Comment

Representation ID: 21298

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy ENV2 – Development Affecting Special Areas of Conservation

Draft Policy ENV2 requires any development that leads to a net increase in homes or creates visitor accommodation within 15km of the boundary of Cannock Chase SAC to carry out an appropriate assessment. Any adverse impacts will be required to be mitigated. Acceptable mitigation measures will include proportionate financial contributions towards the Cannock Chase SAC Partnership Site Access Management and Monitoring Measures (SAMMM).

Whilst the principle of the policy is supported, the costs associated with the local policy requirements proposed should be fully accounted for within the Viability Assessment (in line with the (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). Whilst the Viability Assessment appears to reflect these considerations (in table 3.5) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 58).