Publication Plan April 2024

Comment

Representation ID: 6604

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

We agree with Policies HC10, HC11, HC12 & HC13, and the need to design visually attractive homes with high quality residential amenity, adequate internal space and correct parking provision.

Object

Representation ID: 6605

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree with Policies HC10, HC11, HC12 & HC13, and the need to design visually attractive homes with high quality residential amenity, adequate internal space and correct parking provision.

Comment

Representation ID: 6606

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

We agree with Policies HC10, HC11, HC12 & HC13, and the need to design visually attractive homes with high quality residential amenity, adequate internal space and correct parking provision. HC13 should however make clear at Appendix H (table 10) that the spaces requirement is a maximum

Comment

Representation ID: 6607

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Policy EC1 should recognise the positive economic impacts of housing delivery across the district and make note of the value of investment in local supply chains as well as the creation of short and long-term employment opportunities, as well as supporting apprenticeships noted in EC3. Local tax revenue associated with more households paying council tax will contribute positively towards funding local services and supporting infrastructure.

Comment

Representation ID: 6687

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

We agree with Policy NB4 with regards to landscape character, that distinct landscape features such as trees, woodland, and hedgerows must be protected and maintained

Comment

Representation ID: 6688

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

The contribution of housing development to creating renewable and low carbon energy generation should be acknowledged within policy NB5, for the introduction of technologies such as Air and Ground Source Heat Pumps, solar PVs and EV charging.

Object

Representation ID: 6689

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree with policy NB7 with regards to managing flood risk, and sustainable drainage solutions

Support

Representation ID: 6690

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

We agree that historic assets must be protected and enhanced, as policy NB8 requires.

Object

Representation ID: 6745

Received: 30/05/2024

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

The main criticisms set out in Richborough’s previous response to the 2022 PP (Appendix 3) largely hold true with this latest iteration. There is a clear need for additional employment land within the District to meet not just only the District’s own employment needs, but to assist in addressing shortfalls arising from the Black Country authorities

The calculations of need in the 2024 EDNA update is highly complex and relies on mixing and matching projections. Richborough have concerns regarding the robustness of the EDNA's employment land calculations and considers that a more aspirational approach ought to have been progressed.

The loss replacement of 12.1 ha is based on a miscalculation of the annual average of committed losses, which, if corrected, would increase the adjustment by around 8ha (to 20.1 ha).The Completions Trend scenarios significantly underplay the true scale of need by excluding a margin of choice and the substantial levels of strategic sites that have come forward in recent years. Logistics is under-represented in the modelling and the forecasting does not reflect the substantial recent growth in the sector in recent years nor the market intelligence which points to identified shortfalls in available industrial floorspace in South Staffordshire of all sizes and unprecedented demand for large logistics in this prime location. The Growth Scenario is not aspirational enough and should apply a percentage growth rate to the District-level figure. It is not the role of this EDNA to attempt to quantify how much of WMI contributes to the needs of the District. The very modest addition of 44 jobs per annum to uplift the Transport & Storage sector growth is inadequate to meet likely future growth needs and should be greater.The latest forecasting data from Cambridge Econometrics [CE] and Experian should be obtained and remodelled given the passage of time. The March 2024 Experian projections suggest that instead of a net employment growth of 3,500 between 2020 and 2041 as per the November 2021 forecasts, the District’s economy will grow by 4,900 jobs, an uplift of 40%. There is also forecast to be a much stronger growth in the Transport and Storage sector (from +100 to +700), pointing to a net increase in demand for B8 logistics sites. The EDNA's identification of 27.6 ha unmet need contribution from the current supply is unfounded. The calculation is at least partly based on past trends completions that do not include 'true' strategic take up from JLR, Amazon and Gestamp. The EDNA does not model the strategic employment land needs of the Functional Economic Market Area [FEMA] as a whole and then attempts to justify South Staffordshire's contribution. That is the remit of a wider strategic study.

Effectiveness of the Local Plan could be increased with a policy required the plan to be reviewed within 12-24 months of adoption.

Object

Representation ID: 6759

Received: 30/05/2024

Respondent: Richborough Estates

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

No objections – in principle – to the thrust of the Council’s proposed spatial strategy for employment. It is entirely logical to seek to focus additional employment growth in
well-established employment locations. However, Richborough is concerned that draft Policy DS5 as it is drafted is unsound as it does not identify or allocate sufficient employment sites to provide for objectively assessed needs and those that cannot be met within neighbouring areas (Para 11b).

Regarding the employment site promotion at Gailey Lea, Richborough is of the view that the analysis and justification provided by the Council for discounting the Site is poorly evidenced and not supported by justified evidence. There are no other ‘sequentially preferable’ strategic employment opportunities. The scale of the unmet employment needs of the FEMA is such that Green Belt release is fundamentally required to meet the longer-term strategic needs. As such, it is entirely reasonable to
release ‘high’ performing Green Belt land at Gailey Lea to address the unmet employment needs of the FEMA.

Richborough strongly contends that that there is a clear and cogent need for additional employment land within the
District to meet not just only the District’s own employment needs, but to assist in addressing the acute shortfall arising from the BCAs, and Richborough’s site should be included within the 2024 as a logical and sustainable strategic employment allocation.

Should the matter be deferred Richborough considers that the effectiveness of the LPR could be significantly increased through the provision of an additional planning policy to safeguard land for future development, via the inclusion of a Safeguarded Land policy.