Question 5

Object

Representation ID: 1349

Received: 10/12/2021

Respondent: Mr - Cox & Jenks

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA.
HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire.
No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population.
Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall.
Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country.

Support

Representation ID: 1350

Received: 10/12/2021

Respondent: Mr - Cox & Jenks

Agent: PlanIt

Support the Plan's recognition that Tier 1 settlement such as Bilbrook/Codsall are suitable locations for growth and additional proportionate development.

Object

Representation ID: 1359

Received: 13/12/2021

Respondent: Jay Farm Homes and Lawnswood Homes

Agent: SLR Consulting Ltd

NO – the proposed Spatial Strategy within the Preferred Options consultation does not reflect that which was identified within Option G of the previous Spatial Housing Strategy & Infrastructure Delivery consultation. Option
G previously identified that 8.5% of the housing need (c. 750 units) should be provided along the western edge
of the Black Country urban areas (Wolverhampton and Dudley).
Whilst there is a reduced unmet need from the adjoining Dudley area, this reduction is not reflective of the
unmet housing needs associated with, and allocations needed to support, the Wolverhampton authority area.
Further sites should either be allocated or safeguarded along the western edge of the Wolverhampton urban
area to ensure housing needs are met now and beyond the current plan period.

Object

Representation ID: 1368

Received: 20/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Table 8 should be included in the policy. Broadly support the policy approach in Policy DS3 but concerned that the housing target may be insufficient. The overall unmet need across the GBBCHMA is well in excess of 66,000 homes and SSDC should co-operate with other authorities within the GBBCHMA to ensure that the level of contributions made collectively is sufficient to collectively meet the shortfall. The SHMA currently fails to consider whether the minimum need figure from the standard method would support enough workforce growth to support planned job growth. Richborough Estates does not support limiting new allocations at Perton to only the safeguarded land. Featherstone could support further growth as it is located less than a mile away from a proposed strategic site (646a&b) and could support nearby employment opportunities.

Object

Representation ID: 1380

Received: 13/12/2021

Respondent: Roundleaf Limited

Agent: Cerda Planning

Contend that Policy DS3 – The Spatial Strategy to 2038 requires some redrafting to ensure that the delivery of the homes presently identified for allocation through the Local Plan review should be much closer to the identified minimum need having full regard to the requirement to increase the contribution towards the unmet needs arising from GBBCHMA overspill.

There is an over reliance on large strategic sites in the plan.

Object

Representation ID: 1381

Received: 09/12/2021

Respondent: Mrs Pamela Aust

Projected shortfall may not be as high as expected. Updated analysis should be obtained before making any decisions as we believe the numbers of houses being proposed within South Staffordshire is in excess of the true housing requirement.

Support

Representation ID: 1387

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Taylor Wimpey broadly supports the policy approach of Policy DS3. However, it remains a concern that the 8,881 dwellings proposed through the LPR may be insufficient. Allocation at Linthouse Lane not only assists in providing improved infrastructure but also has due regard to where housing needs exist, including within locations close to
the Black Country conurbation where a 28,239-home shortfall in provision has been identified.

Object

Representation ID: 1389

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Concerned that dwellings proposed through consultation are insufficient. South Staffordshire's need based on the standard method which should be treated as a minimum. May require an economic uplift particularity in light of WMI, i54 and ROF Featherstone employment proposals. No clear evidence that the housing proposed would be enough to support projected job growth. Overall need in GBHMA likely to be well in excess of 66000 homes.

Object

Representation ID: 1397

Received: 13/12/2021

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Contend that Policy DS3 – The Spatial Strategy to 2038 requires some redrafting to ensure that the delivery of the homes presently identified for allocation through the Local Plan review should be much closer to the identified minimum need having full regard to the requirement to increase the contribution towards the unmet needs arising from GBBCHMA overspill. The Plan is over reliant on a small number of strategic sites.
There has been very limited housing development in Bishops Wood in recent years.

