Policy HC2: Housing Density

Object

Representation ID: 4157

Received: 21/12/2022

Respondent: CPRE West Midlands Regional Group

Legally compliant? No

Sound? No

Duty to co-operate? No

See objections to policies DS4 and DS5

Object

Representation ID: 4166

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 should be reworded to advise that the density requirement of 35dph is a“target” rather than a requirement. Density should be a product of good design and a policy should not prescribe density; a better approach is to consider density at the planning application stage.

As drafted, the policy suggests it would be accepted for the scheme to deliver at 35dph if it had an adverse, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate. In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework. NDSS requirements would also restrict density requirements.

Object

Representation ID: 4275

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 should be reworded to advise that the density requirement of 35dph is a“target” rather than a requirement. Density should be a product of good design and a policy should not prescribe density; a better approach is to consider density at the planning application stage.

As drafted, the policy suggests it would be accepted for the scheme to deliver at 35dph if it had an adverse, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate. In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework. NDSS requirements would also restrict density requirements.

Object

Representation ID: 4353

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocated sites have a far lower density than the minimum density given in Policy HC2 (20 - 25 dwellings per hectare rather than 35 dwellings per hectare).

Object

Representation ID: 4356

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.

Comment

Representation ID: 4471

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2
to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Due to the size of the site at Land East of Bilbrook and the lack of identified constraints, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of 35-40dph. However, this would be achieved through the provision of character areas of varying densities and would be reflective of the character of surrounding development, including
higher density development close to centrally located community facilities.

Comment

Representation ID: 4505

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Nevertheless, due to the size of the site at Wolverhampton Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of approximately 35dph. However, this would be achieved through the provision
of areas of varying density and reflective of the character of surrounding development.

Comment

Representation ID: 4535

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Nevertheless, due to the size of the site at Saredon Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of
35dph. However, this would be achieved through the provision of areas of varying density and reflective of the character of surrounding development.

Comment

Representation ID: 4561

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Nevertheless, due to the size of the site at Landywood Lane and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery if an efficient scheme that could achieve a minimum average net density of 35dph. However, this would be achieved through the provision of areas of varying density and reflective of the character of surrounding development.

Comment

Representation ID: 4585

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Due to the size of the site at Land at Cross Green and the lack of identified constraints, it is realistic to expect the delivery of an efficient scheme that could achieve a minimum average net density of 35-40dph. However, this would be achieved through the provision of character areas of varying densities and would be reflective of the character of surrounding development, including higher density development close to centrally located community facilities.

Comment

Representation ID: 4618

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The efficient use of land, in accordance with National Planning Policy and Guidance, is supported. The flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure, is welcomed.
Nevertheless, due to the size of the site at Four Ashes Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery
of an efficient scheme that could achieve a minimum average net density of 35dph. However, this would be achieved through the provision of areas of varying density and reflective of the character of surrounding development.

Object

Representation ID: 4633

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to Policy HC2 as written, as it is not justified. This policy looks for housing developments to achieve a minimum net density of 35 dwellings per net developable hectare within or adjoining Tier 1 settlements, in infill locations with the development boundaries of other settlements or in urban extensions to neighbouring towns and cities.

Clowes does not support this blanket approach, and consider that the determination of appropriate residential density to be a lot more nuanced than the proposed blanket designation taken by the Council. Greater flexibility is required to allow developers to take account of the evidence in relation to market aspirations, deliverability and viability and accessibility. There is a need for low to medium density housing to provide a balanced portfolio of sites to meet all market need, including executive style housing. As written this is not something that policy HC2 seeks to do and is therefore contrary to national policy and guidance.

Comment

Representation ID: 4674

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.

Comment

Representation ID: 4714

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the efficient use of land, in accordance with National Planning Policy and Guidance, and supports the flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.
Nevertheless, due to the size of the site at Pool House Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery
of an efficient scheme that could achieve a minimum average net density of 35dph (excluding the area of land beneath existing pylons). However, this would
be achieved through the provision of areas of varying density and reflective of the character of surrounding development.

Object

Representation ID: 4735

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

The requirement for a minimum of 35dph will create high density designs which are contrary to people's expectations, demands, and needs. Sites will have too much public open space (and associated maintenance/management costs) but lack adequate private garden space. New houses mostly suffer from this to achieve arbitrary density standards.

The policy should be reviewed to ensure the council are not in danger of creating poorer future housing conditions. The solution is to release more land when and where it is needed.

Object

Representation ID: 4761

Received: 19/12/2022

Respondent: Mrs Joanne Harding

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF considers that setting a single housing density target across the district is likely to be inappropriate, and that a nuanced range of residential densities specific to different areas of the district will be necessary. The HBF recommends amendments should be made to create greater flexibility to allow developers to take account of the evidence in relation to market aspirations, deliverability and viability and accessibility. Policies such as open space provision, biodiversity net gain, cycle and bin storage, housing mix, residential space standards, accessible and adaptable dwellings, energy efficiency and parking provision will all impact upon the density.

