Publication Plan April 2024

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Comment

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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

Representation Summary:

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.

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