Object

Representation ID: 1399

Received: 13/12/2021

Respondent: Mr D Parton

Number of people: 2

Agent: AJM Planning Associates Ltd

Large allocations put the delivery of majority of housing requirement in hands of large developers who could dictate supply. Strategy should deliver more growth around the edge of settlements in sustainable and deliverable locations.
Strategy should provide for further GB release as safeguarded land within higher tier settlements to meet requirements post-2038 in accordance with NPPF Paragraph 140.

Object

Representation ID: 1413

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support the policy approach in Policy DS3. Paragraph 4.16 of the supporting text to policy DS3 states that the spatial strategy has been amended since the last consultation in December 2019 to reduce the amount of growth allocated to the western edge of the Black Country, reflecting the relatively limited unmet need arising from Dudley. However, having reviewed the Black Country Local Plan evidence base, it is clear that the majority of Dudley’s Green Belt that is not proposed to be released for development has constraints present on it that prevents development, such as historic landscape designations. there is shortfall between the 4,000
figure stated to be provided to the GBHMA , and the 2,958 dwellings that are planned to be located adjacent to the Black Country. The allocation of more sites adjoining the Black Country, such as Lawnswood Road (site 654) would aid this. The spatial strategy should therefore be amended to place more emphasis on the delivery of dwellings adjoining the Black Country.

Object

Representation ID: 1427

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Policy contains only a single paragraph relating to housing development, based on out-of-date employment evidence. The policy should recognise the potential for additional employment land to come forward in combination with strategic employment sites like WMI, recognising the ability to use new infrastructure from that site.

Object

Representation ID: 1433

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Council has not proposed an uplift to the minimum standard method figure to meet local needs nor has the Strategic Housing Market Assessment (‘SHMA’) May 2021 assessed the requirement for an uplift. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraph 16) nor does it support the Government’s
objective of significantly boosting the supply of homes (NPPF paragraph 60).
The NPPF also requires plans to “be able to demonstrate that Green Belt boundaries will not need to be altered
at the end of the plan period” (paragraph 143). Given our comments above, we consider that additional Green
Belt land will be required within the plan period so therefore the plan does not accord with the NPPF.

Therefore, additional sites should be identified within the District in order to meet these additional housing needs. We consider that our client’s land (site reference 500) forms a logical extension to proposed Strategic Allocation SA1 and should be considered for a residential allocation to assist the Council in meeting their housing needs.
We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (Reference ID: 61-020-20190315).

Object

Representation ID: 1443

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

Table 8 should be included in the policy. Broadly support the policy approach in Policy DS3 but concerned that the housing target may be insufficient. The overall unmet need across the GBBCHMA is well in excess of 66,000 homes and SSDC should co-operate with other authorities within the GBBCHMA to ensure that the level of contributions made collectively is sufficient to collectively meet the shortfall. The SHMA currently fails to consider whether the minimum need figure from the standard method would support enough workforce growth to support planned job growth. Richborough Estates does not support limiting new allocations at Perton to only the safeguarded land. Featherstone could support further growth as it is located less than a mile away from a proposed strategic site (646a&b) and could support nearby employment opportunities.

Object

Representation ID: 1462

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Council has not proposed an uplift to the minimum standard method figure to meet local needs nor has the Strategic Housing Market Assessment (‘SHMA’) May 2021 assessed the requirement for an uplift. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraph 16) nor does it support the Government’s
objective of significantly boosting the supply of homes (NPPF paragraph 60).
The NPPF also requires plans to “be able to demonstrate that Green Belt boundaries will not need to be altered
at the end of the plan period” (paragraph 143). Given our comments above, we consider that additional Green Belt land will be required within the plan period so therefore the plan does not accord with the NPPF. n light of the above, we consider that an uplift should be applied to the minimum standard method figure of
243 dwellings per annum and the proposed contribution towards the HMA should be updated to reflect the
additional housing shortfall identified by the Black Country authorities. Therefore, additional sites should be
identified within the District in order to meet these additional housing needs. We consider that our client’s land (site reference 549 and 550) form a logical extension to Kinver, are accessible and should therefore be allocated to assist the District in meeting its housing needs.
We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (Reference ID: 61-020-20190315)

Object

Representation ID: 1476

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Savills

The evidence base includes a duty to cooperate (DTC) topic paper but not a statement of common ground of
progress to date with an agreed strategy going forward. The plan does not currently comply with the duty to
cooperate as a result and there is evidence within the Preferred Options Plan (POP) and the DTC Topic
Paper, that cross boundary needs have not been adequately defined. Lack of evidence of South Staffordshire’s employment land needs and lack of proper engagement with all neighbouring authorities.

