Publication Plan April 2024

Support

Representation ID: 6203

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

The approach of locating development in the most sustainable locations is consistent with national policy.The allocation of land for the delivery of housing in Kinver is clearly sound and would contribute towards meeting identified housing needs in a sustainable location.

Notwithstanding the above, the wording of the final sentence of Policy DS5 is inconsistent with Section 38(6) of the Planning and Compulsory Purchase Act 2004 (as amended) and Paragraph 11 of the NPPF (i.e. the presumption in favour of sustainable development) and should be deleted.

Support

Representation ID: 6204

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Crest fully supports the allocation of the land south of White Hill, Kinver for housing development. The site was identified as suitable through the 2018 SAD DPD and is necessary for the Council to be able to demonstrate compliance with paragraph 146 of the NPPF. The site is deliverable, available now, suitable and achievable. The site has good access to nearby facilities and is served by a bus stop located within 200m. highways work demonstrates that the site can deliver the proposed allocation without unacceptable impacts on the local road network. ALC report confirms land is Grades 3b and 4 and the site will deliver a number of benefits including market and affordable housing in a range of sizes and types as well as a considerable number of other benefits.

Object

Representation ID: 6205

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy states that major housing development sites “must” include a minimum of 70% of properties with 3 bedrooms or less. Policy HC1, as worded, is inflexible and could impact on the delivery of much needed homes. Policy HC1 should, therefore, be amended to state that major developments “should” provide a minimum of 70% of properties with three bedrooms or less, unless an alternative housing mix can be justified by other more up to date evidence of need, for example, evidence of current market demand and more up to date local needs assessments.

The section of Policy HC1 which states that development which fails to make efficient use of land by providing a ‘disproportionate’ amount of large 4+ bed houses is ambiguous (i.e. it is unclear how a decision maker should react to development proposals and what might be considered disproportionate). This section of Policy HC1 should, therefore, be deleted.

Object

Representation ID: 6206

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

It is unclear whether the requirement for a minimum density of 35dph applies to allocated sites adjoining non-Tier 1 settlements. this is unlikely to be appropriate and the policy should be amended to allow greater flexibility

The draft Policy appears to set a single minimum density for the majority of housing developments planned to come forward across the District. Having regard to NPPF para 128 this is unlikely to be appropriate and the policy should be amended to allow greater flexibility to reflect a range of other factors including market, viability, accessibility and character.

Object

Representation ID: 6207

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Whilst it is anticipated that 30% affordable housing would be viable at Crest’s site in Kinver, a ‘blanket’ requirement for 30% would not appear to be justified having regard to the Council’s own evidence, nor be consistent with the NPPF.

Object

Representation ID: 6208

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy HC4 is vague, it is unclear how it would be applied by a decision-maker in the consideration of individual applications for planning permission. This fails to comply with part d) of paragraph 16 of the NPPF and requires clarification to avoid situations where the ambiguity in policy leads to delays in delivery of much needed homes.

Crest is not convinced that a requirement for 100% of dwellings to comply with M4(2) standards is justified having regard to national policy and guidance.

Object

Representation ID: 6209

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

It may be appropriate for a policy to encourage self and custom-build development on housing sites. However, it is not considered appropriate to require major developments to provide for self-builders.This element of the policy is unsound and should be deleted.

Object

Representation ID: 6210

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The proposed wording of this policy appears to seek to give the guidance in the South Staffordshire Design Guide SPD and other guidance documents the same weight as Development Plan Policy. This is clearly inappropriate as the NPPF confirms that whilst supplementary planning documents are capable of being a material consideration in planning decisions, they “are not part of the development plan”. The wording of HC10 should be amended accordingly.

Object

Representation ID: 6211

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

NPPG requires evidence to justify use of the Nationally Described Space Standards. The Internal Space Standards Topic Paper (2024). It does not provide any evidence of the need for NDSS to apply in the Borough and the reasons why houses in the Borough need to be bigger. There is also a risk that an inflexible approach to the adoption of NDSS could have the unintended consequence of impacting on affordability.This element of the policy is unjustified and unsound and should be deleted.

Object

Representation ID: 6212

Received: 29/05/2024

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Appendix H sets out a requirement for 1 fast EV charge socket per house with on plot parking and 1 fast EV charge socket per for flats and apartments with allocated and unallocated spaces. Crest supports the provision of electric vehicle charging points, in principle, but believes that the references to EV charging in Appendix H of the Local Plan should be deleted. This is because Part S of the Building Regulations now set out the national requirements for the provision of EV charging infrastructure in new developments. There is no need to repeat these and no justification to go beyond the national requirements set out in Building Regulations.