Question 5

Support

Representation ID: 1629

Received: 13/12/2021

Respondent: Jaguar Land Rover UK

Agent: WSP

Yes, subject to the comments made below:
Jaguar Land Rover supports draft Policy DS3 and considers that the land surrounding the i54 site (including the Western Extension) should be continued to be supported for employment development.
However, housing development in close proximity to employment land should be carefully controlled to guard against any potential conflicts between uses. Jaguar Land Rover supports this safeguarding of employment land. It is proposed that draft Policy DS3 is amended to bring it in line with national policy (revised wording suggested on page 4).

Object

Representation ID: 1639

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: 1650

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.

Support

Representation ID: 1678

Received: 13/12/2021

Respondent: Mr J Barnes

In principle this makes sense subject to the appropriate selections of sites. You also cannot fairly re-allocate the categorisation of places (like you have with Lower Penn) without a proper consultation.

Support

Representation ID: 1687

Received: 13/12/2021

Respondent: Mrs Vicky Barnes

In principle this makes sense subject to the appropriate selections of sites. You also cannot fairly re-allocate the categorisation of places (like you have with Lower Penn) without a proper consultation.

Support

Representation ID: 1699

Received: 14/03/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Taylor Wimpey broadly supports the policy approach of Policy DS3

Object

Representation ID: 1700

Received: 14/03/2022

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: 1711

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: 1723

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: 1727

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips supports the general thrust of the Council’s preferred spatial strategy. However, St Philips has the below comments on draft Policy DS3, and the evidence base underpinning it, which St Philips consider would need to be addressed by the Council to ensure the policy is robust and sound.

The districts housing needs
Broadly, St Philips supports the Council’s approach to assessing its minimum LHN. However, as set out in St Philips representations to the SHSID, the Council should not utilise the c.750 dwelling completions already delivered in the district between 2018-2021. These should not form part of the Council’s housing need figure for the 2018/21 period. The Council should, therefore, update the assessment of its LHN to reflect the need across the whole plan period.

Object

Representation ID: 1728

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Uplifts to the minimum LHN figure
Both the NPPF and PPG are clear that the LHN figure generated by the standard method is a minimum
starting point. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing needs.

Affordable Housing
However, St Phillips notes that the Council’s affordable housing need, for its residents, actually equates to 53% of its LHN figure. Whilst it is true that the Council’s proposed annualised housing requirement (e.g. its LHN figure and GBBCHMA contribution) would enable it to meet its own affordable housing needs, the SSHMA does not appear to have given any consideration to whether the in-migration of households from the Black Country or Birmingham, resulting from this contribution, would also need affordable housing.

Economic Growth
The NPPF recognises the implicit link between economic growth and housing need, and that economic growth should not be decoupled from housing growth.
The EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit and the Council intends to prepare an update prior to the Publication
version of the Local Plan Review. The above highlights the clear need to ensure sufficient homes are delivered within the District to align with the anticipated job growth.

Object

Representation ID: 1729

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

The Unmet Housing Needs of the Greater Birmingham and Black Country Housing Market Area:
St Philips welcomes the Council’s commitment to addressing part of the GBBCHMA unmet needs. However, St Philips still has concerns regarding the Council’s derivation of its 4,000-dwelling contribution. It should be noted that the SGS has not been examined, and therefore the findings of the SGS carry little to no weight. At present, the Council’s current approach relies upon a document that clearly caveats its findings and has not been robustly tested through the examination process. The Council should prepare a robust and evidence-led approach to distributing the unmet
housing needs of the Black Country and Birmingham and test the outcomes of this through the SA process. South Staffs should contribute 8,650 dwellings towards the GBBCHMA unmet needs.

Object

Representation ID: 1730

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Sufficient Flexibility
Local Plans should be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a housing trajectory has sufficient land supply across the plan period. There is no scope within the Local Plan Review to respond to changing circumstances. The Council should apply a 10% buffer to the GBBCHMA contribution and the Council’s LHN figure.