Object

Representation ID: 1480

Received: 07/12/2021

Respondent: FGD Ltd

Agent: Savills

Consider that an uplift should be applied to the minimum standard method figure of 243 dwellings per annum
in order to fully meet local needs. In addition to this, the proposed contribution towards the HMA should be
updated to reflect the increases shortfall arising from Birmingham’s 35% standard method uplift and the
additional housing shortfall identified by the Black Country authorities. If additional sites
are released from the Green Belt and allocated to meet any requirement increase, Site 577 is immediately
adjacent the edge of the Black Country conurbation and scored well in the Site Assessment, we consider that
it is suitably placed to meet this housing need. In regards to employment, the Preferred Options document states that there is a need for 67-86ha of employment land across the plan period and that the District has an identified supply of 340 ha which the Council is primarily relying on being met by Strategic Allocation SA7 – West Midlands Interchange (297ha). We strongly object to this on the basis that this proposal was intended to be delivered to meet a national / regional employment requirement that simply a local need which should be met using a smaller range of site types and locations. Further clarity is sought from the Council on this matter. Should additional land be required, the Site 577 is considered to be a suitable location for employment uses.

Object

Representation ID: 1485

Received: 10/12/2021

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Housing Requirement - Housing requirement proposed is below the standard method figure that is derived from the Council's own HMA. HMA fails to correctly factor in affordable housing need and whether an uplift is required. The 4000 dwellings will have its own affordable housing requirement separate to that of South Staffordshire. No consideration given to uplifting the standard method to take account of economic growth aspirations and increasingly ageing population.
Strategic Housing Growth Study is out of date and does not use the standard method. there is more up to date evidence available on the housing shortfall.
Birmingham's assertion that their shortfall has reduced should be treated with caution. Together with the Black Country shortfall 66139 dwellings should be considered the absolute minimum. South Staffs proposes 4% of the shortfall, this is unacceptable. Should be taking more given the functional relationship with the Black Country. Insufficient capacity in other GBHMA authorities to absorb shortfall and South Staffordshire should be taking a greater proportion given its functional relationship with the Black Country. The plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation.

Object

Representation ID: 1504

Received: 13/12/2021

Respondent: D Morgan PLC

Agent: Peacock and Smith

No. D Morgan PLC supports locating growth in the most sustainable locations, and although Policy DS3 appears to agree with this approach, the strategy has not been implemented in the manner stated; many proposed allocations are in locations that are not sustainable. Suggests wording changes to DS3. We request that the Council implements its strategy as it sets out in Strategic Objective 2 and Policy DS3, with growth being located in the most sustainable Tier 1 settlements. Failure to direct growth to these most sustainable locations will inevitably result in unsustainable development and isolated communities, something which Strategic Objective 2 and Policy DS3 and national policy seeks to avoid.

Support

Representation ID: 1538

Received: 13/12/2021

Respondent: Boningale Homes ltd.

Agent: Alder King

Support the classification of Codsall/Bilbrook as Tier 1 settlement.

Object

Representation ID: 1539

Received: 13/12/2021

Respondent: Boningale Homes ltd.

Agent: Alder King

An appropriate level of growth can be facilitated in settlements lower down the hierarchy which have close ties to higher tier settlements.
Further growth should be directed towards Codsall/Bilbrook beyond proposals in Policies SA1 and SA5.

Support

Representation ID: 1550

Received: 13/12/2021

Respondent: Boningale Homes ltd.

Agent: Alder King

Support the proposals to bring forward previously identified safeguarded land for residential development.
Support principle spatial aim to direct growth to accessible/sustainable locations based upon Settlement hierarchy.

Object

Representation ID: 1554

Received: 13/12/2021

Respondent: Boningale Homes ltd.

Agent: Alder King

Further growth should be attributed to Codsall/Bilbrook beyond current proposals in policies SA1 and SA5 to ensure confidence in housing delivery as scale of uplift based on historic trends causes concern, and safeguard land for next LP review.

