Publication Plan November 2022

Comment

Representation ID: 4269

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Plan for adoption in winter 2023/24 may be unrealistic. If the Plan period does need to be extended to account for any slippage in its adoption date, the Council should explore the potential for increasing the capacity of the proposed allocation at Land at Hall End Farm, Pattingham.

Comment

Representation ID: 4270

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

There is a mismatch between the potential size of the employment pool from those who reside in the district and the new job opportunities which will be created. The Issues and Challenges for South Staffordshire’ section of the Plan should be re-drafted to reflect the fact that the housing and employment requirements are an opportunity for the local economy. Delivering sustainable development should be at the heart of the Plan and it should look to facilitate the delivery of this development at suitable locations.

Object

Representation ID: 4271

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS2 is ambiguous and simply suggests that S.106 agreements will be used to secure “compensatory improvements” to the environmental quality. What constitutes a “compensatory improvement” is not clear, and provides no certainty to developers.
Policy DS2 should be deleted. The “key requirement” of the proformas for each of the allocations should be used to clearly set out any Green Belt compensatory measures that may be required as part of the development of any former Green Belt sites. Policy DS2 is unclear and potentially undeliverable and could result in housing delivery being stalled.

Object

Representation ID: 4272

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Spatial Housing Strategy identified in Table 8 is flawed.

The distribution of development in Table 8 should be reconsidered and additional development should be directed towards Pattingham. Pattingham is expected to deliver just 0.2% of the total housing requirement. This will not meet the needs of the villages growing population. There are suitable and sustainable sites available for allocation that should be included within the Plan.

Object

Representation ID: 4273

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Housing requirement may need to be increased. Green Belt is not a constraint in itself because it is accepted by the Local Planning Authority that Green Belt land release is required. Pattingham has a number of services and facilities, but the draft Plan makes provision for development within the village which is equivalent of approximately 1 dwelling per year over the plan period. Additional development should be directed to Pattingham to reflect its size and the range of local services it provides.

Object

Representation ID: 4274

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to the requirement for 70% of homes to be 3 bed or less. The demand for property types could change over time. As such, policy HC1 should not be prescriptive and restrict the number of larger properties at this stage as there may be demand for larger properties later in the plan period. In addition, South Staffordshire has a large plan area. The demand for different property types is likely to change across the plan area. We object to the suggestion that S.106 agreements will be used to secure the mix of outline planning applications as this can be done by condition if necessary.

Object

Representation ID: 4275

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 should be reworded to advise that the density requirement of 35dph is a“target” rather than a requirement. Density should be a product of good design and a policy should not prescribe density; a better approach is to consider density at the planning application stage.

As drafted, the policy suggests it would be accepted for the scheme to deliver at 35dph if it had an adverse, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate. In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework. NDSS requirements would also restrict density requirements.

Object

Representation ID: 4276

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Internal Space Standards Topic Paper does not justify the requirement for use of space standards in Policy HC12 but identifies a series of matters relevant throughout the country. There is no evidence to suggest that the existing stock of housing is deficient against NDSS. Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDSS and the policies should seek to deliver this amount. The Council needs to recognise that if they require all properties to be NDSS compliant, it will have a direct impact on densities and affordability of new homes.
Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain, it should make it clear that some flexibility to the policy may be applied depending on the individual merits of the development proposal. This flexibility is applied to the part of the policy on external space standards and the same principle should also apply to internal space standards.

Object

Representation ID: 4277

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The approach to the distribution of development means that a number of sustainable locations are only planned to receive a minimal housing allocation. For example, of
the 7 tier 3 villages, only two are subject to a new housing allocations.Additional development should be directed to the villages in order to bolster their
services and facilities. A number of the settlements have schools, shops and public houses that would actively benefit from additional patronage. They are sustainable in
their own right and have local housing needs (both market and affordable) that are not being met by the plan.

Object

Representation ID: 4278

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

No evidence that the cost implications of the net zero policy, and its impact on viability, have been assessed. We consider that this policy is unnecessary and that the proper framework for delivering carbon reduction is through the Building Regulations legislative framework. There is no justification for the Council to accelerate the requirement for net zero through a planning policy.
It is noted that policy NB6 requires a 10% improvement to the Part L 2021 Target for Fabric Energy Efficiency. However, that benchmark standard is already out of date and is replaced by the introduction of the 2022 changes to the Part L Building Regulations; those changes achieve the 10 % improvement which is referenced in policy NB6. This policy should be removed from the Plan.