Publication Plan April 2024

Comment

Representation ID: 7130

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The policy should be clear that in having regard to the Council’s self-build register, it is only Part 1 of the register which needs to be considered. The policy should also recognise that delivery of self-build housing on new residential sites successfully occurs when there is a distinct phasing or grouping of plots secured for such delivery. Persimmon Homes supports the position that should a proposed custom self-build not be sold after 12 months following marketing, then the developer will be permitted to building out the plan as a standard property type. The policy is considered unsound as it is neither justified nor consistent with national policy.

Comment

Representation ID: 7131

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The provision of tree lined streets should be subject to highway authority agreement. The point on house types and tenures is repetition of policy material set out in HC1. The provision of bespoke house types is onerous and unrealistic for commercial housebuilders who work with a portfolio of house types. The reference to ‘bespoke homes’ within the policy is unjustified, jeopardising the delivery of homes within the district. The policy is considered unsound as it is neither justified nor consistent with national policy.

Comment

Representation ID: 7132

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The requirement to comply with NDSS is generally supported. Some flexibility must be allowed in its application as occasionally a small minority of homes on larger sites may require non-compliance with NDSS for sound urban design reasons. The policy is considered unsound as it is neither justified nor consistent with national policy.

Comment

Representation ID: 7133

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The policy continues to refer to proposed development causing ‘unacceptable impact’ on existing healthcare facilities but fails to define what level of impact is deemed unacceptable or how that is to be measured. The policy should acknowledge that not all residents of a development will be new to the catchment area and may already be registered by the local healthcare provider.
Careful analysis is required with regard to the capacity of existing infrastructure to accommodate new patients, before reaching a conclusion as to what any CIL Regulation 122 compliant financial request might be. The policy is considered unsound.

Comment

Representation ID: 7134

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The policy requires further clarification to ensure that any such provision to be delivered via a S106 agreement has regard to the tests of CIL Regulations rather than referring to Staffordshire Education Infrastructure Contributions Policy. The policy should also recognise new infrastructure will be required from new development, only where it can be demonstrated that existing capacity to accommodate growth does not exist. The policy is considered unsound as it is neither justified nor consistent with national policy.

Comment

Representation ID: 7135

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Whilst there is no in principle objection to the requirements of the policy or the provision of open space within developments, some clarifications are required to make the policy sound. The requirement for on-site equipped play provision as default is not supported as it will not be appropriate for every site (e.g. duplication of high-quality equipped play). It is not appropriate to require open space to be centrally located on all sites as this does not take into consideration differences in development sites.

Comment

Representation ID: 7136

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The focus of Green Infrastructure provision should be based on quality rather than quantity. The policy text cites landscape buffers as an example of incidental GI which may be excluded – this is not appropriate as landscape buffers can be of a significant size and clearly contribute towards open space provision on site. The overly prescriptive wording of the policy should be revisited to ensure the policy takes a more flexible approach to open space provision. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7137

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The emphasis should be on establishing deficiencies in existing sports and playing pitch provision, and a requirement for any additional provision alongside the proposed development having regard to the tests of the CIL Regulations, rather than making a blanket assumption that all major developments will be required to make a contribution. The wording of the policy should be amended to ensure this is made explicit.
It is noted that further guidance will be provided in an Open Space, Sport and Recreation SPD, but no further quantitative details are provided to set out the detail of what will be expected within the Publication Plan. The Council must ensure the delivery of all potential obligations are taken into account for both on and off-site provision to support the soundness of the Plan.

Object

Representation ID: 7138

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Any assessment of cumulative impact and mitigation requested must be proportionate and CIL Regulation 122 complaint – the policy should be explicit that this is the case. The policy is unsound as it is neither justified not consistent with national policy.

Object

Representation ID: 7139

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The wording of point B should be revisited to ensure consistency with NPPF Paragraph 115. Point e is unclear and lacks clarity in the context of the policy, it is unclear why a policy relating to sustainable transport is seeking to minimise the impact of noise. The policy is unsound as it is neither justified not consistent with national policy.