Preferred Options November 2021

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: 1738

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 S51B should be reduced from moderate-high harm to low-moderate when considered against the five green belt purposes. The SA should not score site as a major negative under landscape as it isn’t in the highest category of GB/landscape harm. The SAs Climate Adaptation score should reflect the site’s ability to improve drainage on the site and improve flood risk in the wider area.

Support

Representation ID: 1739

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 off Strawmoor Lane could contribute to improvements to sports and leisure facilities, green infrastructure enhancements and health contributions.

Support

Representation ID: 1740

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: 1741

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: 1742

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: 1743

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 South Staffordshire College, offering an opportunity for a comprehensively planned site.

Support

Representation ID: 1744

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 off Strawmoor Lane, Codsall, should also be allocated as it is suitable and deliverable, subject to release from the Green Belt.

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.

Object

Representation ID: 1890

Received: 25/03/2022

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.

The Sustainability Appraisal fails to consider proposed compensatory green infrastructure (e.g. Country Parks) when assessing housing site proposals against the landscape criteria. The illustrative layout has been amended to provide a primary school, which should be reflected in the scores in the next Sustainability Appraisal under the education criteria. The site can also provide walking links to wider education facilities and should score a minor positive in terms of education.

The Green Belt Study incorrectly treats Perton as not being separate from the West Midlands conurbation and fails to take into account proposed compensatory improvements to Green Belt (country park). Detailed assessment of the parcel against the five Green Belt purposes shows the Green Belt harm should be reduced to ‘low-moderate’.

It is unclear how the site scores ‘moderate’ sensitivity in the landscape sensitivity study, given that the previous landscape sensitivity study scored it as ‘low’ and there has been an allocation on adjacent land since.