Publication Plan April 2024

Comment

Representation ID: 7163

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The introduction of a detailed design policy to ensure high quality design and the creation of beautiful places is supported. However, the provision of tree lined streets should be subject to highway authority agreement. The point on house types and tenures is repetition of policy material set out in HC1. The policy should be amended to remove the repetition and ensure that Staffordshire County Highways have been consulted on the proposed draft policy.

Comment

Representation ID: 7164

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The continuity of existing external space and dwelling standards is generally supported although there should be some recognition that certain house types (M4(2) dwellings) should have smaller, more manageable gardens. Taylor Wimpey suggests that some flexibility must be allowed in the application of the NDSS as occasionally, non-compliance with NDSS may be appropriate.

Object

Representation ID: 7165

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy continues to refer to proposed development causing ‘unacceptable impact’ on existing healthcare facilities but fails to define what level of impact is deemed unacceptable or how that is to be measured. The policy should acknowledge that not all residents of a development will be new to the catchment area and may already be registered by the local healthcare provider.
Careful analysis is required with regard to the capacity of existing infrastructure to accommodate new patients, before reaching a conclusion as to what any CIL Regulation 122 compliant financial request might be. The policy is considered unsound.

Comment

Representation ID: 7166

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Taylor Wimpey broadly supports the policy but it makes a blanket assumption that new education infrastructure will be required from all new development. The policy text requires further clarification as any such provision to be delivered by a S106 must have regard to the tests of CIL Regulation 122, the policy should make this explicit. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7167

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Whilst there is no in principle objection to the requirements of the policy or the provision of open space within developments, some clarifications are required to make the policy sound. The requirement for on-site equipped play provision as default is not supported as it will not be appropriate for every site (e.g. duplication of high-quality equipped play). It is not appropriate to require open space to be centrally located on all sites as this does not take into consideration differences in development sites.

Object

Representation ID: 7168

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The focus of Green Infrastructure provision should be based on quality rather than quantity. The policy text cites landscape buffers as an example of incidental GI which may be excluded – this is not appropriate as landscape buffers can be of a significant size and clearly contribute towards open space provision on site. The overly prescriptive wording of the policy should be revisited to ensure the policy takes a more flexible approach to open space provision. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7169

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The emphasis should be on establishing deficiencies in existing sports and playing pitch provision, and a requirement for any additional provision alongside the proposed development having regard to the tests of the CIL Regulations, rather than making a blanket assumption that all major developments will be required to make a contribution. The wording of the policy should be amended to ensure this is made explicit.
It is noted that further guidance will be provided in an Open Space, Sport and Recreation SPD, but no further quantitative details are provided to set out the detail of what will be expected within the Publication Plan. The Council must ensure the delivery of all potential obligations are taken into account for both on and off-site provision to support the soundness of the Plan.

Object

Representation ID: 7170

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The requirement for an Employment and Skills Plan to be prepared for all developments of 100 or more residential dwellings is not supported. Whilst the benefits of such plans are acknowledged, it is considered more appropriate to implement them on a site-by-site basis. If the policy is to be found sound it should be amended to incorporate flexibility.

Comment

Representation ID: 7171

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Any assessment of cumulative impact and mitigation requested must be proportionate and CIL Regulation 122 complaint – the policy should be explicit that this is the case. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7172

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The wording of point B should be revisited to ensure consistency with NPPF Paragraph 115. Point e is unclear and lacks clarity in the context of the policy, it is unclear why a policy relating to sustainable transport is seeking to minimise the impact of noise. The policy is unsound as it is neither justified not consistent with national policy.