Preferred Options November 2021

Support

Representation ID: 1076

Received: 09/12/2021

Respondent: St Philips

Agent: Pegasus Group

No objection - policies are strategic in their nature.

Object

Representation ID: 1326

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

- Strategic Objective 1: Concerned at the lack of clarity of how this objective will be delivered; unlikely that most developers will have control over other land parcels. Do not consider this objective deliverable.
- Strategic Objective 2: It is unclear how this contribution is disaggregated across the HMA. Details of agreements made under the Duty to Co-operate should be included in the evidence base.
- Strategic Objective 9: Strategy relies on new rail stations but rail is not mentioned in the objective – suggest this is amended. The importance placed upon rail does not reflect some of the sites selected.

Object

Representation ID: 1327

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

Policy DS1 repeats the Framework and could be – in part – removed. On-site green infrastructure can be delivered but compensatory improvements create uncertainties for landowners and developers and are unlikely to be deliverable. It is unclear how development in the Green Belt could maintain its character and openness. Encourage the Council to set out the exceptional circumstances required to remove sites from the Green Belt.

Policy DS2 – It is unclear what forms of development would or would not be acceptable in open countryside. The policy wording as a whole should be revisited.

Object

Representation ID: 1328

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1329

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

Why is the policy included when it applies to a time period outside the scope of the plan -why not extend the plan period instead?

Object

Representation ID: 1330

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

Policy SA2 – Delivery of the site is heavily reliant on the ‘Land at Cross Green SPD’ and there is no clear justification to demonstrate that this allocation can be implemented. As there is no clear timeline for delivery the plan should allocate further sites to ensure it can meet the 8,881 dwelling housing target.

Object

Representation ID: 1331

Received: 09/12/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC14 – Policies should clarify that new development should not solve existing infrastructure issues.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.

Object

Representation ID: 1769

Received: 13/12/2021

Respondent: St Philips

Generally support but have concerns regarding the robustness of the Employment Sites: Site Assessment Topic Paper and EDNA, which are markedly out of date and don’t reflect COVID-19 and Brexit. The SHMA also needs to be updated to reflect the latest affordability ratios. The SHMA also relies heavily on demographic trends in establishing required market and affordable mixes and does not have regard to market demand and trends or the impact of COVID-19 on demand for additional living space. Costs of EV chargers in the Viability Study should be increased to £976 per dwelling in line with estimated government costs.

Support

Representation ID: 1770

Received: 13/12/2021

Respondent: St Philips

Yes – but Strategic Objective 2 should explicitly refer to the Black Country Authorities, not just the GBHMA, as the issue of addressing unmet need is no longer being addressed at the GBHMA level by Birmingham and the Black Country and two separate unmet needs for different HMA sub-areas should be identified. Have concerns that Strategic Objective 2 would not be delivered by Policy DS3.

Object

Representation ID: 1771

Received: 13/12/2021

Respondent: St Philips

Do not support DS1. The district’s rural character is not relevant to Green Belt. Paragraphs 4.2 – 4.3 fail to specify that exceptional circumstances are required to alter Green Belt boundaries. The policy should have regard to the need to release further Green Belt to address the GBBCHMA unmet housing need over the plan period and beyond.