No

ID sylw: 99271

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

It does not contain any Call for Sites submissions - why is it included?

No

ID sylw: 99273

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

No, we fail to understand why some of the specific new settlement locations have been chosen and how disconnected they are from the Call for Sites exercises. We would also question the integrity of inviting further Call for Sites submissions where none were previously submitted. Were prospective new settlements to be identified then they should have drawn on the Call for Sites results, as they have been, as in the case of proposed new settlement A1, which is supported by our client.

Other

ID sylw: 99291

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

The potential for smaller scale developments to fulfil a significant role in meeting future growth needs should be recognised and given as much importance as strategic allocations. Existing settlement boundaries should be reviewed and new boundaries created. Tanworth-in-Arden contains 2 HELAA B sites (515 and 758) to allow smaller scale development supporting its services and facilities and in villages nearby.

Green Belt policy changes need to be fully taken on-board, e.g. Site 758 is Grey Belt. This is likely to increase the number of small-scale developments.

In a predominantly rural area, small sites should contribute significantly > 10% of supply.

Other

ID sylw: 99295

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

There is a need for greater certainty and quantification on meeting cross-boundary needs. The suggestion in the Policy Direction for the capacity to be identified on reserve site released only when supply in the source area falls below 5 years is unworkable. Also, this forgets that some of the requirement might be for other types of development.

Other

ID sylw: 99297

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

Our client considers there are some important points to make on this:
(1) this statement implies the critical technical work to justify the plan is not in place, and
(2) why should the IDP being 'live' only apply up to submission and not be continuous even post adoption?

No

ID sylw: 99301

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

This policy direction implies that transport infrastructure trumps all other infrastructure types with other types of infrastructure dealt with as after-thoughts.

If the pattern of development is over-reliant on strategic level growth that requires too many large-scale infrastructure projects to deliver it, then the scale of growth might be constrained.

Decisions on major investment locations seem to have been taken outside the key public transport corridors whereas a different approach appears to apply in relation to housing and smaller scale employment proposals. This suggests there is too high a focus given to transport considerations in the emerging plan.

No

ID sylw: 99306

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

The consultation itself appears to confirm that it has been overtaken by events and should be rerun at a later date taking account of responses, e.g. changes in Green Belt policy including the introduction of grey belt? This would enable, for example, detailed policy wording to be added.

Notwithstanding that, it is clear from the Councils’ own interpretation of Site 758 under the HELAA B that the site is Grey Belt and therefore its development would not be considered to be inappropriate, subject to its compliance with the Golden Rules, which the site could meet.

Yes

ID sylw: 99310

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

The policy confirms that where available brownfield land is located outside of urban areas, decisions on its use will have reference to the sustainability of the location, with regard to the Spatial Growth Strategy priority areas 1-3; and/or whether its use would increase the sustainability of the area as part of a large-scale development such as a new settlement.

New Settlement A1, including site 758, demonstrates the acknowledgement of the brownfield status of the site and the sustainability of its location, including the use of the site as part of a larger scale development. Our client supports this policy.

Other

ID sylw: 99318

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

The planning process seems to have run into various cul-de-sacs. There is a need to focus on:

• the level of growth required - housing and employment
• how this should be accommodated, urban/ rural, small, medium and strategic level growth including a possible new settlement(s)
• a single rather than 2-part plan
• settlement boundary reviews or establish where appropriate
• embrace updated NPPF especially with regard to Green Belt and Grey Belt
• embrace infrastructure ‘in the round’
• deploy development to help achieve 20-minute neighbourhoods in all areas.

Other

ID sylw: 99321

Derbyniwyd: 06/03/2025

Ymatebydd: Summers Holdings Ltd

Asiant : The Tyler Parkes Partnership Ltd

The consultation states, "5.1 Draft Policy Direction 10- Providing the Right Tenure and Type of Homes - The councils will have regard to the latest evidence in drafting policies relating to housing tenure and type."

This policy needs to be specific to be subject to informed comment.