Preferred Options November 2021

Support

Representation ID: 1867

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Whilst Taylor Wimpey considers that the evidence base is broadly appropriate, we have some concerns regarding the robustness of some of the documents within the evidence base, largely due to the passage of time.
The Council’s EDNA Part 1 EDNA is now markedly out of date in light of the implications of Covid-19 and Brexit.

Taylor Wimpey considers that the Council’s Staffordshire Housing Market Assessment [SHMA] requires an update to reflect the publishing of the most recent 2020 median work-place based affordability ratios.
Consider that further information needs to be provided in the Infrastructure Delivery Plan with regard to Health and Education provision.

Support

Representation ID: 1868

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

(a)
Whilst we agree that the appropriate types of infrastructure have been identified in the Infrastructure Delivery Plan [IDP] 2021, Taylor Wimpey considers that clarity needs to be provided on future requirements for health infrastructure. It is not clear whether existing schools in these areas have sufficient capacity to meet need or whether expansion will be necessary, as no
information on capacity or proposals for expansion have been identified. Taylor Wimpey would welcome clarity on this matter.

Support

Representation ID: 1870

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

(a)
Taylor Wimpey broadly agrees with the Objectives and considers that they would align with the economic, social and environmental goals and ambitions of the Framework.
However, Taylor Wimpey considers that the Council’s Strategic Objective 2 should explicitly refer to the Black Country Authorities [BCAs], rather than just the Greater Birmingham HMA.
(b)
Taylor Wimpey generally considers that the draft policies set out in within the SSLP would deliver the Strategic Objectives identified. However, Taylor Wimpey has some reservations regarding whether the Council’s proposed draft Policy DS3 (The Spatial Strategy to 2038) would
adequately deliver Strategic Objective 2.

Support

Representation ID: 1871

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Pool House Road, Wombourne
Taylor Wimpey fully supports the allocation of the site.

Object

Representation ID: 1872

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Land at Clent View Road, Stourbridge

Taylor Wimpey objects to the inclusion of land at Clent View Road, Stourbridge within the Green Belt boundary. The assessment of this part of the Green Belt in the evidence supporting the SSLP is also considered to be incorrect.
The site is suitable for Green Belt release and should be allocated for residential development.
The Site is contained within well-defined existing boundaries.
Having considered the findings of the SSGBS and the BCGBS, Taylor Wimpey considers that the land at Clent View Road would perform a more limited contribution to the five tests if it were to be reviewed on a site-specific basis.
Land at Clent View Road, Stourbridge represents a sustainable location for development which
does not make a valuable contribution to the purposes of the Green Belt when considered in isolation. The site would play an important role in meeting the need for housing land over the period to 2038

Object

Representation ID: 1879

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

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

The districts housing needs
Broadly supports the Council’s approach to assessing its minimum LHN. However 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: 1880

Received: 13/12/2021

Respondent: Taylor Wimpey

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, 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: 1881

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

The Unmet Housing Needs of the Greater Birmingham and Black Country Housing Market Area:
Welcomes the Council’s commitment to addressing part of the GBBCHMA unmet needs. However, they have 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: 1882

Received: 13/12/2021

Respondent: Taylor Wimpey

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.

Land at Clent View Road, Strourbridge
For the above reasons, Taylor Wimpey considers that additional housing land needs to be identified within the SSLP to meet need over the plan period. Taylor Wimpey considers that its land at Clent View Road, Stourbridge would be appropriate for allocation.

Support

Representation ID: 1883

Received: 13/12/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Wombourne
The proposed allocation of Taylor Wimpey’s site at Pool House Road, Wombourne (Site 285) in Policy SA5 is fully supported.