Publication Plan April 2024

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Comment

Publication Plan April 2024

1.2

Representation ID: 5695

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Representation Summary:

Satisfied that the Plan period presently meets the test of soundness. However, the plan period should be kept under review in case there is slippage to the expected timescales for plan adoption. If the Plan period does need to be extended, the Council should explore the potential for increasing the capacity of the allocated sites to address any increase in the housing requirement.

Change suggested by respondent:

Satisfied that the Plan period presently meets the test of
soundness. However, if there are delays in the adoption of the Plan then it may be necessary to extend the plan period. In that scenario, the Council should explore the potential to increase the capacity of the allocated sites to address any
increase in the housing requirement.

Comment

Publication Plan April 2024

3.15

Representation ID: 5696

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Representation Summary:

Mismatch between the pool of employment opportunities in the District and the working age population. There is also a mismatch between existing housing stock and future housing need.

'The Issues and Challenges for South Staffordshire’ section of the Plan should be re-drafted to reflect the fact that the housing and employment requirements are an opportunity for the local economy.

Object

Publication Plan April 2024

Policy DS1 – Green Belt

Representation ID: 5697

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Local Plan fails to remove land from the Green Belt and safeguard it for development in order to ensure that the Green Belt is not continually reviewed through each Local Plan review.

Policy DS1 should confirm that safeguarded land has been identified for future development to ensure that Green Belt boundaries endure beyond the plan period in accordance with provisions of paragraph 148 of the Framework. Additional sites should be safeguarded accordingly for this purpose. Our client’s land at Pattingham could be included within the list of safeguarded sites.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 5698

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Additional development should be directed towards the sustainable settlements, including the tier 1, 2 and 3 villages in order to ensure that the housing is directed towards sustainable locations to supporting existing services and facilities.

Change suggested by respondent:

As detailed in our representations, the housing requirement may need to be increased. Additional development should be directed towards the sustainable settlements, including the tier 1, 2 and 3 villages in orderto ensure that the housing is directed towards sustainable locations to supporting existing services and facilities.

Object

Publication Plan April 2024

Policy HC1: Housing Mix

Representation ID: 5699

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy HC1 is overly prescriptive . Policy HC1 should not impose a minimum requirement that 70% of dwellings on new housing schemes should be 3 bedrooms or less.

The Council’s HMA considers the mix requirements for the South Staffordshire element of the housing requirement only, not the Black Country and Birmingham’s.

We object to the suggestion that S.106 agreements will be used to secure the mix of outline planning applications.

Change suggested by respondent:

Policy HC1 should not impose a minimum requirement that 70% of dwellings on new housing schemes should be 3 bedrooms or less. A prescriptive requirement on development mix should be removed from this policy which should be reworded to make it clear that, whilst this may be a desirable target, it is not a policy requirement.

Object

Publication Plan April 2024

Policy HC8: Self-build and Custom Housebuilding

Representation ID: 5700

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy should be revised. The first paragraph in the
policy should be retained and the remaining sections should be deleted.

The policy is a sledgehammer to crack a very small nut as the need can be addressed through windfall sites. There is unlikely to be a take-up of self-build plots on large housing
estates

Change suggested by respondent:

The first paragraph in the policy should be retained and the remaining sections should be deleted.

Object

Publication Plan April 2024

Policy HC12: Space about dwellings and internal space

Representation ID: 5701

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain, it should make it clear that some flexibility to the policy may be applied depending on the individual merits of the development proposal.

Internal Space Standards Topic Paper does not justify the
requirement for use of space standards. Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDSS and the policies should seek to deliver this amount.

Change suggested by respondent:

Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain,it should make it clear that some flexibility to the policy may beapplied depending on the individual merits of the development proposal. This flexibility is applied to the part of the policy on external space standards and the same principle should also apply to internal space standards.

Object

Publication Plan April 2024

Policy NB6A: Net zero new build residential development (operational energy)

Representation ID: 5702

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy NB6 should be removed as it will jeopardise the deliverability and viability of residential schemes.This policy is unnecessary as the proper framework for delivering carbon reduction is through the Building Regulations legislative framework.

Policy NB6 requires a 10% improvement to the Part L 2021 Target for Fabric Energy Efficiency. However, that
benchmark standard is already out of date and is replaced by the introduction of the 2022 changes to the Part L Building Regulations; those changes achieve the 10 %
improvement which is referenced in policy NB6. Developers will not be able to comply with the post occupation monitoring requirement at policy NB6 A7. It will be extremely difficult to access that data from individual households over a 5 year period post occupation. We consider, therefore, that this part of the policy is not deliverable.

Change suggested by respondent:

This policy should be removed from the Plan.

Object

Publication Plan April 2024

Table 8: How housing growth will be distributed across the district

Representation ID: 5703

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Spatial Housing Strategy identified in Table 8 is flawed. May need to increase housing requirement with additional development required across the settlement hierarchy to meet the increased housing target.. Additional development should be directed towards Pattingham.

Change suggested by respondent:

The distribution development set out in Table 8 should be reconsidered if there is a need to increase the housing requirement. Additional development should be directed towards Pattingham.

Comment

Publication Plan April 2024

Appendix C

Representation ID: 5704

Received: 03/05/2024

Respondent: Hampton Oak Developments

Agent: PlanIt

Representation Summary:

Whilst we support the identification of land at Hall End Farm for residential development, The Housing Site Proforma should be amended. The site area should be quoted as 0.7 Hectares and the minimum capacity should be changed from 17 dwellings to c15 dwellings.

The site should be enlarged reflecting Pattingham as a sustainable settlement, the site specific credentials and there being no known constraints to development of the site. In the event that Allocation 251 is not enlarged we invite the council to remove the site from the Green Belt and identify it as safeguarded land.

Change suggested by respondent:

The Housing Site Proforma should be amended. The site area should be quoted as 0.7 Hectares and the minimum capacity should be changed from 17 dwellings to c15 dwellings.As detailed above, the proposed allocation 251 should be extended further south and east. This will help to address any shortfall in the housing requirement.
In the event that Allocation 251 is not enlarged we invitethe council to remove the site from the Green Belt and identify it as safeguarded land for the reasons which we have explained in response to Policy DS1.

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