Publication Plan November 2022
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Publication Plan November 2022
Policy SA4 – Strategic development location: Land North of Penkridge
Representation ID: 4534
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
Cameron Homes notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan.
Cameron Homes considers a more detailed housing trajectory should be included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.
Comment
Publication Plan November 2022
Policy HC2: Housing Density
Representation ID: 4535
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
Cameron Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Nevertheless, due to the size of the site at Saredon Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of
35dph. However, this would be achieved through the provision of areas of varying density and reflective of the character of surrounding development.
Comment
Publication Plan November 2022
Policy HC3: Affordable Housing
Representation ID: 4536
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
Cameron Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, Cameron Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.
Comment
Publication Plan November 2022
Policy HC8: Self-build and Custom Housebuilding
Representation ID: 4537
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
The 2022 SHMA identifies 30 applicants on the self-build register as of Spring 2022, recognising that 10 of these applicants are also on a register within another LPA. This demonstrates a very low level of demand.
Cameron Homes considers Policy HC8 provides a justified and proportionate approach to meeting this specific need, which requires the consideration of the
Council’s Self Build Register on major developments but falls short of requiring a specific percentage of provision.
Comment
Publication Plan November 2022
Policy HC10: Design Requirements
Representation ID: 4538
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
Cameron Homes supports the introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance.
It should be noted that Cameron Homes has entered into pre-application discussions to inform the emerging proposal for the proposed allocation at Land adjoining Saredon Road.
Comment
Publication Plan November 2022
Policy HC13: Parking Provision
Representation ID: 4539
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
Cameron Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential
Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
The EVCP standards set out in Appendix I of the Publication Plan are supported in respect of dwellings as this position aligns to Requirement S1 and Regulation 44D.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.
Comment
Publication Plan November 2022
Policy HC18: Sports Facilities and Playing Pitches
Representation ID: 4540
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
Publication Plan November 2022
Policy HC19: Green Infrastructure
Representation ID: 4541
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 at Saredon Road, including the provision of new recreation space and SuDS.
Comment
Publication Plan November 2022
Policy EC3: Employment and Skills
Representation ID: 4542
Received: 22/12/2022
Respondent: Cameron Homes Ltd
Agent: Evolve Planning & Design
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
Publication Plan November 2022
EC11: Infrastructure
Representation ID: 4543
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 adjoining Saredon Road.