Preferred Options November 2021

Support

Representation ID: 1755

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(a)
St Philips agrees with the Council’s proposed Strategic
Objectives. 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: 1756

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(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: 1757

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: 1758

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: 1759

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: 1760

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.

Object

Representation ID: 1761

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.

Support

Representation ID: 1762

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(a)
Yes, St Philips fully support the proposed strategic housing allocations in policies SA1-SA4, with specific reference to draft Policy SA4 (Strategic development location: Land North of Penkridge) for the 1,129 dwellings.
Penkridge remains a Tier 1 settlement within the Spatial Strategy contained at PO Policy DS3 (The Spatial Strategy to 2038). By virtue of this categorisation, the settlement is a one of the most sustainable locations for future housing development, and is well-equipped to
accommodate significant levels of growth.
Whilst St Philips are generally supportive of the infrastructure identified to be delivered through
the policy, however, their comments in response to Question 2a

Support

Representation ID: 1763

Received: 13/12/2021

Respondent: St Philips Land Ltd

Agent: Lichfields

(b)
Yes, St Philips agree in principle to the requirement for a framework for future applications and infrastructure provision for the strategic residential allocations proposed with the PO. However, St Philips do not agree with the requirement for a Supplementary Planning Document
[SPD] to support the delivery of the proposed strategic residential allocation. St Philips suggest that the wording of the policy is amended to require the preparation of a
strategic masterplan by the respective landowners/ developers forming the allocation. Alternative wording suggested.

Support

Representation ID: 1764

Received: 13/12/2021

Respondent: St Philips Land Ltd

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.