Preferred Options November 2021

Support

Representation ID: 1706

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

Yes, in principle; however, St Philips has some concerns regarding the robustness of two documents within the evidence base.

Object

Representation ID: 1715

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

The Council’s EDNA and employment topic paper are now markedly out of date in light of the implications of Covid-19 and Brexit; albeit, it may be that the Council’s forecast job growth may have increased compared to the forecasts from Oxford Economics in 2018.

Accordingly, the Council should update these documents, particularly given that these are core and critical pieces of the Council’s evidence base, to ensure that the Local Plan Review complies with the NPPF.

Council will need to update the SSHMA to reflect the latest workplace-based earnings ratios.

Support

Representation ID: 1716

Received: 13/12/2021

Respondent: St Philips Land Ltd

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.

Support

Representation ID: 1717

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(b)
In general, yes, St Philips considers that the draft policies set out in 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: 1718

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

t 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, and its purposes is to prevent urban sprawl as opposed to providing protection for rural character and
landscape. It is therefore imperative that the Local Plan
comprises a detailed Green Belt review, to ensure that development needs beyond the Plan period can be met.

Object

Representation ID: 1727

Received: 13/12/2021

Respondent: St Philips Land Ltd

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: 1728

Received: 13/12/2021

Respondent: St Philips Land Ltd

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: 1729

Received: 13/12/2021

Respondent: St Philips Land Ltd

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: 1730

Received: 13/12/2021

Respondent: St Philips Land Ltd

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.

The Spatial Strategy
Wheaton Aston is a relatively unconstrained settlement in terms of policy designations and other technical and physical constraints upon development and is located outside of the Green Belt. Despite being a Tier 3 village, it is considered that there are sufficient services and
infrastructure to support additional smaller-scale housing allocations.

Object

Representation ID: 1733

Received: 13/12/2021

Respondent: St Philips Land Ltd

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.