The Spatial Strategy
Wheaton Aston is a relatively unconstrained settlement in terms of policy designations and other technical and physical constraints upon development and is located outside of the Green Belt. Despite being a Tier 3 village, it is considered that there are sufficient services and
infrastructure to support additional smaller-scale housing allocations.

Object

Representation ID: 1742

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: 1757

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

St Philips supports the general thrust of the Council’s preferred spatial strategy. However, St Philips has the below comments on draft Policy DS3, and the evidence base underpinning it, which St Philips consider would need to be addressed by the Council to ensure the policy is robust and sound.

The districts housing needs
Broadly, St Philips supports the Council’s approach to assessing its minimum LHN. However, as set out in St Philips representations to the SHSID, the Council should not utilise the c.750 dwelling completions already delivered in the district between 2018-2021. These should not form part of the Council’s housing need figure for the 2018/21 period. The Council should, therefore, update the assessment of its LHN to reflect the need across the whole plan period.

Object

Representation ID: 1758

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Uplifts to the minimum LHN figure
Both the NPPF and PPG are clear that the LHN figure generated by the standard method is a minimum
starting point. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing needs.

Affordable Housing
However, St Phillips notes that the Council’s affordable housing need, for its residents, actually equates to 53% of its LHN figure. Whilst it is true that the Council’s proposed annualised housing requirement (e.g. its LHN figure and GBBCHMA contribution) would enable it to meet its own affordable housing needs, the SSHMA does not appear to have given any consideration to whether the in-migration of households from the Black Country or Birmingham, resulting from this contribution, would also need affordable housing.

Economic Growth
The NPPF recognises the implicit link between economic growth and housing need, and that economic growth should not be decoupled from housing growth.
The EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit and the Council intends to prepare an update prior to the Publication
version of the Local Plan Review. The above highlights the clear need to ensure sufficient homes are delivered within the District to align with the anticipated job growth.

Object

Representation ID: 1759

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

The Unmet Housing Needs of the Greater Birmingham and Black Country Housing Market Area:
St Philips welcomes the Council’s commitment to addressing part of the GBBCHMA unmet needs. However, St Philips still has concerns regarding the Council’s derivation of its 4,000-dwelling contribution. It should be noted that the SGS has not been examined, and therefore the findings of the SGS carry little to no weight. At present, the Council’s current approach relies upon a document that clearly caveats its findings and has not been robustly tested through the examination process. The Council should prepare a robust and evidence-led approach to distributing the unmet
housing needs of the Black Country and Birmingham and test the outcomes of this through the SA process. South Staffs should contribute 8,650 dwellings towards the GBBCHMA unmet needs.

Object

Representation ID: 1760

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Sufficient Flexibility
Local Plans should be sufficiently flexible to adapt to rapid change. In practice, this means ensuring a housing trajectory has sufficient land supply across the plan period. There is no scope within the Local Plan Review to respond to changing circumstances. The Council should apply a 10% buffer to the GBBCHMA contribution and the Council’s LHN figure.

Object

Representation ID: 1772

Received: 13/12/2021

Respondent: St Philips

South Staffordshire’s LHN should be applied over the whole of the plan period, including retrospectively. The SHMA should also be updated to reflect the most recent LHN figure as it currently uses an outdated 254 dwelling figure. The SHMA should also be reviewed to consider whether a further uplift to meet affordable needs is required. 53% of South Staffordshire’s own LHN figure is affordable need, leaving 6 dwellings per annum towards the affordable needs of in-migrating households.

Agree that a review of the EDNA is necessary given the growth in the industrial and logistics sector and the evidence of shortfalls vs this demand in the region. Projected population growth would only meet a small proportion of the WMI jobs. Reliance on WMI to meet the Black Country employment need would lead to a very high proportion of in-commuting. Sufficient homes should be planned for to align with anticipated job growth, or risk reinforcing unsustainable commuting patterns. This should be considered through updates to the SHMA/EDNA.

