Preferred Options November 2021

Object

Representation ID: 1430

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

In addition to those evidence documents listed, we consider that an Urban Capacity Report to highlight the
limited number of deliverable sites within the urban area and outside of the Green Belt may be beneficial to
justify why Green Belt sites are being allocated for development. A Green Belt Topic Paper setting out the
exceptional circumstances which the Council consider exist to justify the release of Green Belt could also be
appropriate to support the Council’s strategy at Examination.

Object

Representation ID: 1431

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Duty to Cooperate Paper (November 2021)
South Staffs should take a higher proportion of the unmet need from the Greater Birmingham Housing Market Area. They recommend a 8,212 dwelling contribution towards meeting the unmet need.
Housing Site Selection Topic Paper (September 2021)
Our client’s land to the east of Bilbrook (site reference 500) has been incorrectly assessed as ‘NS’ and should be included as part of Strategic Allocation SA1.

Viability Appraisal 2021
We consider that it is imperative for the Council to engage with infrastructure providers to confirm
financial contributions that they will require from allocations, these should then be factored into the Viability Appraisal.

Support

Representation ID: 1432

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

We do not oppose the proposed requirement to provide compensatory improvements but consider that any requirement should accord with the wording of the Planning Practice Guidance (‘PPG’) (Reference ID: 64-002-20190722).
We support the provision of a Green Belt Supplementary Planning Document which we consider should include
more guidance on the provision of compensatory improvements and costs for calculating off-site contributions if improvements cannot be met on-site.

Object

Representation ID: 1433

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Council has not proposed an uplift to the minimum standard method figure to meet local needs nor has the Strategic Housing Market Assessment (‘SHMA’) May 2021 assessed the requirement for an uplift. Without a buffer, we do not consider that the plan has been positively prepared in an aspirational way (NPPF paragraph 16) nor does it support the Government’s
objective of significantly boosting the supply of homes (NPPF paragraph 60).
The NPPF also requires plans to “be able to demonstrate that Green Belt boundaries will not need to be altered
at the end of the plan period” (paragraph 143). Given our comments above, we consider that additional Green
Belt land will be required within the plan period so therefore the plan does not accord with the NPPF.

Therefore, additional sites should be identified within the District in order to meet these additional housing needs. We consider that our client’s land (site reference 500) forms a logical extension to proposed Strategic Allocation SA1 and should be considered for a residential allocation to assist the Council in meeting their housing needs.
We question why these SoCGs are not being drafted and regularly updated now, as recommended by the PPG (Reference ID: 61-020-20190315).

Object

Representation ID: 1435

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

We support the allocation of Land East of Bilbrook (Policy SA1). However, as stated in our response to Question 1, we consider that our client’s land (reference 500) should be included within the strategic allocation in order to provide a revised Green Belt boundary that is clearly defined by permanent and physical features (NPPF
paragraph 143f).

We also consider that the Council should provide a housing trajectory for all of the allocations within the District to demonstrate that housing needs will be met across the plan period (NPPF paragraph 74). The plan should demonstrate that all of the strategic allocations have a reasonable prospect of being delivered within the plan period and that infrastructure providers have been engaged to discuss requirements (PPG Reference ID: 61-060-20190315).

Object

Representation ID: 1436

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy SA5 sets out the proposed allocations across the District. We support additional growth being directed to Bilbrook. However, as stated in our response to Question 5, we consider that an uplift should be applied to the minimum local housing need and a greater contribution towards the HMA shortfall may be required in light of recent evidence that the shortfall is likely to be significantly more than the existing figure.

In light of the above, we considered that Bilbrook is a suitable location for additional growth given it is one of
the most sustainable settlements in the District. We consider that our client’s land (site reference 500) forms a
logical extension to proposed Strategic Allocation SA1 and its allocation will assist the Council in demonstrating
a more defensible Green Belt boundary.

Object

Representation ID: 1447

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Consider that the policies within each of these tables should be supported by an overarching strategic policy (NPPF paragraph 21).

Object

Representation ID: 1450

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy HC1 – Housing Mix
Do not support applying a blanket requirement across the
District. Although the policy could provide useful guidelines to the type of dwellings that the District would seek to be provided on a site, it is important that the final housing mix on a site is determined on a site by site basis taking relevant market signals. Additionally, we also request that when determining housing mix for a site, consideration is given to the size of properties.
Policy HC2 – Housing Density
Do not support a blanket approach to density being taken. Housing density should be determined on a site by site basis and consideration should be given to site context and its accessibility.
Policy HC3 – Affordable Housing
Object to the proposed requirement for 50% of the affordable housing to be delivered in the form of social
rent. A distinction needs to be made between
affordable and social rent, and this should be reflected in the policy.
Policy HC4 – Homes for Older People
Any proposed standards in the Local Plan Review will need to accord with the requirements of the NPPF and
PPG and ensure that they do not negatively impact on the viability of a site. We consider that the policy should
be worded flexibly and allow proposals to be determined on a site by site basis

Object

Representation ID: 1451

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy HC9 – Design Requirements
We consider that the policy should be worded as set out in the NPPF. We consider that input should be had by developers to ensure that the design codes are market facing and deliverable.
Policy HC11 – Space about dwellings and internal space standards
The Council should provide justification on the requirement to meet the NDSS and provide further information on the potential impact on viability.
Policy HC12 – Parking Standards
Across the plan period, it is likely that electric vehicles and supporting infrastructure are likely to change /
advance therefore this policy should allow for flexibility.
Policy HC14 – Health Infrastructure
We do not consider that contributions should be sought from health providers for any allocations within the plan as they will be known developments.
Policy HC17 - Open Space
There is no justification as to why the open space needs to be ‘centrally located’.No definition of what constitutes ‘small’ is provided nor how applicants can demonstrate that it serves a purpose. Further clarity is sought on this matter as landscape buffers identified as ‘semi natural / natural open space’ can play an important role in connecting green infrastructure and pedestrian links.

Object

Representation ID: 1454

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy NB1
As stated in our response to Policy HC9, we consider that any reference to tree lined streets should be compliant with the NPPF.
Policy NB4 - Landscape Character
We do not consider that Category C or U trees should be afforded any specific protection within the policy
Policy NB6
This requirement should therefore be monitored throughout the plan-making period and only included
within the plan if the Building Regulations are update.