Policy HC1: Housing Mix

Object

Representation ID: 4165

Received: 20/12/2022

Respondent: Miller Homes

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.

Comment

Representation ID: 4247

Received: 23/12/2022

Respondent: Kinver Neighbourhood Plan Group

There is no reference to Community Infrastructure Levy only S106 agreements on schemes, although both can be used. The Local Plan should provide clarity on optimising both options to increase much needed community funding. Please explain what plans there are to change to CIL.

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: 4355

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Object

Representation ID: 4397

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Bloor Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Bloor Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District
See supporting representations for further details.

Object

Representation ID: 4492

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Cameron Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Cameron Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4521

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Cameron Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Cameron Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4547

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Cameron Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Cameron Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District.

Object

Representation ID: 4573

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Taylor Wimpey would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Taylor Wimpey would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4604

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Four Ashes Road Ltd would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Four Ashes Road Ltd would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District.

Object

Representation ID: 4632

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is important that housing mix is determined on a site by site basis and takes account of market signals at the time (PPG Reference ID: 61-038-20190315). It would be appropriate for the Council to refer to other evidence not just the latest Housing Market Assessment and consider other elements such as the current demand.
Reference is made in the policy to: “any development that fails to make efficient use of land by providing a disproportionate amount of large, 4+ bedroom homes compared with local housing need will be refused”. “disproportionate” is not defined in the policy, so it is therefore unclear how this is measured or how a developer should respond to this. This policy should be reworded in order to evidence it has been positively prepared as required by paragraph 35 of the NPPF.

Object

Representation ID: 4660

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Keon Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Keon Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4700

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Lovell Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Lovell Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District

Object

Representation ID: 4734

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is not appropriate for each site to display variety and choice in housing types and tenures, and for there to be a specific requirement of 70% of properties to be 3bed or less. It is not the case that smaller household units and an ageing population want smaller homes. There is a growing trend for the elderly to want spare rooms for visitors, and working age population to want home office space. This requirement should be removed.

Small sites should not be required to provide a mixture of property sizes.

Object

Representation ID: 4760

Received: 19/12/2022

Respondent: Mrs Joanne Harding

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF understands the need for a mix of house types, sizes and tenures and is generally supportive of providing a range and choice of homes. The HBF recommends a flexible approach is taken regarding housing mix which recognises that needs and demand will vary from area to area and site to site; ensures that the scheme is viable; and provides an appropriate mix for the location and market. The Council should refer to other evidence not just the latest Housing Market Assessment.

Object

Representation ID: 4801

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The requirement for a minimum of 70% of dwellings to be 3 bedrooms or less would not deliver mixed, sustainable and inclusive communities and does not provide sufficient flexibility.

Object

Representation ID: 4807

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The policy, as worded, is inflexible, and changing needs over time can not be reflected impacting upon the delivery of homes in future.

The reference to disproportionate quantum of 4+ bedrooms and making efficient use of land is ambiguous, and should be deleted.

Wording should be amended to read "major developments should provide a minimum of 70% of properties with three bedrooms or less, unless an alternative mix can be justified by more up to date evidence of need, for example, evidence of current market demand and more up to date local needs assessment".

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: 4841

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy should be more flexible, recognising that housing needs vary within different areas and on a site-by-site basis. Housing requirements constantly evolves and as such there should be flexibility embedded in policies to enable them to respond to changing demands and context.

Policy HC1 should therefore more closely reflect the flexibility of the existing Core Strategy policy H1 which requires:
“A mix of housing sizes, types and tenures within both market and affordable sectors, particularly the
needs of an ageing population, informed by the Housing Market Assessment, which meet the needs
and aspirations of all sections of the local community.”

The Strategic Housing Market Assessment (October 2022) does not identify a significant predicted
change in the projected household type proportions in South Staffordshire between 2018 figures and
2040. As such, it is not clear why a highly prescriptive housing mix is included within Policy HC1.

