Publication Plan November 2022

Object

Representation ID: 5396

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

What level of impact is deemed unacceptable?
Policy should acknowledge that not all residents of a development will be new to a catchment area, may already be registered locally and therefore will not create an additional burden. Careful analysis is required with regard to the capacity of existing infrastructure to accommodate new patients before any conclusions are reached.

Object

Representation ID: 5397

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy as currently written makes a blanket assumption that new education infrastructure will be required from all new development. Policy should recognise that new infrastructure will only be required where it can be demonstrated that existing capacity to accommodate growth does not currently exist.

Object

Representation ID: 5398

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

policy should acknowledge that the type of open space provision including formal play equipment should be considered on a site by site basis taking account of site constraints and existing provision in the wider area.

Object

Representation ID: 5399

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Reference to requiring for all developments to incorporate tree lined streets should be refined to reflect NPPF.

Object

Representation ID: 5400

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The level of contribution should be monitored in line with proposed housing numbers going forward to ensure contributions accurately reflect the housing levels within the 15km zone.

Welcome confirmation that offsite SANGs are not being pursued at this time.

Object

Representation ID: 5401

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend wording to recognise that close proximity to national road network is a critical requirement for B8 use development.

Object

Representation ID: 5402

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Apply policy EC8 to new settlements as well as SUEs.

Object

Representation ID: 5403

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Ensure that Infrastructure Delivery Plan is up to date at the time of the examination.

Object

Representation ID: 5404

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy requirements should be drafted in line with requirements of the Environment Bill. There should be a flexible approach to the delivery of BNG in a comparable manner to open space, biodiversity improvements can be delivered in conjunction with open space.

Object

Representation ID: 5405

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Requirements in Part1 go beyond Government’s Future Homes Standard roadmap. Confused over differing standards – net zero and a 63% reduction. Not clear how the 63% will be implemented. Not clear that South Staffs have considered the implication of the proposed standards in Part1 on deliverability. Changes should be introduced gradually and applied equally across the UK. Advancing ahead of national standards could impact on delivery owing to skilled labour shortages.

On-site renewable energy policy should be applied flexibly to take account of any site specific site constraints.

Part 3 – Issues surrounding data collection to undertake a proper Whole Life Carbon Assessment (WLCA) – many manufacturers still lacking the creation and verification of data for Environment Product Declarations, important that South Staffordshire allow some tolerance when assessing WLCA. Suggest that WLCA be submitted as part of planning condition attached to grant of detailed planning permission.

In relation to the recognised quality regime, we wish to highlight the following issues:
- Registered inconsistencies in the as built testing methodologies. These need to undergo more rigorous testing before they are rolled out at scale.
- Limited number of companies offering as built testing, unlikely the current sector will be able to cope with demand.
- Current elements can only be undertaken in winter.
We suggest that South Staffordshire reconsider the requirement for immediate implementation of the as built assessment. If retained, demonstrate that the as built assessment sector will be able to meet the resultant demand.