Preferred Options November 2021

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 The SHMA should also be updated to reflect the most recent LHN figure as it currently uses an outdated 254 dwelling figure.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: 1773

Received: 13/12/2021

Respondent: St Philips

This is not supported as it risks pre-determining the next local plan review and would not be found sound. This reflects findings of the Hart Local Plan which identified a new settlement in addition to other sites for beyond the plan period, which was found unsound. This approach does not reflect the need to test reasonable alternatives through the SA process.

Support

Representation ID: 1774

Received: 13/12/2021

Respondent: St Philips

Agree in principle with the requirement for a framework for future applications and infrastructure provisions for strategic allocations.

Object

Representation ID: 1775

Received: 13/12/2021

Respondent: St Philips

The previously safeguarded site 416 performs very similarly to the Green Belt element of Site 416, with the only difference being the Green Blet designation. If allocated the Green Belt element would not extend the site any further into the countryside and the Green Belt boundary is illogical and not clearly defined. The existing adjacent safeguarded land and previously developed land within the site does not appear to have been acknowledged in the Green Belt assessment. Lack of allocation of the remaining site may create access issues for Site 416. Given the need for 8,650 dwellings towards the GBBCHMA’s unmet needs there is a need to identify additional sites, in particular in Tier 2 settlements such as Wombourne. The land would contribute to the District’s small sites requirement.

Support

Representation ID: 1776

Received: 13/12/2021

Respondent: St Philips

Support the proposed allocation.

Object

Representation ID: 1777

Received: 13/12/2021

Respondent: St Philips

HC1 – Have concerns with inflexibility of policy. Market and affordable mixes by dwelling size should be included in policy and should reflect more up-to-date information where available. The approach isn’t flexible to respond to needs of different sub areas.
HC7 – Support the flexible approach adopted in the policy. Policy should explicitly set out evidence against which it would determine an ‘identified need’ to exist. The Council should publish annual data on level of demand and how it has met its statutory duty to provide suitable plots and reflect these in the draft policy.
HC11 – Support the principle of NDSS but only if the Council provides a local assessment evidencing the case for NDSS in accordance with the NPPF/PPG.
HC12 – Disagree with the proposed parking standards. Given the variety in future chargers and the need for flexibility the priority should be for the relevant cabling to be installed, not specific chargers.

Support

Representation ID: 1778

Received: 13/12/2021

Respondent: St Philips

Agree that policies DS1-4 and SA1-7 are strategic policies. Do not consider any of the draft policies in Chapter 6 are strategic policies.

Support

Representation ID: 1839

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Yes, in principle; however, St Philips has some concerns regarding the robustness of two documents within the evidence base, largely due to the passage of time. The Council’s ‘South Staffordshire EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit.

St Philips also consider that the Council’s SSHMA requires an update to reflect the publishing of the most recent 2020 median work-place based affordability ratios.

Support

Representation ID: 1841

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

(a)
Yes, St Philips considers that the Vision for what South Staffordshire will be like in 2038 is correct.
However, St Philips considers that, for clarity, the Council’s Strategic Objective 2 should explicitly refer to the Black Country Authorities [BCAs], rather than just the Greater Birmingham HMA.

(b)
In general, yes - St Philips considers that the draft policies set out within the PO would deliver the Strategic Objectives identified in the PO (Pg.24). However, St Philips has some reservations regarding whether the Council’s proposed draft Policy DS3 (The Spatial Strategy to 2038) would adequately deliver Strategic Objective 2

Object

Representation ID: 1842

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

St Philips do not support the development strategy contained within draft Policy DS1. The text implies that a Green Belt designation directly contributes to the ‘district's rural character’, which suggests Green Belt is a landscape designation. Green Belt is a policy designation. It is imperative that the Local Plan comprises a detailed Green Belt review, to ensure that development needs beyond the Plan period can be met.