Preferred Options November 2021

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The EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit and the Council intends to prepare an update prior to the Publication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.

Object

Representation ID: 1848

Received: 13/12/2021

Respondent: St Philips

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: 1849

Received: 13/12/2021

Respondent: St Philips

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.

Edge of Cannock
St Philips have concerns regarding the Council’s consideration of Wedges Mills and its ability to
accommodate growth. The Council’s PO document has not had due regard to the role that Cannock’s ‘higher order’ services have for the residents of settlements along its boundary, such as Wedges Mills.

Object

Representation ID: 1850

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Quotes the Hart Local Plan examination where the inspector raised concerns over a new settlement promoted within that Plan. The Inspector concluded that Plan established the ‘principle’ of the new settlement as the most appropriate growth strategy for meeting the Council’s long-term needs within a relatively confined area of search. However, he highlighted that the Plan had not tested other reasonable alternatives to a new settlement. As a result, he concluded that the policy, and therefore the new settlement, should be removed from the plan.
Taking the above together, St Philips consider that identifying a new settlement within this plan period is unnecessary, as it would not serve to meet the District’s, or GBBCHMA’s, housing needs in this plan period. Fundamentally, St Philips considers that the Council have provided insufficient justification for why such an approach is necessary, and invariably such an approach
is likely to be found unsound at EiP. To this end, St Philips considers that the Council should omit this policy from the draft Local Plan review as it is not necessary to make the plan sound.

Support

Representation ID: 1851

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

(b)
St Philips agree in principle with the requirement for a framework for the for future applications and infrastructure provision for the strategic residential allocations proposed with the PO.

Object

Representation ID: 1852

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

The Council’s [RSFA] identifies Wedges Mills as a Tier 5 settlement, and therefore does not propose any allocations within the settlement, or at all along the edge of Cannock.

The PPG and Friends of the Earth High Court judgment are clear that reasonable alternatives must be identified and assessed to provide adequate reasoning for why sites should be preferred or rejected in favour of alternative means.
St Philips welcome the Council’s recognition of the need to review the Green Belt to ensure that its housing needs, and a contribution to the GBHMA’s unmet needs can be met. St Philips has some concerns regarding the site selection process carried out and considers the methodology and assessment of individual sites to be flawed with regards to their land interests at Wolverhampton Road, Wedges Mills.

Object

Representation ID: 1853

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

St Philips site at Wolverhampton Road, Wedges Mills (Site ref: 202) has been assessed as part of the updated SA and HSSTP and discounted on the basis of Green Belt harm and landscape impact. However, St Philips contend that the developable area would not significantly extend beyond the current line of development along Wolverhampton Road, and would be contained within the existing tree-lined field boundary.
St Philips consider that it is entirely reasonable, and appropriate, for land which fulfils strong Green Belt purposes to be released where exceptional circumstances are evidenced. The site is located on the edge of Wedges Mills, which has high sustainability
credentials in terms of proximity to the existing shops and services in Cannock, and access to existing transport routes and infrastructure.

Support

Representation ID: 1854

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

Yes. St Philips supports the Council’s proposed allocation in draft Policy SA7. It is entirely logical to rationalise the consented WMI within the emerging Local Plan Review and remove it from the Green Belt.

Support

Representation ID: 1860

Received: 13/12/2021

Respondent: St Philips

Agent: Lichfields

(a)
Yes. St Philips agrees with the Council that the draft Policies set out in Policies DS1-DS4 and SA1-SA7 are strategic policies as defined by paragraph 21 of the NPPF.
(b)
No. St Philips do not consider that any of the draft policies set out in Chapter 6 should be identified as Strategic Policies.