Publication Plan April 2024

Comment

Representation ID: 7140

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Whilst important that consideration is given to the potential requirement for a species mitigation licence, this should be identified within the supporting text or the Natural Environment and Biodiversity SPD for information purposes only. The requirement should be deleted from NB1. The provisions are reliant upon Natural England responding in relation to an initial licence application which is considered onerous and unnecessary given NE are not required to grant at this stage. To require this input ‘upfront’ has the potential to unnecessarily slow the submission of applications.

Object

Representation ID: 7141

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In referring to best and most versatile agricultural land, the policy sets out that it will be protected and enhanced. The NPPF recognises the economic benefits for agricultural land which should be considered in the over planning balance alongside the provision of homes. The policy should be amended to accurately reflect national policy. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7142

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Persimmon Homes are supportive of the need to address net losses to biodiversity. Given the 10% BNG is a mandatory requirement for all developments, the detailed provisions in NB2 are considered unnecessary and a duplication of national policy requirements. The policy should be simplified with clauses A-C deleted so as to avoid potential misinterpretation within the wording. The Natural Environment and Biodiversity SPD should expand upon the requirements but not seek any additional policy provisions.

Comment

Representation ID: 7143

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Amendment to the policy to read ‘all trees, woodland and hedgerows should be protected and retained wherever possible’. Despite the protection of trees and hedgerows wherever possible, some loss of trees and hedgerows is likely to be inevitable to accommodate vehicular access.

Object

Representation ID: 7144

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Although a move towards delivering greater energy efficiency is supported, it is important that the Development Plan’s response to climate change is realistic and consistent with national legislation and policy provisions. The recent Ministerial Statement was clear that Local Plans should not be placing onerous requirements on developers which exceed the requirements of national Building Regulations. The Local Plan is not supported by robust evidence to support this approach. There is the risk of making various assumptions without vigorously testing against the specifics of the revised policy and the potential cost implications for proposed developments. The policy conflicts with Government advice and should be deleted.

Comment

Representation ID: 7145

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Clause A7 – there are issues of data protection and consent surrounding the recording and sharing of data with a third party and/or the reliance on the cooperation of private home-owners to share data in order to meet with the requirements of any monitoring condition associated with the policy. There is no evidence that the Council have considered or addressed the GDPR implications of this requirement, it is not practical to be delivered in the form proposed and is therefore considered unsound.

Comment

Representation ID: 7146

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Persimmon Homes fully appreciates the value of Whole Life-Cycle Carbon Assessments and the need for some post construction, pre-occupation assessment. There remains concerns over the inclusion of the policy, in particular when read alongside paragraph 13.15. Clause C2 is considered unnecessary with Building Regulations providing the basis on which the construction of buildings should adhere to. There should be no expectation placed on housebuilders to exceed national standards which have already been through vigorous viability testing.

Comment

Representation ID: 7147

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Clause C3 – the SPD should do no more than clarify the Local Plan policy. The requirement for an Energy Statement is referenced only within the supporting text, if deemed necessary to deliver the requirements of NB6C it should be explicitly set out within the policy itself. The policy is unsound as it is neither justified not consistent with national policy.

Support

Representation ID: 7148

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

A vision document for ‘Land at Cherrybrook Drive’ is contained within Appendix 1. Details regarding Penkridge and its services can be found in paragraphs 5.3 – 5.7 of the full representation. The Cherrybrook Drive site is capable of early development in the first five years of the plan and will complement the larger, strategic scale allocations within the plan. The following information can be found in the full representation - history of the site (paragraphs 5.10 – 5.14), sustainable connectivity (paragraphs 5.15 – 5.20), technical assessment (paragraphs 5.21 – 5.22), landscape and visual impact (paragraphs 5.23 – 5.24), traffic and transport (paragraphs 5.25 – 5.27), heritage matters (paragraph 5.28), ecology and biodiversity (paragraph 5.29), flood risk and drainage (paragraph 5.30 – 5.31), noise (paragraph 5.32), air quality (paragraph 5.33).