Preferred Options November 2021

Object

Representation ID: 1734

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Philips support the existing allocation SAD379 and the allocation of sequentially preferable brownfield site within the existing settlement boundary (Ref: 426a). However, St Philips have concerns regarding the site selection process in respect of the additional greenfield allocation at Marston Road/Fenton House Lane, particularly as this has been selected in preference to their land interests East of Ivetsey Road.

At the outset, and as set out in Section 2.0 above, it is important to note that the Council’s SHELLA has assessed the site as two separate parcels (References: 379 and 614). However, the Council should be aware that St Philips is promoting the two sites as one and has submitted a CfS Form alongside these representations to confirm the promotion of the Site in its entirety.

Object

Representation ID: 1737

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Recent judgment are clear that reasonable alternatives must be identified and assessed to provide adequate reasoning for why sites should be preferred or rejected in favour of alternative means.

Whilst the Council appears to have included a range of reasonable alternative sites in the Wheaton Aston Cluster within the SA and HSSTP, St Philips consider the methodology and assessment of individual sites to be flawed. The SA has assessed 15 sites within the Wheaton Aston Cluster for future residential led development and sets out overall scores within Section
B.26.

Whilst the sites assessed in the Wheaton Aston Cluster do score similarly overall, it should be noted that a comparison of the SA’s scoring of St Philips’ sites and the proposed allocations show that the Council’s preferred site ref: 610 performs worse than both St Philips’ sites in
terms of both climate change adaption and landscape impact. As such, it cannot be considered to be the most sustainable option for future housing allocation within the open countryside adjoining the village.

Object

Representation ID: 1746

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips strongly contends that there is an urgent need for the Council to adopt a higher housing requirement in the Local Plan Review to reflect the functional linkages
between the District and Birmingham HMA and particularly the Black Country HMA.

Support

Representation ID: 1748

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Yes. St Philips supports the Council’s proposed allocation in draft Policy SA7. It is entirely logical to rationalise the consented WMI within the emerging Local Plan Review and remove it from the Green Belt.

Support

Representation ID: 1749

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips has reviewed the emerging policy directions set out in Chapter 6 and in general support, the Council’s proposed approach to the policies set out in Chapter 6. However, St Philips have the following comments on the below specific policies.

Policy HC1 – Housing Mix
St Philips has some concerns regarding the Council’s proposed direction of travel and in particular the implied inflexibility in the policy. The policy should include wording that defers to alternative mixes should more up-to-date information become available. It would be inflexible and unsuitable to prescriptively apply a District-wide housing mix to all parts of the District when different areas will have differing requirements and demographic
profiles.
Households occupy market housing more in line with their wealth and age than the number of people which they contain. Although some adjustments have been made, this data is not necessarily reflective of South Staffordshire’s market. Adjustments need to take into account the impact of Covid and people wanting more space to live and work from home.

In summary, whilst St Philips would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically-derived District-wide housing mix.

Support

Representation ID: 1750

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC7 - Self & Custom Build Housing

In general, St Philips supports the proposed direction of travel for draft Policy HC7 as it would align with the requirement set out in the NPPF. St Philips consider that the Council’s policy should explicitly set out the evidence against which applicants should establish whether there is an ‘identified need’. In particular, St Philips notes that the Council does not publish annually any data on the
level of demand for SCHB, or how it has met its statutory duty to grant suitable permissions for the SCHB plots within the monitoring year.

Support

Representation ID: 1751

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Policy HC11 - Space about dwellings and internal space standards
St Philips supports the need to ensure improved housing standards are delivered by requiring developments to meet Nationally Described Space Standards [NDSS]. As such, St Philips support the principle of the direction of travel for draft Policy HC11.
St Philips would advise the Council that, should the Council wish to proceed with a policy approach that requires the delivery of dwellings to the NDSS.

Policy HC12 - Parking Standards
Largely supportive of the policy. However, St Philips disagrees with the Council’s proposed direction of travel for residential dwellings proposed as a part of draft Policy
HC12. In particular, St Philips considers that the Council should acknowledge the diversity of different charging speeds depending on the type of vehicle and type of charge point. St Philips considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is in place would allow for the proportional expansion of the charging network

Support

Representation ID: 1752

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(a)
Yes. St Philips agrees with the Council that the draft Policies set out in Policies DS1-DS4 and SA1-SA7 are strategic policies as defined by paragraph 21 of the NPPF.

(b)
No. St Philips do not consider that any of the draft policies set out in Chapter 6 should be identified as Strategic Policies.

Support

Representation ID: 1753

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Yes, in principle; however, St Philips has some concerns regarding the robustness of two documents within the evidence base:
The Council’s ‘South Staffordshire EDNA Part 1 (August 2018)’ (“the EDNA”) is now markedly out of date in light of the implications of Covid-19 and Brexit.
St Philips also consider that the Council’s ‘South Staffordshire Housing Market Assessment’ (“the SSHMA”)requires an update to reflect the publishing of the most recent 2020 median work-place based affordability ratios

Support

Representation ID: 1754

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips agree that the Council has set out the correct and appropriate infrastructure. However, several infrastructure improvements or new provisions required for Penkridge, several remain un-costed. In particular, no costs associated with the new education provision or country park