Publication Plan April 2024

Object

Representation ID: 7301

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF are concerned that this second Regulation 19 consultation is a significant rowing back from the amount of housing that was being planned for in South Staffordshire under the previous Reg 18 and Reg 19 consultations. The failure to address the full housing needs of the area, and to make a greater contribution to the wider needs of the region when previous evidence supported such an approach, means that the plan is not proactively planning for development and would therefore fail the tests of soundness. In our view the housing requirement for South Staffordshire should be higher and additional housing allocations are needed.
HBF wrequest that the Plan is amended to reflect a higher housing requirement for South Staffordshire which will enable a greater contribution to be made to meeting the wider hosing needs of the HMA. This figure should then be included in criteria a of the policy.

Object

Representation ID: 7302

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF believe the plan is unsound because it has not been positively prepared and question whether the Duty to Cooperate has been met.

HBF is disappointed that the DTC statement simply sets out what has happened but gives no explanation of what has been agreed upon and why. Merely noting that there is an unmet need, does nothing to address it. HBF is supportive of the need for the Council to have an up to date Local Plan which is why it is so disappointing that there is a total lack of collective thinking around how the unmet need of the whole Housing Market Area will be addressed.

Object

Representation ID: 7303

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF believe that for the plan to be positively prepared and in line with national guidance, the plan period needs extending to ensure that the Plan has a 15-year timeframe post adoption. As such para 1.2 needs amending to reflect an extended time period. It will be importance the evidence also covers the whole plan period.

Object

Representation ID: 7304

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF believe that this is currently unsound as it fails to plan positively for the future development needs of South Staffordshire. This is illustrated by the wording of para 1.11 which disappointing fails to fully set out the benefits of planning system. These benefits have not been fully captured as there is no mention of positive benefits of new development to current residents and businesses with South Staffordshire who stand to benefit from getting to live in a new home, benefiting from new sustainable development, accessing new affordable housing, securing employment within a new employment sites or benefitting from a more energy efficient new home. This paragraph should be revised to show the positive benefits of plan-making and house building. As currently drafted it fails to show the plan has been positively prepared.

Object

Representation ID: 7305

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF is disappointed that the Council has rowed back from the level of housing being proposed in the previous Reg 19 consultation, which sought to do much more to help meet the wider housing needs of the HMA, and deliver the benefits of growth. We are very disappointed to see the Council’s change in direction, and do not agree that the changes to the NPPF require the Council to take this approach. A positively prepared Local Plan for South Staffordshire would require a consequential amendments to this section. In addition, HBF request that additional information be providing in the monitoring and review section of the Table One. The Council needs to monitor other things and not just planning applications if they are to use monitoring effectively to ensure that the new Local Plan for South Staffordshire is delivering. It will be important for the Council to also monitor the progress of ongoing discussions with neighbouring authorities and other regional partners. In particular the Council should monitor the policy making and evidence gathering activities around the issue of unmet need within the Greater Birmingham and Black Country Housing Market Area (GBBCHMA).
This should include both the level of that need, and how this could/should/is be re-distributed across the HMA. HBF have also commented on the need for an early Plan Review policy to be an essential component of this plan. This will also need to be detailed in this section.

Object

Representation ID: 7306

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Consequential changes will be needed to the policies map to reflect the HBF’s comment on this plan and to make it sound, most notably additional housing allocations.

Object

Representation ID: 7307

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF note the importance of investment and economic growth in the district. In HBF’s view this necessitates a higher housing number to support ongoing inward investment as envisaged in the Plan. Additional wording should be added to this paragraph to explain the importance of new housing in supporting economic growth.

Object

Representation ID: 7308

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan is rowing back on the housing numbers planned for in the earlier Regulation 19 consultation. The result is a plan to deliver less housing than was already being planned for, which it itself was not enough. HBF is very disappointed that in the midst of a Housing Crisis the Council is changing direction in this way. We do not agree with the Council’s characterisation of the changes resulting from the changes to the NPPF or the Council’s response to it. There is nothing in the changed NPPF that would force the Council to change tack in this way. If the Council remained committed to meeting their own housing needs and contributing to wider growth agenda of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) there is nothing in the NPPF changes that would prevent them from continuing on the path proposed in the original Reg 19
consultation.

Object

Representation ID: 7309

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The change of tack proposed in the new Reg 19 consultation fails to take the longer-term view needed on the future growth in South Staffordshire. The failure of the joint-working and cross-boundary collaboration between the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) LPAs including South Staffordshire failing to recognise and address the scale of housing need, does not result in the housing need disappearing, it simply makes the situation worse as the unmet housing needs of the region continue to grow. The Plan does not help to address the national housing crisis.

Object

Representation ID: 7310

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Paragraph 22 of the NPPF requires that “strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger-scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery”. HBF would wish to see the South Staffordshire Plan take this approach, and it is very disappointing it does not.