Publication Plan April 2024

Comment

Representation ID: 6987

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

DS4 sets out that delivery of new development will be monitored. If the LP is not to allocate additional land to contribute to meeting the overwhelming shortfall, it is imperative that further work in accordance with DtC, along with an early review of the LP, is undertaken. The extent of the unmet housing need clearly requires cooperation of adjoining authorities such as South Staffordshire to contribute a substantial, albeit appropriate, quantum of housing land.

Comment

Representation ID: 6988

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

SSDC’s preferred spatial strategy, Option I, focuses growth to sustainable non-Green Belt locations alongside limited Green Belt allocations in Tier 1 settlements. The Plan relies upon the delivery of over a third of the district’s housing on the large strategic allocations. Larger sites will typically have longer lead in times, which is reflected in the Indicative Housing Trajectory with completions falling significantly short of local housing need in the period through to 2028. There also appears to be an under delivery of 84 units across the two strategic sites.

Comment

Representation ID: 6989

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

The role the district plays in the wider GBBCHMA and FEMA must be emphasised further within the wording of DS5. Spatial Strategy Option I currently fails to reflect the district’s relationship with the adjoining areas of Dudley and Wolverhampton. It should place greater emphasis on housing growth along the eastern edge of the district. It is acknowledged in the evidence base that Tier 2 and 3 settlements can also accommodate housing growth, whilst this may require the release of Green Belt land, carefully considered layouts can enhance setting through appropriate compensatory measures. It is important that over reliance on brownfield sites does not result in an overprovision of development unable to meet a range of needs.

Comment

Representation ID: 6990

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Windfall development comprises 600 homes. Historic windfall delivery rates have been based on historic permissions to achieve a capacity of 35dph. These developments were based on less onerous policy provisions which did not require the delivery of 10% BNG, NDSS or M4(2)/M4(3) compliant homes. The strategy also fails to address affordability concerns, stating that affordable housing could be reduced to below 30% if viability is an issue.

Object

Representation ID: 6991

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DS5 is currently considered unsound and is not justified based on proportionate evidence nor positively prepared. It is considered that additional housing allocations capable of accommodating housing needs in sustainable locations accessible to public transport should be delivered.

Object

Representation ID: 6992

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

HC1 is overly prescriptive in relation to housing mix and pre-empts housing need through the Plan period rather than simply referring to the SHMA. The SHMA shows a clear need for 4-bedroom market and affordable family homes. HC1 should delete specific reference to the delivery of 2 and 3-bedroom homes (proposed text in paragraph 6.2 of full representation). Requiring 70% of properties to be 3-bedroom or less on major developments does not afford sufficient flexibility in order to meet the need to provide for a range of size, type and tenure of different groups. Housing mix should be guided by market signals as reflected in the most up-to-date assessment needs.

Object

Representation ID: 6993

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Plan acknowledges an increased need to accommodate home working. HC1 as currently drafted will restrict the ability to meet these needs across the Plan period. The policy should recognise that needs and demand will vary from area to area, including individual settlements. Mix can also influence the viability of development and the policy should recognise this. The policy is considered unsound.

Comment

Representation ID: 6994

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

Richborough welcome text which recognises that a blanket approach to density is unlikely to be effective. Reliance on the delivery of housing developments at a higher density does not provide a reliable strategy for the housing requirement and therefore a greater number of housing sites will be necessary to achieve the required housing numbers. The numerous policy requirements places increased pressure on sites and the ability to achieve higher densities. The allocation of additional housing sites would allow for the delivery of much needed homes balanced alongside the need to delivery high quality residential environments.

Comment

Representation ID: 6995

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

The use of the term ‘major residential development’ in this context requires a definition. The policy also needs to ensure that evidence is provided when considering viability, especially on brownfield sites. 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. The Council’s position to continue using S106 agreements to secure the necessary infrastructure to support and mitigate development is supported.

Comment

Representation ID: 6996

Received: 31/05/2024

Respondent: Richborough Estates

Agent: Pegasus Group

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. Richborough supports the removal of the suggestion that grant funding for homes to be provided under the requirements of the policy. The frequent reference to the Affordable Housing SPD is noted, but it should do no more than clarify the Local Plan policy.