Comment

Representation ID: 4886

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the core principle of these policies, to create ‘mixed, sustainable and inclusive communities’. However, the prescriptive minimum housing requirements
may risk providing the wrong type of housing for Kinver residents and potentially impact on development viability and delivery.
As such, the policy should be reconsidered to ensure it accords with paragraph 82 of the NPPF and the need for policies to “be flexible enough to accommodate needs not
anticipated in the plan” and to “enable a rapid response to changes in economic circumstances.”
The policy should take a more flexible approach on housing mix to ensure it is
consistent with NPPF paragraph 82’s need for policies to “be flexible enough to
accommodate needs not anticipated in the plan” and to “enable a rapid response to
changes in economic circumstances.” It also needs to recognise that housing needs vary within different areas and on a site-by-site basis. The policy must ensure that the viability of development proposals is protected whilst providing an appropriate housing mix for the site location and local market. In addition to evidence such as the latest Housing Market Assessment, it would be appropriate for the Council to refer to other evidence including current demand. We would recommend the following modifications to the third paragraph of policy HC1 to ensure it is consistent with NPPF paragraph 82:
“On major development housing sites (excluding sites exclusively provided for self-build or custom housebuilding), the market housing should include a minimum of 70%of properties with 3 bedrooms or less, with the specific mix breakdown to be determined on a site-by-site basis and reflective of need identified in the council’s latest Housing Market Assessment, unless evidence is submitted to demonstrate otherwise”.

Object

Representation ID: 4919

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The housing mix as identified in the Council’s latest evidence base will only provide a snapshot in time in relation to the current housing needs.The requirement for 70% of market housing to have 3 bedrooms or less should be removed as it is overly prescriptive. Furthermore, the policy should also refer to other evidence, not just the latest Housing Market Assessment, and should include consideration of elements such as the demand/need at the time of the application.

Comment

Representation ID: 4925

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway support the core principle of these policies, to create “mixed, sustainable and inclusive communities”. However, the prescriptive minimum housing requirements
may risk providing the wrong type of housing for Wombourne residents and potentially impact on development viability and delivery.

As such, the policy should be reconsidered to ensure it accords with paragraph 82 of the NPPF and the need for policies to “be flexible enough to accommodate needs not
anticipated in the plan” and to “enable a rapid response to changes in economic circumstances.”

The policy should take a more flexible approach on housing mix to ensure it is consistent with NPPF paragraph 82’s need for policies to “be flexible enough to
accommodate needs not anticipated in the plan” and to “enable a rapid response to changes in economic circumstances.” It also needs to recognise that housing needs vary within different areas and on a site-by-site basis. The policy must ensure that the viability of development proposals is protected whilst providing an appropriate housing mix for the site location and local market. In addition to evidence such as the latest
Housing Market Assessment, it would be appropriate for the Council to refer to other evidence including current demand.

We would recommend the following modifications to the third paragraph of policy HC1 to ensure it is consistent with NPPF paragraph 82: “On major development housing sites (excluding sites exclusively provided for self-build or custom housebuilding), the market housing should include a minimum of 70% of properties with 3 bedrooms or less, with the specific mix breakdown to be determined on a site-by-site basis and reflective of need identified in the council’s latest Housing Market Assessment, unless evidence is submitted to demonstrate otherwise”.

Comment

Representation ID: 4942

Received: 23/12/2022

Respondent: AJM Planning Associates Ltd

Agent: AJM Planning Associates Ltd

Policy far too prescriptive and will lead to developments
of too similar character and blandness. There should be more flexibility built into the policies to allow for the individual circumstances of each site and its context.

Object

Representation ID: 4962

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

This policy seeks to increase the supply of 2 and 3 bedroom homes which Barratt supports. However, the policy then seeks for all major development housing sites to provide a minimum of 70% of properties to be 3 bedrooms or less. We note that this requirement has reduced from the 75% previously proposed in the Preferred Options plan. However, Barratt do not support applying a blanket requirement across the District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site (e.g. stating that ‘a greater amount of 1, 2 and 3 bed dwellings is encouraged’), it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals (Planning Practice Guidance (PPG) Reference ID: 61-038-20190315), site location and needs assessments at the time of the application in to account.

The Policy also states that “any development that fails to make efficient use of land by providing a disproportionate amount of large, 4+ bedroom homes compared with local housing need will be refused”. When stating ‘disproportionate’ does the Council mean anything above the 30% required under this policy? If it is, then we are not sure what benefit this part of the policy provides. The wording is negative and we therefore do not consider that it has been ‘positively prepared’ (NPPF paragraph 35).

