Publication Plan April 2024

Object

Representation ID: 6300

Received: 31/05/2024

Respondent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Previous 4000 home contribution was of a reasonable scale and necessary to address acute housing needs that exist now.There is no question that there remains a well-evidenced and substantial unmet need arising from the GBBCHMA. Given the substantial shortfall, Gladman contend that the proposed contribution to unmet needs of just 640-homes is not positively prepared, justified or effective.To remedy this, an entirely reasonable course of action for the Council to take is to plan for an increased housing requirement incorporating a 4,000-home contribution to GBBCHMA unmet needs, in alignment with the previous Publication Plan (1).If there is no intention to the uplift the housing requirement now, then as an absolute minimum the Plan must contain a review policy which includes an effective and implementable trigger mechanism linked to the publication of a SoCG and/or new satisfactory evidence of unmet housing need informed by the latest sub-regional evidence base and Duty to Cooperate agreements.

Gladman at present do not consider that a 10% buffer is sufficient to ensure the Local Plan Review remains robust over the plan period.Given the way the Plan’s strategy is so heavily reliant on these two strategic sites, a larger flexibility percentage should be considered in the order of at least 15%. This can be achieved, in the first instance, by maximising development at non-Green Belt locations in accordance with national policy through extensions to existing site allocations.One such opportunity clearly exists at ‘Land at Weeping Cross (036c)’, a proposed allocation adjacent to the town of Stafford.

Support

Representation ID: 6301

Received: 31/05/2024

Respondent: Gladman

Gladman broadly supports the spatial strategy to 2041 as detailed through Policy DS5. The strategy expressly recognises that directing an element of growth adjacent to the southern edge of Stafford can facilitate sustainable growth at a non-Green Belt location.

Nonetheless, national policy is clear that all reasonable non-Green Belt options should first be considered for meeting identified needs for development. Gladman is of the view that the Council have not fulfilled this requirement of national policy. The larger site 036c Land at Weeping Cross represents one of if not the only remaining opportunity to deliver development in a non-Green Belt location in the authority, at a highly sustainable location on the edge of a main settlement. The potential for development here should be maximised and the larger site 036c allocated.

Support

Representation ID: 6302

Received: 31/05/2024

Respondent: Gladman

Land at Weeping Cross (Site 036c) is supported by Gladman and soundly responds to the emerging spatial strategy which directs growth to the most sustainable locations in the District.The explicit reference to minimum capacity of 81 dwellings is supported.The site is in a sustainable location to accommodate growth adjoining an already established community in the town of Stafford. The site has good access to facilities and community infrastructure and can deliver approximately 100 high quality homes. The site will deliver green infrastructure and provide an active travel link to services and facilities at Weeping Cross.

We consider that the allocation is sound but the potential for development should be maximised at this location, and thus we are of the view the allocation for a minimum of 168 dwellings, as set out in the Preferred Options Plan, should be reinstated. Technical note on potential heritage impacts confirms that any harm to the non-designated heritage asset would be minimal at most.

Object

Representation ID: 6303

Received: 31/05/2024

Respondent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HC1 could benefit from a further degree of flexibility to ensure it remains a sound policy over the lifetime of the Plan.It would be appropriate for the policy to include consideration of elements such as the demand/need at the time of a planning application. The requirement for 70% of market housing to have 3-bedrooms or less should be removed from the policy wording as it is overly prescriptive and could frustrate planning applications from being able to respond positively to local needs at the time of the application

Object

Representation ID: 6304

Received: 31/05/2024

Respondent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Gladman do not consider that the requirement for all residential development to meet or exceed Nationally Described Space Standard (NDSS) has been robustly justified by the Council at this stage.

Object

Representation ID: 6305

Received: 31/05/2024

Respondent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Concerned that the policy seek to go further and faster than national legislation and policy changes. There is a lack of clarity, justification and robust evidence for the many facets of the policy as detailed, and as a consequence we consider that Policy NB6a is ‘unsound.

the policy fails to differentiate between the levels of detail required between Full, Outline and Reserved Matter applications which could seriously undermine the overarching aims. If the policy is to remain in the Plan, it must clearly differentiate between what type of information is required for different types of applications.

Criteria A7 as drafted sets out that development proposals of more than 50 dwellings should monitor and report total energy use and renewable energy generation values on an annual basis for 5 years from first occupation. This requirement is exceptionally excessive and would appear to intrude into people’s privacy.