Publication Plan April 2024

Object

Representation ID: 6371

Received: 30/05/2024

Respondent: Pland Estates Limited

Agent: Knight Frank LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

To contribute to making the Local Plan sound Strategic Objective 1 should be reworded to Protect the Green Belt and Open Countryside ensuring that where Green Belt release is proposed in sustainable locations, mechanisms are in place to secure compensatory improvements to the environmental quality and accessibility of the remaining Green Belt. ”

Object

Representation ID: 6372

Received: 30/05/2024

Respondent: Pland Estates Limited

Agent: Knight Frank LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Startegic Objective 2 - the last part of the last sentence that currenlty reads "with a partcular focus on the district's most sustainable Tier 1 settlements' should be removed to contribute to making the plan sound and to reflect that there are further sustainable locations in lower tier settlements.

Object

Representation ID: 6373

Received: 30/05/2024

Respondent: Pland Estates Limited

Agent: Knight Frank LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Given the major allocations in the plan including at Penkridge, it considered that policies should be set to look further ahead by at least 30 years, which increases the plan period from 2023-2041 to 2023 to 2053. Otherwise, the local plan is not considered to be compliant with para 22 NPPF.

The removal of an additional 4,000 dwellings, as proposed in the South Staffordshire Local Plan, does not align with para 26 NPPF which explicitly states that “joint working should help to determine where (…) development needs that cannot be met wholly within a particular plan area
could be met elsewhere”.The removal of the contribution of 4,000 dwellings is considered to make the plan unsound, as per the definition of para 35 NPPF, stating that plans should be “positively prepared”

Object

Representation ID: 6374

Received: 30/05/2024

Respondent: Pland Estates Limited

Agent: Knight Frank LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The allocation north of Penkridge should be reduced to 905 dwellings to reflect outline permissions. Not appropriate to include part of wider development consented under 19/00862/REM as a draft allocation. The approach of only releasing Green Belt around Tier 1 settlements is not justffied. Approach of only releasing Green Belt at Tier 1 settlements due to being well served by public transport, does not mean that all new development adjacent to, within or around Tier 1 settlements will directly benefit from the availability of rail transport due to either distance to the site or lack of secondary or tertiary public transport (i.e. bus services) to link to the nearest railway station. It is therefore not considered robustly justified that directing major development predominantly into Tier 1 settlements, including green belt locations, will lead to more sustainably located development.

It is therefore considered that the tier’ed approach to releasing Green Belt land is not justified and should be done on a case-by-case basis, including considering the site on land north of Featherstone as an allocation for residential development.

Object

Representation ID: 6375

Received: 30/05/2024

Respondent: Pland Estates Limited

Agent: Knight Frank LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The justification for limiting green belt release to Tier 1 settlements is not inherently clear, as the settlement
tiers do not directly correlate with the green belt and its five purposes as set out in para 143 NPPF.It is considered that sustainable development is not only achieved at Tier 1 settlements, but can be achieved in sub-Tier 1 settlements, subject to immediate availability of public transport, services and facilities.Policy SA3 should be amended to incorporate the land north of Featherstone which can deliver circa 370 dwellings.

Object

Representation ID: 6821

Received: 31/05/2024

Respondent: Pland Estates Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Promoted site at Land off Moor Lane Pattingham should be allocated representing a natural 'rounding off' of the village.

The site would contribute to local housing needs by providing circa 80 additional dwellings in a sustainable development with direct access to public transport and within walking distance of facilities and services.

Object

Representation ID: 6822

Received: 31/05/2024

Respondent: Pland Estates Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As Penkridge is a large urban extesion the plan needs to look forward to 2053 (i.e at least 30 years) in order to comply with NPPF para 22.

Comment

Representation ID: 6823

Received: 31/05/2024

Respondent: Pland Estates Limited

Recommended to include 'in sustainable locations' in Strategic Objective 1 to read:

"Protect the Green Belt and Open Countryside ensuring that where Green Belt release is proposed in sustainable location....'

Recommend removing 'with a particular focus on the district's most sustainable Tier 1 settlements' from Strategic Objective 2 as it should not be generalised within the Strategic Objective 2, as sustainable locations can vary within Tier 1 settlements.

Object

Representation ID: 6825

Received: 31/05/2024

Respondent: Pland Estates Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In light of evidenced unmet needs in the HMA, the removal of the additional 4000 dwelling contribution to unmet needs does not align with para 26 of the NPPF.

Object

Representation ID: 6826

Received: 31/05/2024

Respondent: Pland Estates Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is noted that part of the draft allocation as per detailed permission (ref 19/00862/REM ifor up to 200 dwellings is complete so should be reoved from the allocation.

The allocation north of Penkridge should be reduced to 905 dwellings to reflect out applications on the site.