Lichfields has undertaken work to examine the extent of the functional relationships across the GBBCHMA (December 2021), including breaking down the GBBCHMA into two sub-HMAs. This identifies that South Staffordshire should accommodate 25% of Black Country unmet needs and 7% of Birmingham unmet needs, equating to circa 8,650 dwellings to the GBBCHMA. This level of growth should be tested through SA.

To ensure plan flexibility, 10% headroom should be built into supply against the housing target. Wombourne is identified as being capable of accommodating further growth due to its facilities and good access to public transport, so growth on Wombourne edge would be the most appropriate strategy for accommodating further growth.

Object

Representation ID: 1784

Received: 13/12/2021

Respondent: John Davies Farms ltd.

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 settlements is considered to be inappropriate as it fails to recognise their sustainability, helping to protect and enhance their village centres.
Diminishing supply of brownfield land within settlements requires allocations in all settlements to meet demand arising from local community to support and enhance local community services in Tier 4 settlements.
It is unclear whether requirement for 10% of housing will be on sites less than 1ha, NPPF Paragraph 69 notes 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. Allocations in Tier 4 settlements can achieve this.

Support

Representation ID: 1791

Received: 13/12/2021

Respondent: WM Housing Associations

Agent: Tetlow King Planning

Support especially for directing growth to most sustainable locations, whilst accepting very limited growth in less sustainable areas. Understand approach of directing growth to Tier 1 settlements but Council should consider alternative rural locations for development where suitable to ensure that rural needs are met and required affordable housing provision is delivered.
Support for inclusion of strategic development sites, but should consider a more flexible approach. If enough affordable homes are to be delivered, Council should assess proposals on case by case basis, affordable housing may have to be located in range of locations. Small sites just as important to (affordable) housing delivery and can be delivered much quicker.

Object

Representation ID: 1806

Received: 06/12/2021

Respondent: Persimmon Homes

Agent: RPS Group

The local assessment of housing need should be revisited to account for 8,550 jobs growth provided for by WMI and the potential employment land oversupply of 254-273 hectares in the District.

Events have moved on since the Strategic Growth Study (SGS) was published in 2018, with the Black Country’s need increasing and supply diminishing over a different timescale to the SGS’s preparation. The Black Country’s unmet need has not been appropriately factored into the housing requirement or the strategic locations in the SGS. The rural services and facilities audit fails to take into account Hilton Cross and ROF Featherstone in assessing access to employment. The spatial strategy fails to give sufficient consideration to co-locating jobs and housing, particularly in the Featherstone area. As the SGS may have underestimated unmet housing needs the employment-led area of search should be widened to include Featherstone.

Support

Representation ID: 1809

Received: 07/12/2021

Respondent: Jones Appleby and Dorsett

Current landowners wish to promote their land at the rear of Sneyd Lane, Essington for residential development. Site promotion is being submitted to be registered as part of the Strategic Housing and Employment Land Availability Scheme.

Spatial Strategy
Recognising the existing and emerging shortfalls, identifies the need to provide a housing target of 8845 dwellings between 2018 and 2037. Option G from the 2019 Local Plan Review shows 13.5% of the housing needs to be met along the boundary of Essington/Great Wyrley, whereby, the land rear of Synd lane will help to deliver the unmet need.

Object

Representation ID: 1814

Received: 13/12/2021

Respondent: IM Land

Agent: RPS Group

Paragraph 4.25 should be amended to allow for design-led approaches that can demonstrate increased levels of housing growth are suitable and deliverable. The RSFA fails to take account of the close proximity to facilities in Cannock via walkable routes. If these facilities are taken into account Huntington would score ‘green’ rather than ‘amber’ on criteria B.1.

