Publication Plan April 2024
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Publication Plan April 2024
Policy HC12: Space about dwellings and internal space
Representation ID: 6555
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Keon Homes has limited comment in respect of the external space standard that reflect existing policy which are generally considered appropriate. However, if bungalows are to be provided within a scheme, it would seem logical to relax garden sizes to allow for the provision of communal gardens to ensure efficient use of land.
Object
Publication Plan April 2024
Policy HC12: Space about dwellings and internal space
Representation ID: 6556
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Keon Homes do object to the internal floorspace policy requirement for all homes to meet NDSS (details provided in paragraphs 6.6 – 6.14 of full representation) It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced. NDSS requirement should be removed.
Support
Publication Plan April 2024
Policy HC13: Parking Provision
Representation ID: 6557
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Keon Homes supports the proposed parking standards contained within the Publication Plan. It is no longer necessary for the Council to have a proposed policy requirement for EVCPs as this is included in Government Regulations.
Object
Publication Plan April 2024
Policy HC17: Open Space
Representation ID: 6558
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
Accessibility standards should be established through the Local Plan to provide certainty and not displaced to supplementary guidance which is not intended to establish policy.
Comment
Publication Plan April 2024
Policy HC18: Sports Facilities and Playing Pitches
Representation ID: 6559
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Keon Homes recognises that a financial contribution to sports facilities and playing pitches may be necessary from new major development to meet needs arising from the development, but this should only apply where evidence recognises there is a shortfall in capacity to meet the generated demand from the development.
Support
Publication Plan April 2024
Policy HC19: Green Infrastructure
Representation ID: 6560
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Keon Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of inter-connected, multi-functional and accessible green and blue spaces.
Object
Publication Plan April 2024
Policy EC3: Employment and Skills
Representation ID: 6561
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Legally compliant? Not specified
Sound? Not specified
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 units is not supported by Keon Homes. It is not clear how any certainty could be provided through the provision of such a Plan. Keon Homes is a local housebuilder with a headquarters within 5km of South Staffordshire District. As such, Keon Homes already supports local employment growth.
Support
Publication Plan April 2024
EC11: Infrastructure
Representation ID: 6562
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Keon Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected settlements.
Comment
Publication Plan April 2024
Policy NB2: Biodiversity
Representation ID: 6563
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
The intention of NB2 is recognised, and any policy should require a net gain in line with latest Government legislation, policy or guidance.
Object
Publication Plan April 2024
Policy NB6A: Net zero new build residential development (operational energy)
Representation ID: 6564
Received: 31/05/2024
Respondent: Keon Homes
Agent: Evolve Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
A locally specific sustainable construction requirement is unnecessary and without justification for deviation from the Government’s Future Homes standards to be considered through building regulations. Full details on the Climate Change Study & other Regulations detailed in paragraphs 11.1 – 11.11 of the full representation.
These policies are fundamentally unsound and should be removed.