Publication Plan April 2024

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Support

Publication Plan April 2024

Policy EC8: Retail

Representation ID: 6043

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

Policy (EC8) is supported, there are some good public health links made. Suggest that consideration be given to whether there is any scope for developing the retail policy further to include an approach that considers older people, for example, provision of rest spaces and public toilets etc.

In relation to hot food takeaways we’d consider the possible inclusion of a further consideration in relation to health impact particularly in areas where obesity is and issue? This could be strengthened by reference obesity data for the district, which we can supply.

Support

Publication Plan April 2024

Policy HC1: Housing Mix

Representation ID: 6044

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

The Plan has good coverage in relation to Health and Well-being in general, which is acknowledged.

The data shows that the District has an increasingly ageing population. This is referred to well across the document and the Plan seeks to address it with proposals for specialist elderly housing, and with references to accessible and adaptable homes. However, given the demographics this we believe this could have gone further. For example, using the homes for life idea there is scope for development of housing for all, where people are able to grow old with minor adaptations. Homes for life – Guide to accessible homes | Centre for Ageing Better (ageing-better.org.uk)

Change suggested by respondent:

Using the homes for life idea there is scope for development of housing for all, where people are able to grow old with minor adaptations. Homes for life – Guide to accessible homes | Centre for Ageing Better (ageing-better.org.uk)

Support

Publication Plan April 2024

Policy HC4: Homes for older people and others with special housing requirements

Representation ID: 6045

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

The Plan has good coverage in relation to Health and Well-being in general, which is acknowledged.

The data shows that the District has an increasingly ageing population. This is referred to well across the document and the Plan seeks to address it with proposals for specialist elderly housing, and with references to accessible and adaptable homes. However, given the demographics this we believe this could have gone further. For example, using the homes for life idea there is scope for development of housing for all, where people are able to grow old with minor adaptations. Homes for life – Guide to accessible homes | Centre for Ageing Better (ageing-better.org.uk)

Change suggested by respondent:

Using the homes for life idea there is scope for development of housing for all, where people are able to grow old with minor adaptations. Homes for life – Guide to accessible homes | Centre for Ageing Better (ageing-better.org.uk)

Support

Publication Plan April 2024

Policy EC3: Employment and Skills

Representation ID: 6046

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

Fully support the principle of Policy EC3 and been working closely with colleagues at the District Council on the early implementation of the Employment and Skills Plan for the WMI development.

The employment and skills sections feature on pages 113 & 114 of the Plan. There is reference to the need to complete an employment & skills plan, and there is a brief description of the themes to feature in the ESP though a bit limited. There is also reference to a need for specific and measurable outputs to be secured through a legal agreement or planning condition.

The County has been working with District/Borough (and Stoke-on-Trent City Council) colleagues to prepare a Employment and Skills Plan Framework that will provide advice and structure on the preparation of Employment and Skills Plans associated with new development across Staffordshire. This approach was endorsed by Staffordshire District/Borough Directors earlier this year to provide consistency across the County. However, we note the Plan does not make reference to this.

Comment

Publication Plan April 2024

Policy SA2 – Strategic development location: Land North of Penkridge

Representation ID: 6047

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

Provision for the development to the North of Penkridge does not take into account or make provision for the potential development to West of Penkridge as referred to in our representation to paragraphs 5.12-5.17 and Policy DS4.

The proposals for the West of Penkridge include a spine road that would in effect become the A449 and allow the existing road through the historic centre of the village to be returned to local use and design. The new spine road is proposed to connect back to the A449 through the North of Penkridge site. Should this not be possible then further land to the north of the North of Penkridge allocation would need to be brought into the West of Penkridge proposal to facilitate the delivery of a re-routed A449.

The Masterplanning for the West of Penkridge proposal includes in scenario 4 the north of Penkridge allocation site. We suggest that the alignment of the spine road through the allocation site be protected such that is doesn’t obstruct or hinder the opportunity the West of Penkridge affords to the village.

The County Council is willing to compensate the developers’ of the North of Penkridge site for any developable land lost as result accommodating the spine road.

Change suggested by respondent:

Amend part (d) of the policy, which presently reads ‘A transport strategy which includes consideration of accesses onto the A449, a gateway feature to the village on the site's northern edge and appropriate public transport provision to support sustainable travel from the scheme;’

to

A transport strategy which includes consideration of accesses onto the A449 including details to demonstrate how accommodation of West of Penkridge spine road can be provided for by the site layout and junction arrangement/s, a gateway feature to the village on the site's northern edge and appropriate public transport provision to support sustainable travel from the scheme;

Support

Publication Plan April 2024

Policy HC15: Education

Representation ID: 6048

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

We note and support the inclusion of a specific Policy for Education and Schools in Policy HC15. We support reference in the policy to our Education Infrastructure Contributions Policy, as this sets out the methodology and mechanisms by which we work to when considering development affect education infrastructure and access to school.

Support

Publication Plan April 2024

13.1

Representation ID: 6049

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

It is encouraging to see Climate Change running through the whole Plan and setting specific asks across a number of areas in relation to climate change mitigation and adaptation.

