Preferred Options November 2021

Object

Representation ID: 1314

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

Strategic Objective 2: It is unclear how this contribution is disaggregated across the HMA. Details of agreements made under the Duty to Co-operate should be included in the evidence base.

Object

Representation ID: 1315

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

Policy DS1 repeats the Framework and could be – in part – removed. It is unclear how development in the Green Belt could maintain its character and openness.

Policy DS2 – It is unclear what forms of development would or would not be acceptable in open countryside. The policy should be revisited.

Object

Representation ID: 1316

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Wombourne is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1317

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

Policy SA2 – Delivery of the site is heavily reliant on the ‘Land at Cross Green SPD’ and there is no clear justification to demonstrate that this allocation can be implemented. As there is no clear timeline for delivery the plan should allocate further sites to ensure it can meet the 8,881 dwelling housing target.

Object

Representation ID: 1318

Received: 13/12/2021

Respondent: Richborough Estates

Agent: RCA Regeneration Limited

Allocations have been made in Wombourne but we are of the view that the evidence needs to be clearer and better explained as to why they are the sequentially preferable sites and why the omission sites were considered sequentially less preferable. Land South of Bridgnorth Road would represent a deliverable site that could provide 350 dwellings in the first five years of the plan period.

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: 1364

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

The SHELAA 2021, GBHMA Strategic Growth Study and Self and Custom Build Register should be identified as part of the evidence base. The GBHMA Strategic Growth Study is a key aspect of the evidence base informing the 4,000 home contribution to housing shortfalls and has been subject to scrutiny as part of the supporting evidence at the North Warwickshire Local Plan examination.

Sustainability appraisal should score non-Green Belt sites better than Green Belt sites by default under the landscape criteria (leading to minor negative scores).

Support

Representation ID: 1365

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Support the infrastructure-led strategy’s focus of development on larger settlements with smaller sites in smaller settlements to deliver infrastructure benefits. Land west of Fenton House Lane could contribute to improvements to sports and leisure facilities, green infrastructure enhancements and health contributions.

Support

Representation ID: 1366

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

The vision is succinct but not locally relevant and has no spatially specific elements. It seeks to ‘protect and enhance’ the District rather than considering how growth could be accommodated. The strategic objectives are supported, particularly objective 2. Draft policies will assist in delivering these objectives.

Support

Representation ID: 1367

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy DS1 is supported but should include recognition of exceptional circumstances existing to justify Green Belt release for sustainable development. No comment on Policy DS2.