Preferred Options November 2021

Object

Representation ID: 1876

Received: 10/12/2021

Respondent: Balfour Beatty

Agent: CBRE

GB Stage 2 assessment is flawed and unjustified and should be revisited as a matter of urgency.
Site 673 (land at Wollaston Road/Bridgnorth Road) is incorrectly identified within S82Bs2 which is to the west of site 673 and not connected on any boundary.
Due to this, it is unclear how site 673 (land at Wollaston Road/Bridgnorth Road) scored in GB terms. It is not appropriate to group these sites together for assessment as the context for each parcel is different.
When assessed against NPPF 5 purposes of GB, site 673 (land at Wollaston Road/Bridgnorth Road) does not significantly contribute due to; existing development adjacent three sides, distance to neighbouring towns and existing of A458 as defensible barrier.

Object

Representation ID: 1877

Received: 10/12/2021

Respondent: Balfour Beatty

Agent: CBRE

Additional smaller site allocations should be made adjacent to existing towns/cities.
Such sites maximise the presence of existing infrastructure to directly meet the housing shortfall of these authorities.
The Black Country Housing Market Assessment final report observed that commuting into the Black Country for work were mostly likely to live in South Staffordshire, and most established linkages are between the two.
Site 673 (land at Wollaston Road/Bridgnorth Road) adjoins the existing urban area of Dudley MBC and is appropriate for development to contribute to Black Country housing shortfall.
Policies SA2, SA3, SA5 are all large sites which take longer to assemble and deliver as such, fewer homes will be delivered in the short term and provide the NPPF required 'housing boost'.

Support

Representation ID: 1878

Received: 10/12/2021

Respondent: Balfour Beatty

Agent: CBRE

Policies SA2, SA3, and SA5 include sites adjacent to neighbouring towns/cities which will directly contribute to urban authorities housing shortfall.

Object

Representation ID: 2137

Received: 10/12/2021

Respondent: Balfour Beatty

Agent: CBRE

Smaller site which can bring forward development in shorter timescales in locations adjacent to neighbouring towns/cities should be allocated to provide earlier cross-authority benefit to meeting cross-boundary DtC needs in the earlier years of the plan period.
Large sites are unlikely to be delivered until at least the mid-2020s and having a balanced portfolio of housing sites capable of delivery across the entirety of the plan period is an important consideration.
The distribution of allocated sites is considered unequal in that it does not fully reflect the importance of sites which are adjacent to neighbouring towns/cities. This approach is considered flawed as it assumes sites which border authorities with greater housing need should be prioritised over sites which border authorities with lower housing need and this is not in the best interests of cross-authority cooperation and neglects to consider the overall focus of co-operation on DtC matters across the entirety of the HMA and not specific authorities.
Furthermore, it does not provide for a range of smaller sites at land adjacent to neighbouring towns/cities thus resulting in fewer sites coming forward at these cross-boundary areas in the early years of the plan period.

Object

Representation ID: 2140

Received: 10/12/2021

Respondent: Balfour Beatty

Agent: CBRE

Policy HC1:
The proposed policy is too prescriptive and does not refer to the proposed housing development site to be informed by the latest SHMA or other evidence that would enable flexibility to reflect local needs/demands at the time of the application.
The policy should require consultation of appropriate evidence base documents such as Market Housing Reports.
Prescribing a specific mix may have negative implications for housing delivery if market demand does not coincide with policy at a particular time.
Proposed alternative policy wording:
"Developments of ten homes or more should provide for a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as: - The South Staffordshire HMA 2021 (or any subsequent revision; or - Detailed Local Housing Market Assessments (where applicable); or - Current and future demographic profiles; or - Locality and ability of site to accommodate a mix of housing; or - Market signals and local housing market trends.
The policy should encourage applicants to demonstrate why the proposed mix on a site is appropriate considering up to date South Staffs evidence.

Policy HC2:
A policy which is flexible would be beneficial for both allocated and unallocated sites.
The policy should also make provision for applications to put balanced proposals forward which demonstrate how they have taken into account the specific site character and context.

Policy HC3:
The policy should specify how exceptional circumstances for offsite and/or reduced affordable housing provision is to be evidenced and negotiated.
The policy should specify whether smaller sites will require affordable housing contributions or if they are exempt.
A threshold figure should be provided in relation to the sizes of of sites and their requirement for affordable housing.

Policy HC4:
The policy should clarify where exemptions are to be made to the requirement for affordable housing.

Policy HC5:
The policy should set out the number of units for specialist housing for the identification of any potential sites which would be able to accommodate demand.