Preferred Options November 2021

Object

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.

Support

Representation ID: 1439

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. 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.

Landscape sensitivity study SL36S1 should be amended to score the area of Site 006 as ‘low-moderate’ sensitivity, as it is enclosed on three sides, is closely related to urban influences and is well contained by hedgerow field boundaries.

Support

Representation ID: 1440

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 at Boscomoor Lane, Penkridge could contribute to improvements to sports and leisure facilities, green infrastructure enhancements and health contributions.

Support

Representation ID: 1441

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. The strategic objectives are supported, particularly objective 2. Draft policies will assist in delivering these objectives.

Support

Representation ID: 1442

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: 1443

Received: 13/12/2021

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: 1444

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.

Object

Representation ID: 1445

Received: 13/12/2021

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).

Land at Boscomoor Lane Penkridge (Site 006) should also be allocated. Not allocating the site on Green Belt grounds when other Green Belt sites in less sustainable settlements does not reflect the Council’s evidence base or sustainability objectives. It is suitable and deliverable and should be allocated in addition to other sites already identified.

Object

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

Representation ID: 1635

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. 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.

Green Belt sub-parcel S46Bs2 performs less Green Belt purpose than the wider parcel (S46B). Development of S46Bs2 would not extend the built extent of Wolverhampton further into the countryside and would ‘round off’ this edge. When specific character of the sub-parcel is properly considered, the overall harm should be reduced from high to moderate. Provision of a country park would strengthen the Green Belt boundary.