Publication Plan November 2022

Support

Representation ID: 4810

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

The overall levels of growth for South Staffordshire is also supported as set out in Policy DS4: Development Needs. Although some caution should be given to the significance of the identified contribution of 4,000 homes for the plan area given the ever-increasing level of unmet housing need within the Greater Birmingham and Black Country Housing Market Area. This is noting the most recent Birmingham City Issues and Options consultation (November 2022) identified a shortfall of 78,415 homes and that the Black Country Plan has collapsed since the publication of the current publication version of the SSC Plan.

Support

Representation ID: 4811

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

The identification of Penkridge as one of the Districts Tier 1 settlements in Policy DS5: The Spatial Strategy to 2039 is supported and reflects the villages sustainable nature
and ability to support new housing growth

Object

Representation ID: 4812

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is important that the masterplan prepared for the site does not prejudice the fair delivery of development on Site 420, which is a key link between the exisitng built form of Penkridge and the main bulk of the strategic allocation north of Penkridge.

In terms of the requirements for a Transport Strategy for the site to be developed the plan appears to be supported by a Strategic Transport Assessment for Land North of Penkridge prepared by PJA and included within the Council's evidence base. We raise concerns regarding the status of this document given that we as one of the site promoters have not been provided with the opportunity to feed in to either its scope or contents.The current indicative masterplan does not include direct access to Trine's land from the A449 which should not be assumed as a previous planning application to the Council showed that this was achievable with no objections from the highways authorities.

In regard to the provision of a Community Hub within the development, this element of the proposed allocation should be supported by evidence. Evidence of the need for such uses must be presented for that requirement to be justified. Should appropriate evidence be provided, and the requirement retained, the policy should be updated to give specific guidance in relation to the floorspaces and use classes being sought, so that the policy requirement is clearly written and unambiguous in accordance with the NPPF.

The principles of part g) of the policy are supported. However, the requirement to provide compensatory Green Belt Improvements are somewhat confusing as they do not appear to apply to this site. The site is outwith the defined Green Belt and when cross referenced with the requirements of Policy DS2: Green Belt Compensatory Improvements the development of the site falls outside of the scope of this policy. The need for the riverside linear park is understood but this should not be a compensatory requirement for the removal of other sites within the District or Penkridge from the Green Belt and in any event any compensatory improvements should be undertaken within the Green Belt. As such reference to compensatory Green Belt improvements should be removed from the policy.

Object

Representation ID: 4814

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We generally support the principle of the preparation of wider strategic masterplanning for these important sites, but it is imperative that the Council help to ensure that Trine are able to meaningfully and fairly input into and influence the preparation of the Strategic Master Plan (SMP) for Penkridge. It is also important that Trine are actively involved in any pre-application discussions,
community and stakeholder engagement for the site.

One area of concern under e) Green Infrastructure Framework. relates to the provision of the following:
'Areas for allotments/community gardens/forest schools etc. (informed by engagement with local community/Parish Council).'

There is a potential risk here given the explicit requirement for areas to be identified within the SMP that the need, appropriateness and quantum of such provision on the Land North of Penkridge may not align with the desires of the local community/Parish Council which if there is no agreement could be seen as a failing of the SMP.

It is suggested that the explicit reference to the provisions of allotments/community gardens/forest schools are removed as a requirement of the policy and included within the ‘for example list’ under the first point of part e) Green Infrastructure Framework.The requirement for community engagement would remain a requirement under part k) of the policy.

Object

Representation ID: 4817

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In terms of cross reference between these policies and Policy SA4 – Strategic development location: Land North of Penkridge. The policy requirements are clear that at least 40 units providing for specialist elderly housing are required on each of the housing allocations. It is not clear whether the housing mix, density and affordable housing provision for each of the strategic allocations is to be met within individual planning applications (which could be numerous) or within the allocation as a whole. For clarity and in order to avoid confusion this matter should be identified either within these policies or Policies MA1 or SA4.

Object

Representation ID: 4818

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In terms of cross reference between these policies and Policy SA4 – Strategic development location: Land North of Penkridge. The policy requirements are clear that at least 40 units providing for specialist elderly housing are required on each of the housing allocations. It is not clear whether the housing mix, density and affordable housing provision for each of the strategic allocations is to be met within individual planning applications (which could be numerous) or within the allocation as a whole. For clarity and in order to avoid confusion this matter should be identified either within these policies or Policies MA1 or SA4.

Object

Representation ID: 4819

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In terms of cross reference between these policies and Policy SA4 – Strategic development location: Land North of Penkridge. The policy requirements are clear that at least 40 units providing for specialist elderly housing are required on each of the housing allocations. It is not clear whether the housing mix, density and affordable housing provision for each of the strategic allocations is to be met within individual planning applications (which could be numerous) or within the allocation as a whole. For clarity and in order to avoid confusion this matter should be identified either within these policies or Policies MA1 or SA4.

Object

Representation ID: 4820

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In terms of cross reference between these policies and Policy SA4 – Strategic development location: Land North of Penkridge. The policy requirements are clear that at least 40 units providing for specialist elderly housing are required on each of the housing allocations. It is not clear whether the housing mix, density and affordable housing provision for each of the strategic allocations is to be met within individual planning applications (which could be numerous) or within the allocation as a whole. For clarity and in order to avoid confusion this matter should be identified either within these policies or Policies MA1 or SA4.

Object

Representation ID: 4821

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As mentioned in response to Policy SA4 it is considered necessary for there to be consideration of and a definition of what constitutes the small-scale retail provision for
each of the strategic allocations. Without such clarification the policy requirements remain vague.

Object

Representation ID: 4822

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We support the provisions of Policy EC11 and the need for developer contributions and infrastructure provision in principle. However, as drafted, the policy makes no reference to the provisions of the CIL tests, which
should be explicit. As a result, the policy is imprecise, and it is not clear whether its operation would be discordant and at variation with the CIL provisions. The policy should be modified to expressly refer to the three CIL tests
and furthermore make clear that developer contributions and infrastructure provision will only be required where each of the three tests are demonstrably met.