Preferred Options November 2021

Support

Representation ID: 1455

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy HC7 – Self & Custom Build Housing
We support the proposed wording within this policy in relation to determining the provision of self-build and
custom plots as part of major developments on a site by site basis.
Policy HC15 – Education
As part of any proposed development of site 500, financial contributions could be provided towards the provision of the new primary school.
Policy NB2 – Biodiversity
We consider that the Council should also allow the Applicant to offer off-site land too, particularly if it is in the same landownership and / or in close proximity to the application site
Policy NB10 - Canal Network
We support measures to integrate the canal network into the wider Green Infrastructure network through biodiversity net gain.

Object

Representation ID: 1459

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: 1460

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.

Rural Services and Facilities Audit (‘RSFA’)
Object to the proposed revised Rural Settlement Hierarchy and the categorisation of the village of Kinver as a proposed Tier 2 Settlement. Kinver provides a greater range of shops and services than some of the proposed Tier 1 settlements (Appendix 4 of the RSFA). . It is considered that the modified Main Service Village settlements, which currently includes the settlement of Kinver, should remain as Main Service Villages as they are sustainable settlements which are capable of supporting significant residential growth.

Housing Site Selection Topic Paper (September 2021)
Barratt is promoting land to the north (site reference 549) and south of Dunsley Road (site reference 550), Kinver. They consider that the sites should be allocated.

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: 1461

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

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.

Object

Representation ID: 1462

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. n light of the above, we consider that an uplift should be applied to the minimum standard method figure of
243 dwellings per annum and the proposed contribution towards the HMA should be updated to reflect the
additional housing shortfall identified by the Black Country authorities. 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 549 and 550) form a logical extension to Kinver, are accessible and should therefore be allocated to assist the District in meeting its 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: 1463

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

We 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: 1465

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 Kinver. 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.
Consider that more growth should be directed to Kinver and that site references 549 and 550 should be allocated.

Object

Representation ID: 1466

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: 1468

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: 1470

Received: 13/12/2021

Respondent: Barratt West Midlands

Agent: Savills

Policy EC6 - Retail
We do not support the findings of the RSFA and the identification of Kinver as just a ‘village centre’ rather than a ‘large village centre’ given the significant range of shops, services and facilities provided in the village.
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 updated.