Publication Plan November 2022

Comment

Representation ID: 4512

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes the Indoor Sports Facilities Strategy and Playing Pitch Assessment/Strategy that forms part of the evidence base for the emerging Local Plan.
Cameron Homes recognises that a financial contribution to sports facilities and playing pitches may be necessary from new major development to meet needs arising from the development but this should only apply where evidence recognises there is a shortfall in capacity to meet the generated demand from the development.

Comment

Representation ID: 4513

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the policy approach to protecting, maintaining and enhancing where possible a network of interconnected, multi-functional and accessible green and blue spaces.
The sketch layout included at Appendix 1 demonstrates the delivery of multifunctional, interconnected, accessible green and blue spaces as part of the comprehensive proposal for Land East of Wolverhampton Road, including the provision of new recreation space and SuDS.

Object

Representation ID: 4514

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Not specified

Sound? No

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 units is not supported by Cameron Homes.
It is not clear how any certainty could be provided through the provision of such a Plan. 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 programmes and is committed to doing its part to help to resolve the well-documented national housing crisis.

Comment

Representation ID: 4515

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Cameron Homes is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future
iterations of the Infrastructure Delivery Plan and the emerging proposal for Land East of Wolverhampton Road.

Comment

Representation ID: 4516

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

The intention of Policy NB2 is recognised, however, the Government policy and guidance does not yet require 10% biodiversity net gain. Any policy should require a net gain in line with latest Government legislation, policy or guidance.

Comment

Representation ID: 4517

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes further evidence in respect of Cannock Chase SAC, including a review of mitigation measures and visitor survey. This evidence has informed the current mitigation measures as Policy NB3 to address any impact arising from development within a 15km radius of Cannock Chase SAC.
Cameron Homes recognises that Land East of Wolverhampton Road is within a 15km Zone of Influence of Cannock Chase SAC.

Object

Representation ID: 4520

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At present the SHMA assumes that the projected growth of the working age population in South Staffordshire will grow by 6,618 people between 2020-2040. Whilst this is in excess of the forecast jobs growth outlined in the EDNA, Cameron Homes is concerned that the EDNA fails to realistically consider additional jobs created at WMI. Further consideration should therefore be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth, even taking into consideration the 4,000 additional homes to meet unmet needs in the wider housing market area

Object

Representation ID: 4521

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Cameron Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Cameron Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4522

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered that a specific requirement for bungalows is not appropriate if instead the Council pursues a policy of requiring 100% of all homes to meet optional M4(2) requirements.
The Government has consulted on raising accessibility standards for new homes but the requirement for all homes to meet M4(2) standards is yet to be mandated. If the Council intends to pursue a policy in respect of M4(2) standards this must be evidenced. Cameron Homes considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.

Object

Representation ID: 4523

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.
See supporting representations for further details.