Object

Representation ID: 4984

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

This policy seeks to increase the supply of 2 and 3 bedroom homes which Barratt supports. However, the policy then seeks for all major development housing sites to provide a minimum of 70% of properties to be 3 bedrooms or less. We note that this requirement has reduced from the 75% previously proposed in the Preferred Options plan. However, Barratt do not support applying a blanket requirement across the District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site (e.g. stating that ‘a greater amount of 1, 2 and 3 bed dwellings is encouraged’), it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals (Planning Practice Guidance (PPG) Reference ID: 61-038-20190315), site location and needs assessments at the time of the application in to account.
The Policy also states that “any development that fails to make efficient use of land by providing a disproportionate amount of large, 4+ bedroom homes compared with local housing need will be refused”. When stating ‘disproportionate’ does the Council mean anything above the 30% required under this policy? If it is, then we are not sure what benefit this part of the policy provides. The wording is negative and we therefore do not consider that it has been ‘positively prepared’ (NPPF paragraph 35).

Object

Representation ID: 5002

Received: 15/12/2022

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

In summary, whilst St Philips would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically derived District-wide housing mix. Indeed, the Housing Market Assessment is clear that the “profile set out is a guide to the overall mix of accommodation required in South Staffordshire although it is acknowledged that the Council may wish to divert away from this profile in particular instances” (Para 8.12). A degree of flexibility is encouraged by St Philips.
In this context, St Philips is concerned that Policy HC1 as it is drafted is unsound. Paragraph 82d of the NPPF requires that planning policies:
“be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.”
Furthermore, paragraph 62 of the NPPF states that “the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies”. As it is drafted, Policy HC1 is overly prescriptive and does not allow for sufficient flexibility to react to new evidence that suggests the districts housing needs have changed. Furthermore, the Councils district wide approach to housing mixes does not adequately assess the housing needs of different communities within the District.
St Philips therefore recommends that Policy HC1 be amended to allow for housing mixes to be justified based upon up-to-date market evidence of housing need and demand at the point of decision making. This would ensure that the PP is sound and compliant with paragraphs 62 and 82d of the NPPF.

Object

Representation ID: 5009

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey is concerned that Policy HC1 as it is drafted is unsound.

In summary, whilst Taylor Wimpey would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically derived District-wide housing mix. Indeed, the Housing Market Assessment is clear that the “profile set out is a guide to the overall mix of accommodation required in South Staffordshire although it is acknowledged that the Council may wish to divert away from this profile in particular instances” (Para 8.12). A degree of flexibility is encouraged by Taylor Wimpey.

Taylor Wimpey therefore recommends that Policy HC1 be amended to allow for housing mixes to be justified based upon up-to-date market evidence of housing need and demand at the point of decision making. This would ensure that the PP is sound and compliant with paragraphs 62 and 82d of the NPPF.

Object

Representation ID: 5013

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

In summary, whilst Taylor Wimpey would support the inclusion of a housing mix policy within the Local Plan Review, the Council should not be overly prescriptive in the application of a principally demographically derived District-wide housing mix. Indeed, the Housing Market Assessment is clear that the “profile set out is a guide to the overall mix of accommodation required in South Staffordshire although it is acknowledged that the Council may wish to divert away from this profile in particular instances” (Para 8.12). A degree of flexibility is encouraged by Taylor Wimpey
Taylor Wimpey therefore recommends that Policy HC1 be amended to allow for housing mixes to be justified based upon up-to-date market evidence of housing need and demand at the point of decision making. This would ensure that the PP is sound and compliant with paragraphs 62 and 82d of the NPPF.

Object

Representation ID: 5083

Received: 19/12/2022

Respondent: Barberry

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy HC1 housing mix states that on major development sites, the market housing mix ‘must’ include a minimum of 70% of properties with three bedrooms or less. We would prefer the wording of ‘must include’ to be amended to ‘should’ as such a target would place a disproportionate and inflexible burden on small and medium housebuilders who may be more inclined to provide bespoke homes with a higher specification for customers seeking larger homes.

We therefore do not consider this policy is consistent with NPPF para 82.

Object

Representation ID: 5099

Received: 21/12/2022

Respondent: St Philips

Agent: St Philips

Legally compliant? No

Sound? No

Duty to co-operate? Yes

St Philips is concerned that evidence provided within the Council’s latest Housing Market Assessment could quickly become out-of-date. The Council should therefore allow for housing mixes to be justified based upon evidence of housing need and demand at the point of decision making, rather than through a prescribed housing mix set out in the latest Housing Market Assessment.

Any current assessment of housing mix is likely to not reflect the changing demand for properties as a result of the Covid-19 pandemic and working from home practices. Furthermore, St Philips considers that the Councils approach to prescriptively apply a District-wide housing mix is inflexible and unsuitable when different areas will have differing requirements and demographic profiles.

St Philips recommends that housing mixes are based upon market signals and housing need and demand at the point of decision making.