Publication Plan April 2024

Comment

Representation ID: 7064

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The policy should be clear that in having regard to the Council’s self-build register, it is only Part 1 of the register which needs to be considered. The policy should also recognise that delivery of self-build housing on new residential sites successfully occurs when there is a distinct phasing or grouping of plots secured for such delivery. Whilst Clowes generally supports the concept of self-build housing, they do not consider providing them as part of a larger housing development is the most appropriate solution.

Comment

Representation ID: 7065

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

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 provision of bespoke house types is onerous and unrealistic for commercial housebuilders who work with a portfolio of house types, the reference to ‘bespoke homes’ is unjustified and should be amended to refer to a ‘range of house types’. The policy is currently unsound.

Comment

Representation ID: 7066

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The continuity of existing external space and dwelling standards is generally supported. The introduction of the optional NDSS to all new homes should accord with the provisions of the NPPF. IT should still allow for flexibility when a different solution might be required. This needs to be referenced in the policy wording.

Comment

Representation ID: 7067

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

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. The requirement for CIL Reg compliance of any request should be clearly specified, especially in view of recent appeal decisions. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7068

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Clowes 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: 7069

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

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). The provision of open space under HC17 will place further constraints on development and questions the ability to deliver sufficient homes across the Plan period.

Comment

Representation ID: 7070

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

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: 7071

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

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. 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 requirements of delivering sports facilities and playing pitches through on-site provision or S106 contributions is only one element of the package that sites will need to provide and the Council must ensure the delivery of all potential obligations are taken into account.

Object

Representation ID: 7072

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? No

EC1 identifies 6 strategic employment sites. However, Hilton Cross is now largely developed and the WMI is designed for regional/national requirements and is unlikely to meet the needs of local businesses. Land at i54 is largely taken, with the remaining allocations based around Wolverhampton. Clowes considers that SSDC, due to its locational relationship with the Black Country, need to allocate a balanced amount of employment sites. Further land needs to be developed and the policy should be amended to make it clear that over development opportunities are being brought forward to meet the needs of the Black Country overspill which has not been met.

Object

Representation ID: 7073

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Clowes considers that there is an over-reliance on WMI. The development is intended to serve regional/national companies, and whilst such a provision is welcome, will not meet the needs of local businesses. The Plan does not meet the DtC by failing to meet the needs of other authorities who have a functional and economic relationship with South Staffordshire.