Preferred Options November 2021

Object

Representation ID: 3568

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Disagree. The housing evidence base which underpins the draft Plan’s housing strategy is lacking. Paragraphs 4.6 to 4.12 of the Preferred Option consultation draft Plan refer to various evidence base documents that have been used to help identify the quantum of development South Staffordshire should provide to assist in accommodating the unmet housing requirements of the conurbation. None of the documents referred to in these paragraphs are referred to in the evidence base in Appendix A. They have, however, been fundamental in
shaping the Plan’s housing strategy and should be included.

The housing requirement proposed by the draft Plan is unsound as evidence is dated and does not reflect current data.

Object

Representation ID: 3569

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The infrastructure requirements included within the IDP are based upon the Preferred Options Plan’s housing and employment development targets. As detailed in these Representations it is our view that the emerging Plan makes insufficient provision for housing development. That being the case, the IDP plans for an insufficient level of development. The IDP will need
updating in due course should the housing and employment requirements be increased.

Object

Representation ID: 3570

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Disagree as the plan is viewed as inappropriate.

The framework identified three overarching objectives which constitute sustainable development, with parts of the economic and social objectives to which are not included within the local plan.

The Local Plan should be amended for South Staffordshire to deliver sufficient land of the right type to meet the economic and housing growth required to support the conurbation.

Disagree with Sratgiegic Objective 1 which should be altered to o reflect the fact that the Preferred Options plan identifies that Green Belt release is necessary and that exceptional circumstances exist.

Strategic Objectives 3, 4 and 5 are designed to address ‘homes and communities’. However, nowhere within any of the Strategic Objectives for Housing is reference made to providing a sufficient quantum of housing to support the growing number of households within South
Staffordshire which should be considered.

Additional Strategic Objectives should be added to confirm the Plan will provide enough houses to meet both South Staffordshire’s and the conurbation’s housing need. Another, to confirm that changes to Green Belt boundaries will have regard to their intended
purpose in the long term, so that they can endure beyond the Plan period.

Object

Representation ID: 3571

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The Housing Requirement to meet the Growth of South Staffordshire.

Conclusions in the SSHMA are not reflected in the draft Plan which stated the housing need for the period of 2021-2038 is 4,131 dwellings, with a further 750 completions between 2018 and 2021. Combined this gives a housing target of 4,881 dwellings to support the growth of South Staffordshire.The emerging Plan should plan for the minimum standard method housing requirement from the beginning of the plan period as a bassline the advised 5068.

Local Plan has not correctly factored in affordable housing need and weather an uplift to the South Staffordshire housing requirement is required and not considered uplifting the minimum Standard Method housing figure to take account of economic growth aspirations and the fact that the age profile of South Staffordshire is increasing.

Object

Representation ID: 3572

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Affordable Housing.

Concerns into how South Staffordshire will meet the needs and overspill of the Black Country considered and presented to ensure that all relevant housing needs are being met. With the current policy target being 30% the policy target will need to be increased.

Object

Representation ID: 3573

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Economic Growth.

There is no clear information considered to whether an uplift in the housing requirement would ensure that sufficient houses are available to support the local work force,

Object

Representation ID: 3574

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Additional Housing to Contribute Towards Meeting the Unmet Needs of the Housing Market Area

South Staffordshire District Council should consider whether the conclusions of the Strategic Growth Study and its update are robust for the purposes of its plan making. The Strategic Growth Study does not
establish housing need using the Standard Method.The housing
needs figure in the Strategic Growth Study is not, therefore, fit for plan making purposes. It is
based upon out-of-date evidence and does not use the Standard Method. Furthermore, the Study covers a period that is not commensurate with the South Staffordshire Plan. Its conclusions are not, therefore, directly transferable in any event.

Object

Representation ID: 3575

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

Birmingham Overspill
There is clear evidence to suggest that South Staffordshire should be taking a greater proportion of development than other authorities within the HMA given the level of shortfall identified. This further supports an increase in the 4000 dwellings proposed to reflect this relationship and South Staffordshire’s ability to deliver homes in a location closest to where the need is derived.

The number of homes being planned to contribute to addressing the shortfall should be increased significantly

Object

Representation ID: 3576

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The housing allocations included within the Plan to support the growth of the conurbation should be directed to locations close to where the need arises. The Plan’s spatial strategy for housing should be predicated on making allocations adjacent to the conurbation
to meet its need, or within a sustainable commuting distance, to help reduce the need to travel. The housing requirement should be increased and redistributed so that further allocations are made adjacent to the built-up edge of the Black Country.

the GBHMA Strategic Growth Study is not a relevant evidence base against which to assess the suitability of sites or formulate a housing distribution strategy.

A sequence of smaller sites in appropriate locations, such Heyford’s site at Wall Heath, would not only make a positive and sensitive contribution to meeting the overspill, but would also provide sites that can be delivered in the short term.

Object

Representation ID: 3577

Received: 13/12/2021

Respondent: Heyford Developments

Agent: Harris Lamb Property Consultancy

The Draft Plan does not include the proposed wording of the various Development Management Policies, and instead identifies “directions of travel”. The Preferred Options version of the Plan should set out the full proposed policy wording, as opposed to leave this
matter to the pre-submission stage.

The Sustainability Appraisal
Concerns with they way in which the Plan's Sustainability Appraisal is used to inform the site selection process as it is incomplete and fails to properly consider mitigation, and the advantages of making particular allocations.

Example site: Wall Heath shown in Vision Document.

Omission Site – Wall Heath

The land at Wall Heath should be removed from the Green Belt and allocated for residential led development. The site can provide 148 new homes at a
density of 37 dph alongside supporting infrastructure, including 4 hectares of multifunctional open space and the incorporation and enhancements of the existing public rights of way within the site.