Publication Plan April 2024

Support

Representation ID: 6349

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Details on the 2022 and 2024 Publication Plan Spatial Strategy can be found in the full representation (paragraphs 2.2 – 2.7).
St Philips is generally supportive of the Council’s approach whereby growth is distributed to the Borough’s most sustainable settlements and consider the spatial strategy appropriate.

Comment

Representation ID: 6350

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

St Philips welcome the intention of MA1 to ensure comprehensive development, and have no objections in principle to the preparation, general scope or intention of SMPs. It requires further clarification and amendments to ensure it is sound.
Policy states that the SMP will be approved by the Council’s Corporate Director of Place & Communities. Para 6.6 also states they would be approved through the relevant Cabinet Member and Chairman of Planning Committee. Para 6.6 should be amended to ensure the approval process in unambiguous.
The policy should be clear in stating that the provision of public open space/ GI should be driven by the relevant standards and any evidence of need / demand at the time. Clause H should be reviewed in relation to the timing and approval – it should reflect that a SMP would be submitted alongside a planning application and approved at determination.
Clause I should remove reference to ‘provably popular’ as it is unspecific terminology and focus on ensuring high-quality design.
Amendments to Para 2 and 4, Clause E, H and I detailed in the full representation.

Support

Representation ID: 6351

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

St Philips support the allocation of SA2, are in control of parcel 010 and are committed to bringing forward a comprehensive scheme for the site’s development. The site is not environmentally sensitive and is not subject to insurmountable constraints.

Comment

Representation ID: 6352

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Transport & Drainage
A Strategic Transport Assessment has been prepared in relation to the site. Development of the site is acceptable in principle subject to significant highway improvements, new junctions of the A449, and public transport provision. Proposed improvements would improve accessibility between the site and the services and facilities in the village centre and would promote active sustainable movements.

Flood Risk & Drainage
The vast majority of the site falls in flood zone 1, the eastern margins are in flood zone 3 and act as the functional floodplain for the River Penk. Vast majority of the site is at very low risk of surface water flooding. Detailed consideration has been given to the site’s drainage strategy and demonstrates that the areas of flood risk can be accommodated within the proposed country park.

Landscape & Visual Impact
St Philips do not agree with the findings of the Landscape Sensitivity Assessment (details in full representation). It did not consider the committed development to the north of Penkridge that is now being delivered and also included an area of more sensitive land to the west of the railway line, and therefore was not accurately assessed. The site is not subject to any landscape designations and does not constitute a valued landscape.

Ecology & Arboriculture
No concerns in relation to ecology or arboriculture, confirmed by assessments of the site.

Cultural Heritage & Archaeology
The Council’s Historic Environment Site Assessment confirmed the historic impact for the site has been revised to ‘low’.

Comment

Representation ID: 6353

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Concept Plans and Masterplans
St Philips support the vision of creating a sustainable extension and new neighbourhood and the vision and objectives for the development are entirely appropriate, and the Concept Plan sets out the broad principles. As set out in MA1, it is important the Council recognise that those plans only illustrate a vision. The Concept Plan has not been informed by detailed technical assessments. It is critical that Concept Plans are sufficiently flexible to allow for SMPs / detailed design scheme to depart from Concept Plans in some places.

Emerging Masterplan
Paras 2.42 – 2.46 of the full representation cover the details of the Emerging Masterplan only.

Policy Requirements
The policy sets out a number of specific requirements for the development which are largely appropriate, except the following clauses where some revisions are required to ensure the soundness of the policy (all detailed changes in Para 2.47 in the full representation). Amendments to the policy are detailed in Para 2.49 and 2.50 of the full representation.

Object

Representation ID: 6588

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree that Green Belt development should enhance access to outdoor sport and recreation, enhance landscape, visual amenity and biodiversity – as indeed many proposals within the Green Belt are capable of (including the subject site). We also agree with DS1 that where Very Special Circumstances can be demonstrated with regards to inappropriateness, planning permission should be granted. However, this is a difficult hurdle to get over and the most appropriate way to deliver large scale new housing is through a positively prepared local plan.

We do not agree that affordable housing to meet local community needs should be “limited”, considering the significant and worsening affordable housing shortage within South Staffordshire, as demonstrated by the c.1,500 households on its social housing waiting list. South Staffordshire should look to encourage as many forms of affordable housing delivery as possible, including via Rural Exception Sites.

Comment

Representation ID: 6589

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Disagree with Strategic Objective 1 in its aim to require “compensatory improvement to the environmental quality and accessibility of the remaining Green Belt”. We question how this will be mandated and what level of viability testing has been undertaken to ensure that development is not stymied due to the requirement.

Agree with Strategic Objectives 2, 3, 4, 5, 6, 7, 8 and 13.

Agree with Strategic Objective 9 and 10 However, it is also here that meeting the Duty to Cooperate is essential in identifying and delivering cross-boundary infrastructure which would facilitate unmet housing need from neighbouring authorities.

Strategic Objective 11 and 12 are laudable, however it is our view that the building regulations regime is the best way to set standards for energy performance in new buildings.

Object

Representation ID: 6590

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Despite paragraphs 147 and 148 of the latest NPPF, we disagree that Green Belt proposals must require “compensatory improvements” in order to gain planning consent. We instead agree with motion set by paragraph 57 that requires contributions to be necessary to make development acceptable in planning terms, directly related to the development and related in scale and kind.

We further question whether these further obligations have been tested within South Staffordshire’s evidence base with regards to financial viability. The cost of these compensatory improvements must be tested against existing assumptions for developer contributions, to ensure financial viability

Object

Representation ID: 6591

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The unmet need identified in paragraphs 5.9 to 5.11 attributed to the authorities in the Black Country and Birmingham have as much as 106,653 homes worth of unmet need (78,415 from Birmingham and 28,643 from the Black Country). Wolverhampton and Dudley alone account for over 12,000 homes as unmet need. It appears that South Staffordshire have all but abandoned their previous approach of meeting c4,000 units of this unmet need via the Duty to Cooperate, and since then very little has changed to warrant this new approach.

Policy DS4 should make clear that the delivery of 4,726 homes is a minimum target and should encourage sustainable development on all sites where all other development plan policies are met.

Object

Representation ID: 6592

Received: 29/05/2024

Respondent: St Philips

Agent: RCA Regeneration Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We believe that the spatial strategy should allocate potential housing sites on the urban fringes of the Black Country which already benefit from good sustainable transport links and higher order services such as surgeries, schools and shops. There are also significant employment opportunities throughout the Black Country that simply do not exist within the rural areas of South Staffordshire. We believe policy DS5 should encourage strategic development in urban fringe locations to extend existing larger settlements.