Object

Representation ID: 5027

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

Vistry has no issue with the proposed plan period for growth (2018-2039). Planning for the twenty-one-year period to 2039 is appropriate. The plan is sound in this respect.
Vistry support the general level of housing for its own needs to be provided within the plan period in the context that it is a reflection of the latest Standard Methodology requirements of 4,097 dwellings per annum, albeit this should be seen as the minimum to be provided to allow for slippage or sites not coming forward.
Vistry note that the Council has maintained its commitment to providing some 4,000 houses to accommodate the unmet need arising from the GBBCHMA. Whilst Vistry is generally supportive of this principle of the Council providing for neighbouring unmet need, as set out above, it has concerns in respect of the level of that provision. Furthermore, it is not clear which allocated sites or locations (beyond two obvious ones Linthouse Lane and Langley Road) are making this provision. Vistry consider in the interests of transparency, that this should be made clear in the Plan.
The 2039 Plan proposes to focus the majority of its housing requirement within four new strategic sites, ‘strategic’ because of the level of specific infrastructure identified to support them.
It is recognised by Vistry that there is an inherent finite capacity for development within smaller settlements before other options have to be considered to accommodate the growth required, although Vistry maintain that further expansion of Bilbrook/Codsall, given its sustainable credentials (two stations, a high level of facilities and proximity and ease of access to I54) that further expansion of Bilbrook is considered possible and sustainable. The housing requirements for future plans are likely such that this can realistically only be accommodated through the development of new settlements. The Plan puts down a marker in this regard, with the inclusion of a policy for the identification of a new settlement for a future plan review.
However, the crux of these Vistry representations in respect of Development Strategy is that the allocation of a number of the sites (particularly the strategic ones) have considerable constraints that affect their housing capacities that have not been fully recognised. As a result, they are not fully deliverable and therefore not the most appropriate locations for the development. The 2039 Plan is unsound in this respect.
In summary, given all of the uncertainties identified above in relation to a number of the allocated housing sites, Vistry maintain it is impossible to determine the level of housing and development that the allocations can provide per se, let alone delivery in the plan period to 2039. It would appear that additional land is likely to be required to deliver the overall housing requirement.