Publication Plan April 2024

Object

Representation ID: 7311

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

This version of the South Staffordshire plan seems to be a deliberate attempt to scale back on the delivery of housing that the Council had already accepted was needed and sustainable in the previous Regulation 19 consultation. Failure to address the wider housing needs of the HMA and the refusal to consider further Green Belt release serves to show the Council is failing to positively plan for the future of its area, as national planning policy and guidance requires it to do.

Object

Representation ID: 7312

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF cannot see how adopting a constraint-based approach to plan-making for South Staffordshire in the midst of a housing crisis is appropriate. We have made the same comments to all of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) LPAs whose individualistic approach to plan-making means that the wider housing needs of the region continue to grow.

Object

Representation ID: 7314

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HFB cannot see how the evidence under pinning the previous Reg 19 plan has changed to an extent that failing to meet the already identified housing needs is a reasonable approach or represents a positively prepared plan for South Staffordshire.
In adopting a new “local need” approach to housing, with a minimal contribution to the wider housing needs of the area, the Plan seems to be in conflict with itself. The evidence base behind the previous Reg 19 consultation remains, and this was supportive of the previous approach where South Staffordshire was able to make a greater contribution to the wider housing needs of the HMA, enabling it to benefit from the value of current and future inward investment, attract new jobs and provide a range of employment land to ensure a range and choice of sites for that sector.
It will be essential for the deliverability of the Plan for the Council to demonstrate that the infrastructure needed to support new development remains viable with the new significant lower levels of housing growth now being planned for in this new Reg 19 consultation.

Object

Representation ID: 7316

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

As the SWOT analysis in Table 2 in para 3.15 acknowledges South Staffordshire faces an ageing demographic, reliance on neighbouring areas for its economic health and access to employment. However, the opportunities for growth to generate inward investment and prosperity is noted.
In HBF’s view this should lead to a positive plan seeking to deliver housing and employment to ensure South Staffordshire can benefit from these opportunities. It is therefore disappointing that this version of the plan is rowing back on previous ambitions, which in HBF’s view were in themselves already not ambitious enough.

Object

Representation ID: 7319

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF acknowledge the changes to the NPPF have removed the “requirement” for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated. However, as this section of the Plan notes authorities may still choose to review and alter Green Belt boundaries where exceptional circumstances are fully evidenced and justified. HBF believes the current housing crisis, the scale of unmet need within the GBBCHMA and the failure of joined up strategic planning in both Birmingham and the Black Country provide just such exceptional circumstances that justify further green belt releases. We would request the Council revisits its approach to this matter in order to an enable the South Staffordshire new Local Plan to be positively prepared, justified and effective.

Object

Representation ID: 7320

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF would request changes are made to this section to join the different elements of spatial planning together. In order to be positively prepared, effective and justified, it is important that the plan views South Staffordshire in the round, considering housing and employment, growth and jobs together. These factors are inextricably linked and the failure to proactively plan for more housing will impact negatively on the area’s ambitions for growth. Similarly, the failure to do more to contribute to meeting the wider housing needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA), will negatively impact on the economic aspirations of the wider area.

Object

Representation ID: 7321

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS5 is unsound because it is not effective or justified and does not comply with national policy.
As HBF believes the housing requirement for the South Staffordshire Plan should be higher and a greater contribution should be made to meeting the wider housing needs of the HMA and are of the view that the spatial strategy needs to be reviewed and expanded to enable additional housing allocations. This is likely to include the need for further green belt release.
HBF believes the plan period needs to be extended for the plan to confirm with national policy, as such this paragraph will need updating to reflect the new longer plan period.

Object

Representation ID: 7322

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The vison is unsound as it is not positively prepared
HBF believes the vison for South Staffordshire should explicitly refer to the need for new development and growth and meeting the housing needs of the area in full.

Object

Representation ID: 7323

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DS1 is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy.
Although HBF is supportive of changes to the Green Belt boundary that will enable housing allocations to be brought forward, we believe additional changes are needed to the policy because additional housing allocations including green belt releases are required to meet the housing needs of South Staffordshire and the wider HMA.
Planning policy must be made through the Local Plan process. This is subject to mandatory requirements for public consultation and independent scrutiny through the Examination process. If the Council wish to provide additional advice on the interpretation of any policy, this should be done through a Supplementary Planning Document, which is prepared and consulted on after the Local Plan policy has been adopted. Any reference to any future SPD should be moved from the policy to the supporting text.

Object

Representation ID: 7326

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC3 is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy.To be fully effective this policy should allow for some flexibility and negotiation around housing mix and type to enable site specific considerations to be taken into account.
HBF suggest the policy wording should include the opportunity for negotiation around policy requirements for site specific reasons, as any sites whose circumstances fall outside the parameters of the typologies tested could already be unviable under the proposed Local Plan policies. The PPG viability guidance which does allow for site specific viability considerations to be taken into account, and the wording of this policy should reflect that.
If the Council wish to provide additional advice on the interpretation of any policy, this should be done through a Supplementary Planning Document, which is prepared and consulted on after the Local Plan policy has been adopted. Any reference to any future SPD should be moved from the policy to the supporting text. Seeking to give Local Plan status to an existing, or emerging SPD is not appropriate.