Publication Plan November 2022

Object

Representation ID: 5360

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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 in order to ensure that the Policy is sound.
The policy requirement for on-site equipped play provision as default is not supported as it
will not be appropriate for every site, for example where there is already high-quality
equipped play provision in the locality it would not make sense to duplicate this provision. In
addition, it is not appropriate to require open space to be centrally located on all sites as this
does not take into consideration differences in development sites opportunities and constraints. It is requested that the Council amend the policy to allow policy a more flexible approach to achieve the right design solution for each site.
The focus of Green Infrastructure provision should be based on quality rather than quantity or ‘useability’ and the exclusion of small incidental green infrastructure (GI) without a clear recreational purpose from on-site open space provision is not supported.
Planning Practice Guidance acknowledges that 'Green infrastructure can embrace a range of Spaces.
The policy should therefore be revisited and clarified, with clear reference to national
guidance ensure that open space and green infrastructure is properly and clearly defined and to recognise the contribution that a range of spaces and uses will bring to a development.

Comment

Representation ID: 5361

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy HC18 is informed by the playing pitch and sport facilities assessments produced by KKP in 2020 and is broadly supported.
Cameron Homes recognises that a financial contribution to sports facilities and playing pitches may be necessary from new major developments to meet needs arising from the proposed development but this should be fully evidence and compliant with the CIL tests.

Object

Representation ID: 5362

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirement for an Employment and Skills Plan to be prepared for all developments of 100 or more residential dwellings is not supported. Whilst the benefits of such plans are acknowledged, it is considered more appropriate to implement them on a site-by-site basis,
dependent on local circumstances and the labour market and such a requirement can be sourced by condition.
Cameron Homes is a local housebuilder based in southern Staffordshire with a headquarters office within 5km of South Staffordshire District. As such, Cameron Homes already supports local employment growth, assists in addressing the construction skills shortage through graduate, apprenticeship and trainee schemes.

Comment

Representation ID: 5363

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy EC11 commits SSDC to work with and support infrastructure providers and also offer support for the delivery of infrastructure. This is broadly supported, but any assessment of cumulative impact and mitigation requested must be proportionate and CIL Regulation 122 compliant. The policy should be explicit that this is the case.

Comment

Representation ID: 5364

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Cameron Homes acknowledges the aspirations of this policy however the Government policy and guidance does not yet require 10% biodiversity net gain. The policy should reflect the latest national legislation, policy or guidance with respect to biodiversity net gain.

Object

Representation ID: 5365

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Given that the Environment Act 2021 has recently been made into law, it needs to be made clear that this policy reflects the Act and its purpose.
Concern is raised with some of the technical detail raised in Policy NB6. Clause 3 regarding embodied carbon.
Whilst Cameron Homes fully appreciate the value of Whole Life-Cycle Carbon assessments and the need for some form of post construction, pre-occupation assessment, there is concern raised about this policy. Firstly, once sold the properties will be owned by the
purchasers and their mortgagees. There are issues of data protection and consent surrounding the recording and sharing of energy use, air quality and overheating risk data with a third party, in respect of properties that the developer will not own.
Secondly, a question arises as to the purpose of such widespread collation of such data. It will not be possible to post factum make alterations to the constructed buildings, so what is the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations. Extracting, what is in effect lifestyle data, from private individuals, is neither considered desirable nor practical in this regard.
There is no evidence to suggest that the Council have considered or addressed the GDPR implications of this requirement, its effect on ‘mortgage-ability’, or indeed its effect on sales values. Presumably properties which are wired to share private individual’s lifestyle data,
would be less attractive in the marketplace, and that would be reflected in reduced sales values.
Further, the requirement of the policy for developments to demonstrate a minimum 63% reduction in carbon emissions, with each dwellings achieving at least a 10% improvement on the Building Regulations Part L 2021 Target for Fabric Energy Efficiency, plus post development requirements to achieve as least zero regulated carbon across the scheme is unnecessary. It is repetitious of Part L of the Building Regulations, where the Government set standards for energy efficiency
Similarly, the water efficient standard of 110 litres per person per day is different to the Building Regulations requirements of 125 litres per person per day and is unjustified.

Comment

Representation ID: 5366

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Evidence base: Sustainability Appraisal
The site is assessed within the SA (Volume 2) under site reference 082. The SA produced to support this Regulation 19 Plan provides a summary of the post-mitigation site assessments for allocated sites (see Table 6.5). Cameron Homes broadly supports the scoring within the SA. It is noted that the scoring is particularly favourable when compared against other sites within the SA, thereby justifying the allocation of the site.
It is also noted that the scoring is broadly consistent with the SA published as part of the
Preferred Options (Regulation 18) consultation. The only change is to upgrade the biodiversity and geodiversity from ‘uncertain’ to ‘negligible’. This is supported as the
Indicative Masterplan shows a significant amount of Public Open Space (POS) can be accommodated on-site. This could also present opportunities for biodiversity
enhancement.

Comment

Representation ID: 5367

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Evidence base: Site Selection Topic Paper 2022
The known site constraints listed are the lack of a footway on School Lane, removal of an agricultural field, minerals safeguarding and the well planted boundary along School Lane presenting a barrier to access. The Indicative Masterplan demonstrates how access could
be achieved from School Lane. It also shows how the site would connect into the existing footpath provision on School Lane to the south which does connect to the village centre via Brewood Road. In terms of minerals, the site is relatively small for mineral extraction and located in close proximity to existing residential properties therefore any extraction would likely be unacceptable due to amenity concerns for nearby residents.
The proforma concludes that the safeguarded site could deliver the Council’s spatial strategy is allocation. This is supported and justifies the safeguarded site’s status as a
proposed allocation.