Preferred Options November 2021

Object

Representation ID: 1257

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Raises concerns that GBHMA Strategic Growth Study and Strategic Housing & Employment Land Availability Assessment aren’t included in evidence base.

The GBHMA Strategic Growth Study remains the latest comprehensive consideration of housing needs and locations to meet this need. It has been subject to scrutiny through the North Warwickshire Local Plan EiP and provides justification for the intended contribution of 4,000 homes to meet the identified housing shortfall. The SHELAA establishes a broad range of site options to be tested by the Council in establishing housing and employment allocations. The Self & Custom Build Register should be included to inform emerging housing need and mix policies.

The Green Belt Study parcels S71Cs2 and S71Bs2 should be amended to a ‘moderate’ harm rating to reflect site specific evidence. Land at Royal Farm has a lower score in Cannock’s Green Belt Study – the site’s ‘very high’ harm rating is disputed.

The Landscape Assessment parcel SL15 should be amended to ‘low-moderate’ to reflect scores under majority of assessment criteria.

Technical note provided which indicates that Land at Grange Farm, Coven could achieve a suitable access for up to 200 dwellings onto School Road, contradicting highways authority site comments.

Support

Representation ID: 1258

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The IDP identifies the correct infrastructure projects to support the proposed spatial strategy and may be updated to include site specific infrastructure requirements.

Land East of Bilbrook is a larger strategic proposal that can facilitate delivery of a 2FE First School, additional retail opportunities, green infrastructure enhancements, a new link road, improvements to Pendeford Mill Lane and pedestrian and cycling infrastructure.

Support

Representation ID: 1259

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The vision is clear but doesn’t appear locally relevant or spatially specific. The strategic objectives are succinct, locally relevant and relate to the most important areas of change or protection within the District. The draft and emerging policies will assist in delivering these objectives.

Support

Representation ID: 1260

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Support the acknowledgement that Green Belt boundaries require amendment to accommodate growth and deliver a sustainable spatial strategy. Agree that exceptional circumstances exist for Green Belt release. Safeguarded land should be considered to ensure Green Belt endures well beyond the plan period.

Object

Representation ID: 1261

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Unmet housing needs should be considered in setting the housing target and include shortfalls from the Birmingham Development Plan 2017, and the Black Country shortfall. These do not take into account the 35% uplift to housing needs applicable to Wolverhampton and Birmingham. The 4,000 home contribution appears reasonable and is justified by shared evidence produced by HMA LPAs.

Projected working age population growth in the SHMA doesn’t match projected job growth, which is significantly higher, especially when West Midlands Interchange job growth is considered. Further evidence is necessary to consider the balance between jobs and working age population age.

The settlement hierarchy and distribution of housing growth adjacent to the Black Country and in the most sustainable villages is supported. This aligns growth to Tier 1 and 2 settlements and the proposed employment strategy in an area more connected to major road and rail infrastructure. Concerns are raised that insufficient growth has been allocated in Tier 3 settlements to support existing services and facilities.

Insufficient growth is delivered on the western edge of the Black Country (390 dwellings) compared to the GBHMA Strategic Growth Study recommendations (500-2500 dwellings). Due to constraints within Cannock Chase District, future unmet needs may need to be accommodated on the edge of Cannock.

Support

Representation ID: 1262

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Highlight that even if a suitable or viable option were identified it would take a long time to masterplan and deliver alongside a much larger scale of infrastructure than other development. A new settlement should not be delivered at the expense of safeguarded land to provide a more permanent Green Belt boundary.

Support

Representation ID: 1263

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

The key infrastructure and design requirements set out in the policy for Land East of Bilbrook are supported. Bloor land interests cover the whole of the proposed East of Bilbrook site. Bloor do not consider it necessary to require a separate SPD for establishing site requirements and assessment frameworks. The requirement for site-specific SPDs has the potential to delay delivery of strategic housing allocations and duplicate information prepared through the masterplan and design code process.

Object

Representation ID: 1264

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Insufficient growth is delivered on the western edge of the Black Country compared to the GBHMA Strategic Growth Study recommendations (500-2500 dwellings). Sites 560 & 566 should be allocated to address this and safeguarded land identified for longer term Black Country housing needs.

Insufficient growth has been focused to Tier 3 settlements to support services and facilities.

Future safeguarded land should be identified for local housing needs and future unmet needs from neighbouring authorities. Land at Royal’s Farm should be considered for this purpose.

Object

Representation ID: 1265

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

HC1 – Requiring 75% of all market housing proposals to be three bedrooms or less is overly prescriptive. Flexibility for changing market signals should be allowed.
HC2 – Density should be reflected on a site-by-site basis.
HC3 – A Stage 2 assessment will be needed having regard to the full range of infrastructure and other policy requirements.
HC4 –The 30% M4(2) requirement is excessive compared to the SHMA evidence on need for accessible and adaptable homes and means bungalows are not required.
HC11 –Object to nationally described space standards, which must be fully evidenced.
HC14/15 – Recommend engagement with the CCG and SCC Education to inform future IDPs
HC17 – To avoid blanket inappropriate provision, distances should be identified to different open space typologies (e.g. LEAPs and LAPs) to ensure provision has regard to the wider area.
HC18 – Recommend engagement with Sport England and sports bodies to refine IDP.
EC3 – Concerns such plans will fail to reflect the business models of major housebuilders and reliance on sub contracting
NB2 – Policy should only require net gain in line with government policy which is not yet in place and should reflect government exemptions.
NB3 – Emerging evidence should inform policy.
NB6 – The Council does not need to set local energy efficiency standards to achieve net zero goal because of the 2021 Part L Interim Uplift and 2025 Future Homes Standard.

Support

Representation ID: 1266

Received: 13/12/2021

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Agree that the policies outlined are strategic. Requires final drafted policy wording to determine whether other policies are strategic.