We fully support the soundness of the Plan in relation to Climate change.

Object

Publication Plan April 2024

Policy NB8: Protection and enhancement of the historic environment and heritage assets

Representation ID: 6050

Received: 24/05/2024

Respondent: Staffordshire County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is considered that the key evidence outlined under this policy is not comprehensive enough as it is missing some key documents/studies. See below for documents/studies we believe should be included -

• Staffordshire Extensive Urban Survey (see https://www.staffordshire.gov.uk/environment/Environment-and-countryside/HistoricEnvironment/Extensive-urban-survey-project.aspx for more)
• Cannock Chase AONB Historic Environment Assessment (see https://www.staffordshire.gov.uk/Environment/Environment-and-Countryside/HistoricEnvironment/Assessments.aspx for more)
• Historic Environment Site Assessment Update 2023 (see https://www.sstaffs.gov.uk/sites/default/files/2024-04/south_staffs_hesa_add_sites_nov_2023.pdf) for more

Change suggested by respondent:

The following are also considered to be key parts of the evidence base relating to policy NB8:

• Staffordshire Extensive Urban Survey (see https://www.staffordshire.gov.uk/environment/Environment-and-countryside/HistoricEnvironment/Extensive-urban-survey-project.aspx for more)
• Cannock Chase AONB Historic Environment Assessment (see https://www.staffordshire.gov.uk/Environment/Environment-and-Countryside/HistoricEnvironment/Assessments.aspx for more)
• Historic Environment Site Assessment Update 2023 (see https://www.sstaffs.gov.uk/sites/default/files/2024-04/south_staffs_hesa_add_sites_nov_2023.pdf) for more

Comment

Publication Plan April 2024

EC12: Sustainable transport

Representation ID: 6051

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

The Plan should fully recognise that any development needs to take appropriate measures to ensure the public path network is protected and improved in order to achieve both sustainable travel and health and well-being objectives.

If any development is likely to affect the path network, either directly or indirectly, then section 106 funding and/or appropriate planning conditions should be imposed to improve the path network, through liaison with ourselves, at that time. This could also include situations where housing development is likely to lead to a rise in usage of the network in the vicinity of the development.

Developments should be encouraged to enhance the existing path network where possible in line with Staffordshire County Council’s Rights of Way Improvement Plan. This could include:
• the creation of public bridleways or the upgrading of public footpaths to bridleways to improve provision for horse riders and cyclists across Staffordshire where there is currently a shortfall in available access routes.
• the creation and promotion of short circular walks to promote the health benefits of walking.
• the replacement of stiles with gaps (where there are no stock) or gates (where there are) in line with Staffordshire County Council’s Least Restrictive Principle for path furniture.

Comment

Publication Plan April 2024

Policy NB7: Managing flood risk, Sustainable urban Drainage Systems (SuDS) & water quality

Representation ID: 6053

Received: 24/05/2024

Respondent: Staffordshire County Council

Representation Summary:

The acronym SuDS refers to Sustainable Drainage Systems- not Sustainable Urban Drainage Systems. The word ‘Urban’ should be omitted.

In Section 2 of Policy NB7: reference should be made to the Drainage Hierarchy that needs to be complied with for all new development.

New development should consider the following methods for surface water discharge in this order. Each should be considered and evidence shall be provided as to why each cannot be achieved, before moving down the hierarchy.

1. Rainwater reuse and harvesting
2. Infiltration – (soakaway-to-ground).
3. Discharge to watercourse or waterbody
4. Discharge to surface water sewer
5. Other (e.g. combined sewer or pumped system).

Also, the four pillars of SuDs should be referenced in this section.
Innovative- Blue/Green SuDs such as open basins, swales, treepits and raingardens holistically deliver the four pillars of SuDs:

1. Water Quantity (Flood Risk Management)
2. Water Quality (Pollution Control)
3. Amenity
4. Biodiverstiy.

These shall be maximally included and provisioned for in any new development, as far as possible.

Change suggested by respondent:

The word ‘Urban’ should be omitted where it is used in the term ‘Sustainable Urban Drainage Systems.’

In Section 2 include reference to the Drainage Hierarchy and that it needs to be complied with for all new development.

New development should consider the following methods for surface water discharge in this order. Each should be considered and evidence shall be provided as to why each cannot be achieved, before moving down the hierarchy.

1. Rainwater reuse and harvesting
2. Infiltration – (soakaway-to-ground).
3. Discharge to watercourse or waterbody
4. Discharge to surface water sewer
5. Other (e.g. combined sewer or pumped system).

Also, the four pillars of SuDs should be referenced in this section.
Innovative- Blue/Green SuDs such as open basins, swales, treepits and raingardens holistically deliver the four pillars of SuDs:

1. Water Quantity (Flood Risk Management)
2. Water Quality (Pollution Control)
3. Amenity
4. Biodiverstiy.

These shall be maximally included and provisioned for in any new development, as far as possible.

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