Publication Plan April 2024

Object

Representation ID: 6738

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Full details of the unmet need in the GBBCHMA can be found in the full representation.

A contribution of less than 1% of the unmet housing need from elsewhere in the BBCHMA now proposed in the second Reg 19 plan does not, in our view, make sufficient provision for housing and is not positively prepared. The proposed strategy revision is not soundly-based.

Increase the contribution towards the unmet need of the Black Country and Birmingham to properly reflect increasing scale of the shortfall and the functional relationship with the District.

Object

Representation ID: 6739

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RPS has raised concerns with the housing trajectory proposed in the second Reg 19 Plan, specifically the substantial reduction in housing delivery planned for in the early years of the plan period.

At the site level, the trajectory is heavily dependent on the delivery of the two strategic sites at Bilbrook and Penkridge. The Council provides no evidence to substantiate their position that delivery rates will increase as much as suggested as a result of these sites coming forward.

A recent review of housing delivery across the country indicates that sites in the region of 500-999 (Bilbrook) and 1,000-1,900 dwellings (Penkridge) could take between 5 to 6 years respectively to move from submission of an outline to first completion on site. On this basis, this would suggest that delivery on the two strategic sites won’t deliver any homes until 2029 at the earliest (near the end of year 6 of the plan). However, the Council expects a significant ramping of delivery during 2028 (with commencement preceding that date). In our view, this raises further concerns that housing delivery in the first five years of the plan period, and maybe beyond that, could be severely restricted if the current strategy is taken forward.

None of these factors have been accounted in the redrafting of the Reg 19 Plan. Taken together, the current strategy is not justified, will not be effective in its intended outcome, and is not consistent with national policy. It is not soundly-based.

Comment

Representation ID: 6740

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

An appropriate remedy that could be taken forward relatively swiftly is for additional land to be identified at the most sustainable settlements where growth is not already identified or where it is currently restricted. A particular settlement where growth is restricted is at Huntington. A suitable and deliverable site in this location is ‘Land north of Limepit Lane’ (site 591). This site was previously proposed for allocation at the draft Plan (Regulation 18) stage consulted on in 2021. This would help increase supply in the short-term during the early years of the plan, helping to increase delivery overall but also to assist in the delivery of affordable housing.

Object

Representation ID: 6741

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Details on the spatial strategy options and choices can be found in the full representation. RPS would go further to suggest that the Council has simply devised two additional spatial options (Options H and I) as part of the revised Reg 19 Plan, which merely reinforce the wider objective of reducing the overall scale of growth in the District compared to that which was planned for in the first Reg 19 Plan, using ‘capacity’ as a smokescreen for the revisions.

Taken together, the Council’s approach to revising the spatial strategy in this context is not positively prepared and is represents a backwards step in terms of planning to meet wider development needs, whilst the decision to limit Green Belt release to only Tier 1 settlements is arbitrary in nature. The revised strategy is not soundly-based.

Object

Representation ID: 6742

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Details on the housing trajectory and recent housing delivery can be found in the full representation.

It is evident that the second Reg 19 Plan is effectively seeking to 'turning the tap off' housing delivery between 2024 and 2028. The second Reg 19 Plan and the supporting evidence does not explain why limiting growth in the early years of the trajectory is justified. There is clearly a need for a measured increase in additional smaller sites in the early years, which can help shore up the planned decline in delivery currently proposed. A suitable site to help address this issue is the Land at Limepit Lane, Huntington.

Object

Representation ID: 6743

Received: 31/05/2024

Respondent: IM Land

Agent: RPS Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The second Reg 19 Plan says that growth will be located at the most accessible and sustainable locations in accordance with the settlement hierarchy.

Huntington is also located in close proximity to the development at Pye Green Road, also located in Cannock District, where a range of community facilities and services are being provided, also located within 1 mile of Huntington. These considerations have been ignored in the update of the SHSTP (and in previous versions).

RPS would draw to the Inspector’s attention the Council’s Preferred Options Document (POD), which at the time directed 92 dwellings to Huntington, including the additional site allocation of 44 dwellings on Land north of Limepit Lane (IM Land’s site), part of SHLAA Site 591.

The Council clearly concluded that there was capacity for additional growth to be accommodated at Huntington. However, the Council does not explain why this reasonable alternative growth option of 92 dwellings for Huntington has been excluded from the revised SHSTP, when previously supported by the Council.

Actions -
Assess the growth figure for Huntington (based on a minimum of 92 dwellings proposed at the Preferred Options stage) in order to reflect the status and location of the settlement in the hierarchy and the evidence on the proximity of the Huntington to Cannock.

Identify sufficient land to meet this apportionment of the housing requirement, notably Land north of Limepit Lane (site 591). Alternatively, the Council should identify the site as safeguarded land in this second Reg 19 Plan, consistent with the approach adopted in the current development plan.