Publication Plan November 2022

Support

Representation ID: 4798

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Support the proposed allocation of the safeguarded land to the south of White Hill, Kinver (site 274) alongside the existing allocation for a minimum of 120 dwellings. The allocation of safeguarded land is necessary for compliance with paragraph 141 of the NPPF.

Housing delivery in Kinver is a sound approach as it has been previously assessed/examined as a sustainable location. It is a logical infill to the settlement boundary and existing allocation.

The Site Selection Topic Paper illustrates that the council have followed a logical, robust, and justified process based upon proportionate evidence. Site 274 has no major negative scores in the SA as a non-Green Belt site, and scores better than alternative sites in Kinver. The paper does note that the existing allocation is yet to secure outline planning permission due to an outstanding S106 agreement, however this was issued in September 2021.

Site 274, land south of White Hill, Kinver, is a available for housing development immediately. Although it contains a number of TPOs, it is well serviced by Potters Cross Neighbourhood Centre and slightly further afield by the village centre. Safe pedestrian walking routes are available to nearby schools, which Staffordshire County Council have confirmed can accommodate extra pupils. Regular bus services are available to Stourbridge.

The site is located within Flood Zone 1, with a masterplan designed to accommodate appropriate SUDs. It is considered unlikely that the site will impact upon ecological sites including Kinver Edge SSI. High quality trees and hedgerows will be retained on site where feasible. Opportunities for biodiversity net gains on-site and off-site will be provided where necessary.

Site access will be achieved through the approved priority junction on White Hill with standards to accommodate the proposed allocation. Willing to explore issues and solutions to concerns regarding the Potters Cross junction where they meet the planning tests.

There are no significant heritage/archaeological impacts, and and any effects upon the historic environment can be mitigated. To comply with existing policy SAD2, a view corridor could be achieved between the site access towards Kinver Edge and Holy Austin Rock.

Support

Representation ID: 4800

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Kinver contains a wide range of services and facilities and has the capacity to support housing growth. Housing delivery in Kinver is a sound approach as it is a sustainable location.

Object

Representation ID: 4804

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Not specified

The wording of the final sentence of this policy is inconsistent with paragraph 11 of the NPPF and should be deleted.

Last sentence of policy DS5 should be deleted.

Object

Representation ID: 4807

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The policy, as worded, is inflexible, and changing needs over time can not be reflected impacting upon the delivery of homes in future.

The reference to disproportionate quantum of 4+ bedrooms and making efficient use of land is ambiguous, and should be deleted.

Wording should be amended to read "major developments should provide a minimum of 70% of properties with three bedrooms or less, unless an alternative mix can be justified by more up to date evidence of need, for example, evidence of current market demand and more up to date local needs assessment".

Object

Representation ID: 4809

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

It is unclear whether the density requirement of 35dph applies to allocated sites adjoining non-Tier 1 settlements. This should be amended to provide clarification, and allow for more flexibility in line with paragraph 124 of the NPPF.

Object

Representation ID: 4813

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

A blanket requirement for 30% affordable housing requirement on all sites is not justified having regard to paragraphs 3.2.2 and 3.2.3 of the Viability Study (2022), not consistent with the NPPF requirement that the levels and types of affordable housing should not undermine plan deliverability.

Object

Representation ID: 4815

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

This policy is vague, and it is unclear how it would be applied by a decision-maker. This fails to comply with part D, paragraph 16 of the NPPF to avoid situations where the ambiguity in policy leads to a delay in housing delivery.

The council's own assessment of accessible and adaptable dwellings does not take account of the existing dwelling stock. The figure of 3,978 dwellings equates to c.40% of the overall housing target. The requirement for 100% of dwellings to comply with M4(2) standards is no justified.

Object

Representation ID: 4816

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

It is not considered appropriate to require major developments to provide for self-builders. There is no legislative requirement, or national policy stipulation. The NPPG encourages not requires councils to engage with developers about the contribution their schemes could make towards the supply, only where housebuilders have expressed an interest in this.

The requirement for development to have regard to the self and custom build register and make a provision of plots to meet this is unsound and should be deleted.

Object

Representation ID: 4823

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The wording of this policy appears to give guidance in the South Staffordshire Design Guide SPD and other guidance documents the same weight as a Development Plan Policy. This is inappropriate and the wording should be amended appropriately.

Object

Representation ID: 4824

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The Internal Space Standards Report (2021) does not provide any evidence of the need for NDSS to apply in the district and the reasons why houses in the district need to be larger. There is also a risk that an inflexible approach to the application of NDSS could have unintended the consequence of impacting upon affordability and fails to recognise that well designed dwellings below the NDSS can provide good affordable home options. This element of the policy is unjustified and unsound and should be deleted.