Publication Plan April 2024

Comment

Representation ID: 7120

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

DS1 remains broadly consistent with the provisions of the NPPF. In reviewing the Green Belt, the previous iteration of the Plan accommodated a much larger number of allocations, this has been significantly reduced. Having been previously removed from the Green Belt and identified as safeguarded land, the proposed allocation of Cherrybrook Drive offers an excellent opportunity to deliver new homes.

Comment

Representation ID: 7121

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Despite representations set out in the 2022 Publication Plan consultation, the policy still eaves elements of ambiguity and its practical application is unclear. The policy should identify and name which particular sites it is intended to apply to, or alternatively, the individual site allocation proformas should identify when it is expected this policy would apply.

Support

Representation ID: 7122

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Persimmon Homes support the Council’s strategy is DS5 to distribute growth to sustainable locations, particularly Tier 1 settlements such as Penkridge. The identification of Penkridge as a Tier 1 settlement is welcomed. Land at Cherrybrook Drive offers the opportunity to deliver much needed market and affordable homes consistent with the spatial strategy.

Comment

Representation ID: 7123

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The Council have allocated the minimum figure of housing required by the standard method – Persimmon Homes raises concerns regarding potential insufficient housing to meet the housing needs. The PPG makes it clear that the figure produced by the standard method is a minimum figure, rather than a requirement. Whilst it is acknowledged that the district continue to contribute towards the HMA, the district should go further in providing additional homes to address the significant growing need across the GBBCHMA. In light of the extended Plan period, consideration must be given to expected population growth and the additional shortfall of housing across the GBBCHMA.

Comment

Representation ID: 7124

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The Plan provides a buffer of 10%, this has been reduced from 13% in the 2022 Publication Plan. In view of the 2024 Publication Plan reducing housing supply rather than reducing the buffer, it ought to be increasing it as there will be less supply overall and a proportionally greater impact if sites do not come forward.

Comment

Representation ID: 7125

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

HC1 is overly prescriptive and pre-empts housing need rather than referring to the SHMA.
Whilst the housing stock across the district includes a large proportion of larger homes, these are not available to meet the needs of families in need of a home. HC1 needs to delete specific reference to the delivery of 2 and 3-bedroom homes. The requirement that 70% of properties comprise 3-bedrooms or less is restrictive and does not afford sufficient flexibility. The use of the phrase ‘disproportionate’ lacks the precision and clarity needed for a Plan policy. The policy should recognise that needs and demand in regards to home working will vary from area to area, including individual settlements. The policy is considered unsound as it is inconsistent with national policy.

Comment

Representation ID: 7126

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The flexibility afforded to housing density and the recognition that although a minimum of 35dph across the wider site should be delivered, the density of development within a scheme may vary to take account of local character impacts and the provision of services and facilities across a development, is welcomed.

Comment

Representation ID: 7127

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The use of the term ‘major residential development’ in this context requires a definition. The 30% requirement appears to be supported by the Viability Study but it does highlight the challenges in delivering such a requirement and the need for higher site values to be achieved to deliver this. Both HC3 and HC1 should introduce greater flexibility to allow for viability to be considered alongside the mix identified within an up-to-date SHMA. The requirement to ‘pepper pot’ affordable housing is generally supported. However, the policy should recognise that for management purposes, Registered Providers do require a degree of clustering of affordable housing within a development.
The frequent reference to the Affordable Housing SPD is noted, but it should do no more than clarify the Local Plan policy. The policy is considered unsound as it is neither justified nor consistent with national policy.

Comment

Representation ID: 7128

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

The policy needs to define ‘older people’ as it is unclear as to exactly who the policy is targeting or who would be eligible to occupy such dwellings. Extra care and retirement living often need a minimum critical mass to be viable and the Council needs to determine which should be able to support the provision of such accommodation, it also needs to provide much greater clarity on when such housing will be required and to make clear that some housing types may be required on any given site.

Object

Representation ID: 7129

Received: 31/05/2024

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is noted that the Plan continues to require 100% of all housing to be M4(2) compliant. This raises an issue of affordability. Whilst the principle is agreed, it is not a requirement of the whole population to have such a provision and delivering this will have an impact on the overall capacity of sites to deliver new homes. The M4(2) standard is optional within Building Regulations, if the Government had intended that evidence of an ageing population alone justifies adoption of optional standards, then such standard would be mandatory. The requirement for 100% M4(2) homes is not considered to be adequately justified.