Object

Representation ID: 1817

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

Concerns raised of the start date of the Local Plan being based on anticipated timescale for publication of the plan, rather than written, suggests the start date being 2022 or 2023. Suggestion for the Local Housing Need to be kept under review and altered where necessary through the plan making process until the point of submissions for examination.

Object

Representation ID: 1821

Received: 13/12/2021

Respondent: Bloor Homes Ltd

Agent: Marrons Planning

NPPG requires consideration to the appropriateness and likely market attractiveness for the type of development proposed. Bloor Homes puts emphasis that Wombourne has a very strong demand for development in high values areas and the Council's Viability Study 2021 identifies the market values in Locality 5 to be amongst the higher in the Plan area making the site viable. Suggestion on this basis, it is readily apparent that Wombourne should be considered a Tier 1 settlement, commensurate with the Plan’s infrastructure led strategy, and further growth directed towards it accordingly

Support

Representation ID: 1831

Received: 10/12/2021

Respondent: Wollaston Properties Ltd

Agent: First City Limited

Support the spatial strategy set out in policy DS3: The Spatial Strategy.

Bilbrook has the capacity to accommodate further development and consider the site 211: the land north of Manor House Park should be included as an allocated site or at least a safeguarded site to assist with meeting the current and future needs of Bilbrook.

As a minimum we consider site 211: the land north of Manor House Park should be identified as safeguarded land for future development.

Object

Representation ID: 1838

Received: 13/12/2021

Respondent: Peveril Securities ltd.

Agent: Mr Simon Chadwick

Combination of existing and proposed strategic employment sites will result in a concentration of a large number of jobs; housing development strategy for scale and provision of dwellings needs to be at a quantum and location to promote sustainable development.
Continue the policy of safeguarding land to provide further housing convenient to M54 corridor and southern part of District, close to Strategic Employment Sites.
Targeted review of GB boundaries that identifies sites, and allocation of them, should they be needed if additional housing needs arose or problems arise with delivery.
Proposed housing provision represents only additional 8% above 8,881 dwellings which does not represent sufficient flexibility when 10% of all permissions 'fall out'.
Allocation of a further 400/500 dwellings should be made as a suitable quantum of reserve deliverable land as current proposals do not constitute significant boost to NPPF required housing supply.
Review the capacity of Featherstone (and periphery) to accommodate a proportion of housing needs due to its location to strategic employment sites.

Object

Representation ID: 1846

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

St Philips supports the general thrust of the Council’s preferred spatial strategy. However, St Philips has the below comments on draft Policy DS3, and the evidence base underpinning it, which St Philips consider would need to be addressed by the Council to ensure the policy is robust and sound.

The districts housing needs
Broadly, St Philips supports the Council’s approach to assessing its minimum LHN. However, as set out in St Philips representations to the SHSID, the Council should not utilise the c.750 dwelling completions already delivered in the district between 2018-2021. These should not form part of the Council’s housing need figure for the 2018/21 period. The Council should, therefore, update the assessment of its LHN to reflect the need across the whole plan period.

Object

Representation ID: 1847

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Uplifts to the minimum LHN figure
Both the NPPF and PPG are clear that the LHN figure generated by the standard method is a minimum
starting point. Therefore, the Council should actively identify whether there are reasons for testing higher figures as estimates of housing needs.

Affordable Housing
However, St Phillips notes that the Council’s affordable housing need, for its residents, actually equates to 53% of its LHN figure. Whilst it is true that the Council’s proposed annualised housing requirement (e.g. its LHN figure and GBBCHMA contribution) would enable it to meet its own affordable housing needs, the SSHMA does not appear to have given any consideration to whether the in-migration of households from the Black Country or Birmingham, resulting from this contribution, would also need affordable housing.

Economic Growth
The NPPF recognises the implicit link between economic growth and housing need, and that economic growth should not be decoupled from housing growth.
The EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit and the Council intends to prepare an update prior to the Publication
version of the Local Plan Review. The above highlights the clear need to ensure sufficient homes are delivered within the District to align with the anticipated job growth.