Object

Representation ID: 1566

Received: 13/12/2021

Respondent: Mr Nigel Babb

The 18% population growth is too high, and exceeds the supposed 40% cap on increase in housing in the new planning cycle as stated above.

Support

Representation ID: 1575

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

South Staffordshire’s overall spatial strategy to 2038 is supported insofar as it seeks to deliver a minimum of 4,881 dwellings for the district’s own needs, plus a contribution of 4,000 dwellings towards meeting the GBBCHMA shortfall.

The key strand underpinning the spatial strategy that growth is distributed to the South Staffordshire’s most sustainable locations to avoid a disproportionate level of growth in the less sustainable settlements is also supported. This reflects the requirements of the NPPF.

Approach to small and medium sites
10% of housing growth is to be delivered on sites of less than one hectare. This is reflected in Kinver being identified to accommodate 2.5% of the District’s total need. This includes two new proposed allocations (beyond the existing safeguarded site), both of which total 1ha in area. Firstly, we welcome the proposed release of land at Hyde Lane (west) (site 576 under draft policy SA5) from the Green Belt and allocation for housing growth. However, there needs to be some flexibility in the Council’s application of NPPF paragraph 69a) and the 10% provision of sites of 1ha.

Object

Representation ID: 1576

Received: 13/12/2021

Respondent: Bellway Homes Limited (Hyde Lane site)

Agent: Turley

The plan period should therefore be extended to reflect that NPPF paragraph 22 states that strategic policies should look ahead over a minimum 15 year period from adoption.

In response to Q2 we have identified some concerns regarding the potential delivery of infrastructure required to support the Cross Green (draft policy SA2) and that this could impact any trajectory for housing delivery at the site. he Council should therefore consider whether there would be merit in identifying a greater quantum of development on allocations or safeguarded land to provide a ‘fail safe’ option.

Support

Representation ID: 1579

Received: 13/12/2021

Respondent: Trebor Developments

Agent: Avison Young

Support the proposals to bring forward previously identified safeguarded land for residential development in order to build in greater flexibility into the plan which is not going to be secured in the short/medium term through a new settlement.

Object

Representation ID: 1581

Received: 13/12/2021

Respondent: Trebor Developments

Agent: Avison Young

Strategic Growth Study does not consider potential impact of "35% urban uplift" in the calculation of housing need thus increasing the HMA shortfall. More flexibility should be built into meeting future development needs.
Table 8 - although demonstrates a 13% 'buffer' - is not a sufficient demonstration of proposed allocations providing a rolling 5YHLS at adoption.

Support

Representation ID: 1608

Received: 06/01/2022

Respondent: Four Ashes Road LTD

Agent: Miss Rebecca Allen

FAR Ltd supports the policy approach in Policy DS3 (The Spatial Strategy to 2038). By allowing growth in the Tier 1 and Tier 2 settlements will provide an opportunity to meet locally arising housing needs and offers opportunity to deliver new services, facilities and infrastructure.

The Spatial Strategy provides the opportunity to ensure that the necessary homes, along with supporting infrastructure. Allocations made in the Local Plan represent high-level options to inform a preferred spatial strategy for housing growth.

Object

Representation ID: 1620

Received: 13/12/2021

Respondent: Bradford Estates

Agent: Berrys

The contribution provided to the GBBCHMA housing shortfall may need to rise as ABCA representation to Shropshire Regulation 19 consultation indicates. Additional release of land in South Staffordshire is required to meet Black Country needs.
Level of growth in Tier 4 and 5 settlements is considered to be inappropriate as it fails to recognise their sustainability, helping to protect and enhance their village centres. Failing to plan for Tier4 and Tier 5 settlements will result in the need for housing arising form their local communities being unmet.
Paragraph 4.16 of the consultation document indicates that housing allocations are not required in Tier 4 or Tier 5 settlements to meet the national requirement for 10% of housing growth to be delivered on sites no larger than 1ha. This is contrary to NPPF Paragraph 69 where the 10% requirement is a minimum figure and the allocation of such sites to meet this is necessary for the plan to be found sound.