Object

Representation ID: 4802

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is unduly onerous. In some cases a lower density than 35 dwellings per net developable hectare will be appropriate when considering any on-site or off-site constraints, such as the historic environment, or where the related settlement character requires a lower density, particularly given the policy measures proposed in Policies HC8 and HC12.

Object

Representation ID: 4809

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

It is unclear whether the density requirement of 35dph applies to allocated sites adjoining non-Tier 1 settlements. This should be amended to provide clarification, and allow for more flexibility in line with paragraph 124 of the NPPF.

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.

Comment

Representation ID: 4943

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: 4963

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy proposes a minimum density of 35dph in developments within or adjoining Tier 1 settlements, in infill locations within the development boundaries of other settlements in the district or in urban extensions to neighbouring towns and cities. As set out in our response to Policy HC1, Barratt objects to a blanket approach to density being taken as it should be agreed on a site by site basis. However, it is appreciated that wording has been added to the policy to state that site context could be a consideration to deliver a lower density.

Object

Representation ID: 4985

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy proposes a minimum density of 35dph in developments within or adjoining Tier 1 settlements, in infill locations within the development boundaries of other settlements in the district or in urban extensions to neighbouring towns and cities. As set out in our response to Policy HC1, Barratt objects to a blanket approach to density being taken as it should be agreed on a site by site basis. However, it is appreciated that wording has been added to the policy to state that site context could be a consideration to deliver a lower density.

Object

Representation ID: 5054

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

This Policy is proposing a net site density level of 35 dwellings per hectare (dph) across sensitive greenfield sites within the districts’s countryside. This is fairly high-density residential development for sensitive greenfield sites within the open countryside, and will therefore result in future new housing development site layouts coming forward which would be heavily urbanised and therefore fail to deliver any meaningful on-site biodiversity/ nature conservation enhancement features and climate change mitigation benefits.
Such as reducing the Urban Heat Island Effect and promoting sustainable urban drainage. The heavily urbanised development which will be subsequently delivered will increase the urban heat island effect and increase surface water run-off rates and therefore increase flood risk pressures.
The Plan is therefore in direct conflict with climate change focused guidance reinforced within paragraphs 153 and 154 of the Revised NPPF (2021). These NPPF paragraphs expect emerging Local Plan Reviews to give serious planning policy consideration to the Climate Change Emergency and incorporate effective and meaningful measures which can help to increase an areas resilience to future climate change pressures. The emerging Local Plan Review is failing to do this.
The spatial planning approach to the future distribution of new housing and employment land development does not match the rhetoric within the climate policies within South Staffordshire Local Plan Review. The Publication Stage Report (November 2022) just pays lip service to these critically important climate change issues. These ongoing failures and low-quality development approach cannot be allowed to continue across the South Staffordshire District.
The Council is proposing huge levels of environmental damage across the local area which will make the local area less resilient to future climate change pressures, such as the urban heat island effect and flood risk from severe rainfall flash flooding events.
The position is perfectly clear, the emerging Local Plan Review (November 2022) is not promoting the most sustainable patterns of development, and the spatial planning Plan-making approach being taken by SouthSThe Plan is therefore in direct conflict with guidance in paragraphs 7, 8, 10, 11 (indent a), 16 (indent a), 35 (indent d), 38, 119, and 120 (indents d and e) of the Revised NPPF (2021).

Comment

Representation ID: 5084

Received: 19/12/2022

Respondent: Barberry

Agent: RCA Regeneration

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed most. This would also accommodate the need for higher density development within certain ‘character areas’ of larger multi-phase developments.

Object

Representation ID: 5116

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC2 is fundamentally flawed. Density should be a product of good design. It is not appropriate for the policy to refer to 35dph being a “minimum” requirement, it should be a target.
The policy advises that developments with a net density below 35 dph will only be supported if developing sites at 35 dph would “result in significant adverse impacts to the surrounding area or historic environment, settlement pattern or landscape character”. As drafted, this means it would be accepted for the scheme to deliver at 35dph if it had an “adverse”, but not a “significant adverse” impact on the historic environment, settlement pattern or landscape character. This is clearly inappropriate.
In terms of the historic environment, this approach would directly conflict with the guidance relating to designated and non-designated heritage assets set out in paragraphs 194 to 198 of the Framework.
In addition, if the Council pursues NDSS standards this will restrict the ability to deliver the proposed minimum density requirements particularly on smaller brownfield
sites that may be constrained.

Support

Representation ID: 5124

Received: 13/12/2022

Respondent: Seven Homes

Agent: RCA Regeneration

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed.

Support

Representation ID: 5138

Received: 19/12/2022

Respondent: St Philips

Agent: RCA Regeneration

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed most. This would also accommodate the need for higher density development within certain ‘character areas’ of larger multi-phase developments.

Support

Representation ID: 5150

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed.

Support

Representation ID: 5172

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Support the recognition that a blanket approach is unlikely to be effective.

Comment

Representation ID: 5235

Received: 21/12/2022

Respondent: Richborough Estates

Agent: RCA Regeneration Ltd

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed.