reviewed the emerging policy directions set out in Chapter 6 and in general support, the Council’s proposed approach to the policies set out in Chapter 6. However, St Philips have the following comments on the below specific policies.

Policy HC1 – Housing Mix
St Philips has some concerns regarding the Council’s proposed direction of travel and in particular the implied inflexibility in the policy. The policy should include wording that defers to alternative mixes should more up-to-date information become available. It would be inflexible and unsuitable to prescriptively apply a District-wide housing mix to all parts of the District when different areas will have differing requirements and demographic
profiles.
Households occupy market housing more in line with their wealth and age than the number of people which they contain. Although some adjustments have been made, this data is not necessarily reflective of South Staffordshire’s market. Adjustments need to take into account the impact of Covid and people wanting more space to live and work from home.

In summary, whilst St Philips would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically-derived District-wide housing mix.

Support

Representation ID: 1862

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Policy HC7 - Self & Custom Build Housing

In general, St Philips supports the proposed direction of travel for draft Policy HC7 as it would align with the requirement set out in the NPPF. St Philips consider that the Council’s policy should explicitly set out the evidence against which applicants should establish whether there is an ‘identified need’. In particular, St Philips notes that the Council does not publish annually any data on the
level of demand for SCHB, or how it has met its statutory duty to grant suitable permissions for the SCHB plots within the monitoring year.

Support

Representation ID: 1863

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Policy HC11 - Space about dwellings and internal space standards
St Philips supports the need to ensure improved housing standards are delivered by requiring developments to meet Nationally Described Space Standards [NDSS]. As such, St Philips support the principle of the direction of travel for draft Policy HC11.
St Philips would advise the Council that, should the Council wish to proceed with a policy approach that requires the delivery of dwellings to the NDSS.

Policy HC12 - Parking Standards
Largely supportive of the policy. However, St Philips disagrees with the Council’s proposed direction of travel for residential dwellings proposed as a part of draft Policy
HC12. In particular, St Philips considers that the Council should acknowledge the diversity of different charging speeds depending on the type of vehicle and type of charge point. St Philips considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is in place would allow for the proportional expansion of the charging network

Object

Representation ID: 1873

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Lack of consistency with the protection being afforded to employment sites.
Land at Hobnock Road is included within the employment land at Table 9 but is not proposed for allocation - there is uncertainty as to whether these sites are allocated as employment land.
Policy EC2 does not acknowledge the importance of allocating other employment sites that are available and deliverable during the plan period such as Land at Hobnock Road.

Support

Representation ID: 1874

Received: 10/12/2021

Respondent: Black Country Reclamation Ltd.

Agent: Carneysweeney

Policy EC2 - support the approach to protect existing designated employment sites.

Object

Representation ID: 1888

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC1 – Housing Mix
Concerns regarding the Council’s proposed direction of travel and in particular the implied inflexibility in the policy. The policy should include wording that defers to alternative mixes should more up-to-date information become available. It would be inflexible and unsuitable to prescriptively apply a District-wide housing mix to all parts of the District when different areas will have differing requirements and demographic
profiles.
Households occupy market housing more in line with their wealth and age than the number of people which they contain. Although some adjustments have been made, this data is not necessarily reflective of South Staffordshire’s market. Adjustments need to take into account the impact of Covid and people wanting more space to live and work from home.

Object

Representation ID: 1897

Received: 25/03/2022

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

Representation ID: 1899

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC2 – Housing Density
It is not clear what the density expectations would be
for allocations on the edge of existing settlements (such as the proposed allocation at Pool House Road Wombourne). Taylor Wimpey would therefore request that clarification is
provided on this matter.

Support

Representation ID: 1905

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC4 – Homes for Older People
Taylor Wimpey generally supports the provision of homes that are suitable to meet the needs of older people in principle. However, we consider that any requirement for
more specialist types of accommodation such as sheltered or extra care accommodation would best be addressed through the identification of specific allocations to meet this need.

Object

Representation ID: 1906

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC7 - Self & Custom Build Housing
Consider that the Council’s policy should explicitly set out the evidence against which applicants should establish whether there is an ‘identified need’. In particular, the Council does not publish annually any data on the level of demand for SCHB, or how it has met its statutory duty to grant suitable permissions for the SCHB plots within the monitoring year. We also note that this policy requirement does not appear to have been properly considered in the Local Plan Viability Assessment.
Taylor Wimpey therefore considers that the policy requirement for major residential development to have regard to any need identified on the self-build and custom housebuilding register, with provision to be agreed on a site-by-site basis, should be deleted and the Council
should identify stand-alone sites which are specifically allocated to meet the local demand for self and custom build dwellings.

Support

Representation ID: 1907

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC9 – Design Requirement
If local design codes are to be prepared, Taylor Wimpey would suggest that they are prepared alongside the emerging Local Plan rather than following adoption, so that the viability implications of their requirements can be properly assessed through the Local Plan process.

Object

Representation ID: 1908

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC11 – Space About Dwellings and Internal Space
Standards
Taylor Wimpey objects to Policy HC11.
Taylor Wimpey notes that the Government’s decision to make these standards optional suggests that they do not expect all properties to be built in accordance with them.
With regard these criteria, we firstly note that no need evidence is provided in the SSLP and there appear to be nothing in the evidence base to justify the policy requirement.
An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice.
Taylor Wimpey considers that additional evidence needs to be provided if the Council wishes to proceed with this policy approach. If the Council is able to provide
sufficient evidence to justify the policy, Taylor Wimpey considers that a transitional period should be applied.

Object

Representation ID: 1909

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HC12 – Parking Standards
Questionable whether this Policy is required and whether
it should be introduced as it may not align with national requirements.
The costs applied in the Viability Assessment are too low.