Preferred Options November 2021

Support

Representation ID: 1891

Received: 25/03/2022

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 Wrottesley Park Road, Perton could contribute to improvements to sports and leisure facilities, green infrastructure enhancements and health contributions. Longstanding community concerns about the need for junction improvements are highly unlikely to be delivered by just the safeguarded land and allocation of Land off Wrottesley Park Road would provide significantly greater funding for such improvements.

Support

Representation ID: 1892

Received: 25/03/2022

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: 1893

Received: 25/03/2022

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: 1894

Received: 25/03/2022

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. A detailed technical note prepared by Hub Transport Planning Ltd demonstrates the reasons for non-allocation are not supported by evidence, which indicates that 750 dwellings could be accommodated within land to the west of Perton, and SCC do not support the District’s conclusions. A new school on site will also be provided.

Support

Representation ID: 1895

Received: 25/03/2022

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: 1896

Received: 25/03/2022

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 Wrottesley Park Road should also be allocated in addition to these proposed allocations as it is a suitable and deliverable site, once information in the representation is taken into account.

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.

Support

Representation ID: 1923

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

In general, Richborough agrees that the evidence base documents set out in the PO (Appendix A) are appropriate and necessary to underpin the emerging Local Plan Review. However, Richborough has some concerns regarding the robustness of the Council’s ‘South Staffordshire EDNA Part 1 largely due to the passage of time. The Council’s EDNA is now
markedly out of date in light of the implications of Covid 19 and Brexit. Such an approach would align with the other authorities within the FEMA such as the adjoining Cannock Chase District Council. The fact that the Council has commissioned up to date evidence on employment land needs is welcomed.

Support

Representation ID: 1924

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

In respect of the 12 Strategic Objectives that the Local Plan Review would seek to address (Pg. 24), on the face of it, Richborough does not have too many concerns with the Council’s proposed Strategic Objectives and considers that these objectives would align with the economic, social and environmental goals and ambitions of the NPPF

Object

Representation ID: 1925

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Lichfields

It is plain to see that the Local Plan Review will need to assist in meeting the unmet employment needs of its neighbouring authorities in the FEMA up to 2038 at the very least. Without the Council’s assistance in addressing this crucial matter, there is a real risk that the FEMA’s employment needs may not be fully met. Richborough considers that the Local Plan Review should identify assisting its neighbouring authorities to help them deliver
the employment land that they need as a Strategic Objective in its own right.