Publication Plan April 2024

Object

Representation ID: 6594

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree that Green Belt development should enhance access to outdoor sport and recreation, enhance landscape, visual amenity and biodiversity – as indeed many proposals within the Green Belt are capable of (including the subject site). We also agree with DS1 that where Very Special Circumstances can be demonstrated with regards to inappropriateness, planning permission should be granted. However, this is a difficult hurdle to get over and the most appropriate way to deliver large scale new housing is through a positively prepared local plan.

We do not agree that affordable housing to meet local community needs should be “limited”, considering the significant and worsening affordable housing shortage within South Staffordshire, as demonstrated by the c.1,500 households on its social housing waiting list. South Staffordshire should look to encourage as many forms of affordable housing delivery as possible, including via Rural Exception Sites.

Comment

Representation ID: 6595

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Agree with Strategic Objectives 2, 3, 4, 5, 6, 7, 8 and 13.

Agree with Strategic Objective 9 and 10 However, it is also here that meeting the Duty to Cooperate is essential in identifying and delivering cross-boundary infrastructure which would facilitate unmet housing need from neighbouring authorities.

Strategic Objective 11 and 12 are laudable, however it is our view that the building regulations regime is the best way to set standards for energy performance in new buildings.

Object

Representation ID: 6596

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The unmet need identified in paragraphs 5.9 to 5.11 attributed to the authorities in the Black Country and Birmingham have as much as 106,653 homes worth of unmet need (78,415 from Birmingham and 28,643 from the Black Country). Wolverhampton and Dudley alone account for over 12,000 homes as unmet need. It appears that South Staffordshire have all but abandoned their previous approach of meeting c4,000 units of this unmet need via the Duty to Cooperate, and since then very little has changed to warrant this new approach.

Policy DS4 should make clear that the delivery of 4,726 homes is a minimum target and should encourage sustainable development on all sites where all other development plan policies are met.

Object

Representation ID: 6597

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We believe that the spatial strategy should allocate potential housing sites on the urban fringes of the Black Country which already benefit from good sustainable transport links and higher order services such as surgeries, schools and shops.

Object

Representation ID: 6598

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The housing allocations at Policy SA3 do not allocate any housing to Wombourne other than safeguarded sites, which seems to be poorly conceived if the council are to make any serious headway with housing delivery to meet need.

The 2022 EDNA identified Wombourne as part of the top tier of retail centres. Commuter trips are generally shorter in this area and Wombourne itself is one of the three main employment centres in the Borough providing a significant number of jobs and business opportunities at Heathmill Road Industrial Estate, Smestow Bridge Industrial Estate and Wombourne Enterprise Park as well as in the retail centre. Making significant housing allocations in Wombourne would take advantage of its clear sustainability as a settlement and major source of multiple forms of employment.

Regarding the site Land south of Bridgnorth Road, Wombourne, other than Green Belt and proximity to Wombourne Conservation Area the site is unconstrained. The site would provide the community with a new park and open space. The site could also be delivered within the first five years of the Plan period, without the need for major infrastructure investment. The site relates well to the existing established settlement edge of Wombourne, whilst having the opportunity to provide a more definitive boundary to the Green Belt beyond. Overall, for the reasons stated above, we believe that the site could deliver a successful example of sustainable development which would benefit the public realm extensively. Richborough Estates have submitted a vision document as part of our previous representations which further details the benefits of the site. This has been included in Appendix A. We urge that the council should give further consideration to our client’s site: Land South of Bridgnorth Road, Wombourne and it should be included as a housing allocation within the Submission Plan.

Object

Representation ID: 6599

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree with Policy HC1 and the need to deliver a strong housing mix that meets the needs of a variety of different households, regarding bedroom numbers and mix. However, we would urge flexibility in its application where there are clear vagaries in the housing market throughout the authority.

Object

Representation ID: 6600

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Agree with Policy HC2, that development should seek to make efficient use of land by achieving a least the minimum density of 35 dwellings per ha, and in many cases should exceed this minimum density, to encourage the delivery of more housing across South Staffordshire. However, this should not be at odds with prevailing character, nor the need to accommodate 10% BNG for instance.

Object

Representation ID: 6601

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree with Policy HC3 that 30% affordable housing should be delivered at the tenure mix as described within the policy. On small sites of less than c.10 units, specific wording should be added to allow a given lower end threshold for on-site affordable housing, below which an off-site payment in lieu may be provided.

Object

Representation ID: 6602

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HC6 is not clear as to how some of the exceptional circumstance criteria would apply. Exception (a) is not clear, as it does not consider a scenario where development is proposed inside the settlement boundary, therefore creating a potential reason for refusal by a policy that seeks to prevent sprawl outside the settlement, and consequently rejects development inside the settlement. This appears contradictory and should clarify its position on proposals inside the settlement.

We completely disagree with requirements to involve the Parish Council and a Rural Housing Enabler for a Rural Exception Site; as is clear from recent cases, if the Parish uphold their right to not engage with a developer, the policy cannot be met. It is true that many affordable housing providers also require the endorsement of the parish, which again, would preclude the ability to meet HC6 if a parish choose not to engage with the applicant, effectively holding the process to ransom. Policy HC6 should remove the unnecessary requirement to involve a parish and a Rural Housing Enabler as it is not in accordance with the NPPF or PPG – the parish council and Rural Housing Enabler are not the planning authority and should not be given the role of decision taker.

Comment

Representation ID: 6603

Received: 30/05/2024

Respondent: Richborough Estates

Agent: RCA Regeneration

We agree with Policy HC7 and the need to make exceptional provision for First Homes across South Staffordshire.