Publication Plan April 2024

Comment

Representation ID: 6977

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Despite acknowledging a higher-than-average aging population and decline in families and working age residents, SSDC does not seek to directly address this issue by prioritizing the delivery of family homes and ensuring the housing needs of the working age population are met across the Plan period. Contributing a larger proportion of homes to the HMA would assist in addressing this issue, improving affordability of homes.

Comment

Representation ID: 6978

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

DS1 is broadly in line with the relevant paragraphs in the NPPF and is therefore supported. However, Richborough do not accept the Council’s proposition that Green Belt ‘contributes towards rural character’. Green Belt is a development restraint policy set out at Chapter 13 of the NPPF and therefore the Council should amend the text in DS1 and its supporting text to represent national policy.

Comment

Representation ID: 6979

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

The Council are of the view that the Growth Study, on which the 4,000 contribution to the HMA was based, is out of date. Details on the HMA and shortfalls for other LA’s can be found in paragraphs 4.4 – 4.7 of the full representation. The Green Belt Exceptional Circumstances Topic Paper 2024 continues to acknowledge the exceptional circumstances for the release of Green Belt land, however, in terms of delivering housing for the District and HMA, this continues to focus on non-Green Belt options. Only 0.16% of the district’s Green Belt is proposed for release despite the significant unmet need for the HMA. There are clear opportunities for sustainable housing development across the district through Green Belt release whilst ensuring a significant quantum of high value Green Belt land is protected.

Comment

Representation ID: 6980

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

SSDC clearly recognise the scale of the housing shortfall. Since consultation on the 2022 Publication Plan, the housing shortfall across the HMA has grown further. SSDC’s reduced contribution of 640 homes is not reflective of the significant housing shortfall. The direct relationship between SSDC, Dudley and Wolverhampton provides further support for the release of Green Belt land.

Comment

Representation ID: 6981

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Richborough consider the 2024 Publication Plan should establish Green Belt boundaries which will not require amendment in the next Local Plan cycle through the introduction of safeguarded land. This would give the Council greater flexibility to accommodate development requirements and to assist in meeting a growing unmet need. Richborough continues to advocate the importance of a growth corridor focused around the A449 and West Coast Mainline.

Object

Representation ID: 6982

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DS1 is unsound and does not meet with the provisions of the NPPF. It has been demonstrated that there are clear exceptional circumstances for the release of Green Belt land. The delivery of 640 homes is not considered proportionate.

Comment

Representation ID: 6983

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Richborough supports the inclusion of a policy setting out the need for Green Belt compensation in relation to sites being removed from the Green Belt. However, despite representations in the 2022 Publication Plan, the policy still leaves elements of ambiguity, and its practical application is unclear.

Object

Representation ID: 6984

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The hierarchical approach to the Green Belt compensation policy as drafted is not supported. Neither the NPPF or PPG refer to a hierarchy or preferred methods of compensation. It appears that all the potential methods require some method of actually delivering the compensation. In practical terms this is likely to be via a S106 agreement associated with a planning permission to develop the allocation. Whilst it is accepted that having the Green Belt compensation close to the allocation could be advantageous, it is the overall value of that improvement which is of greatest significance. There is also potential for the lowest ranked element of the hierarchy to result in the same, or greater, benefit than compensation associated with the highest rank.

Object

Representation ID: 6985

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is considered unsound as it is neither justified nor consistent with national policy. The policy should be amended to delete the hierarchy and instead state that Green Belt compensation is required in conjunction with development of sites removed from the Green Belt.

Object

Representation ID: 6986

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Details of housing figures, contribution to the HMA and NPPF/PPG extracts can be found in paragraphs 4.26 – 4.36. The Plan provides a buffer of 10%, this has been reduced from 13% in the 2022 Publication Plan. In view of the 2024 Publication Plan reducing housing supply rather than reducing the buffer, it ought to be increasing it as there will be less supply overall and a proportionally greater impact if sites do not come forward. Richborough objects to DS4 as it is not justified based on proportionate evidence nor positively prepared in line with national policy. The minimum housing requirement figure across the Plan period should be substantially greater than that currently proposed.