Preferred Options November 2021

Object

Representation ID: 1368

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Table 8 should be included in the policy. Broadly support the policy approach in Policy DS3 but concerned that the housing target may be insufficient. The overall unmet need across the GBBCHMA is well in excess of 66,000 homes and SSDC should co-operate with other authorities within the GBBCHMA to ensure that the level of contributions made collectively is sufficient to collectively meet the shortfall. The SHMA currently fails to consider whether the minimum need figure from the standard method would support enough workforce growth to support planned job growth. Richborough Estates does not support limiting new allocations at Perton to only the safeguarded land. Featherstone could support further growth as it is located less than a mile away from a proposed strategic site (646a&b) and could support nearby employment opportunities.

Support

Representation ID: 1369

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Support policy DS4 and recognise the importance and suitability of this growth corridor as recognised in the Strategic Growth Study. Land North of the A5 falls within this area and is next to a proposal by Rodbaston College, offering an opportunity for a comprehensively planned site.

Support

Representation ID: 1370

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Support the allocation of Site 224 (44 Station Road, Codsall), Site 610 (Land off Marston Road/Fenton House Lane) and Site 582 (Land North of Langley Road).

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.

Object

Representation ID: 1423

Received: 13/12/2021

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. Concerns also raised over the age of the Economic Development Needs Assessment.

Sustainability appraisal should consider Site 585 as an employment opportunity as well as residential-led. Site 585 should not be identified as a major negative due to Green Belt, as other landscape factors have lesser scores.

Green Belt study (parcel S32Es1) is flawed as it does not recognise the recent consent of WMI or its allocation, which would fundamentally change the baseline Green Belt score.

Support

Representation ID: 1424

Received: 13/12/2021

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 North of the A5 Gailey could deliver an employment-led development benefiting from infrastructure delivered through West Midlands Interchange and provide enhanced green infrastructure.

Support

Representation ID: 1425

Received: 13/12/2021

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/best used. The strategic objectives are supported, but objective 6 should provide for employment in key locations and recognise sectors beyond advanced manufacturing, including distribution. The Strategic Objectives must also acknowledge Black Country unmet employment needs. WMI is not a threat to infrastructure as it will provide its own infrastructure.

Support

Representation ID: 1426

Received: 13/12/2021

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.

Object

Representation ID: 1427

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy contains only a single paragraph relating to housing development, based on out-of-date employment evidence. The policy should recognise the potential for additional employment land to come forward in combination with strategic employment sites like WMI, recognising the ability to use new infrastructure from that site.

Support

Representation ID: 1428

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Support policy DS4 and recognise the importance and suitability of this growth corridor as recognised in the Strategic Growth Study. Land North of the A5 falls within this area and is next to a proposal by Rodbaston College, offering an opportunity for a comprehensively planned site. The site is immediately adjacent to WMI giving an opportunity to create a sustainable new settlement maximising the use of new infrastructure and reducing the need of WMI employees to travel to work.