Publication Plan April 2024

Comment

Representation ID: 7109

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Details of housing figures, contribution to the HMA and NPPF/PPG extracts can be found in paragraphs 4.21 – 4.28. The most recent SHMA fails to consider the impact of committed development at the HS2 West Midlands Interchange which is projected to create around 8,500 new jobs and 8,100 indirect jobs off-site. The EDNA outlines that the approved WMI has the potential to deliver 1,560 jobs. St Philips would like to see further clarity in relation to these figures. The Plan should go further in providing additional homes to address the significant and growing housing need across the wider GBBCHMA.

Comment

Representation ID: 7110

Received: 31/05/2024

Respondent: St Philips

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. DS4 is not justified as it is not based on proportionate evidence nor positively prepared in line with national policy. The minimum housing requirement figure across the Plan period should be substantially greater than that currently proposed.

Comment

Representation ID: 7111

Received: 31/05/2024

Respondent: St Philips

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: 7112

Received: 31/05/2024

Respondent: St Philips

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. Whilst support is given within the Plan to the delivery of housing allocations, it is important that DS5 recognises that a range of housing allocation sites will be required to deliver balanced housing growth across the district and GBBCHMA.

Comment

Representation ID: 7113

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Contributing a larger proportion of homes to the unmet needs of the GBBCHMA would improve the affordability of homes and in turn support existing services. 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 Walsall and Wolverhampton. Although the importance of brownfield land is acknowledged as part of a balanced housing strategy, it is important that over reliance on these sites does not result in an overprovision of flatted development unable to meet a range of needs, reduced affordable housing, compromising the existing landscape character of village settlements.

Comment

Representation ID: 7114

Received: 31/05/2024

Respondent: St Philips

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. In addition, it would appear that windfall sites have been double counted, with the Indicative Growth Table for Option I on which the housing delivery figures for the Plan have been based including windfall allowance.

Object

Representation ID: 7115

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

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: 7116

Received: 31/05/2024

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Details regarding Wombourne and its services can be found in paragraphs 5.1 – 5.3 of the full representation. The site of Bratch Common Road would be able to deliver development in the first five to ten years of the Plan period. Details of the site, including landscape sensitivity, highways and access, sustainability appraisal and remediation can be found in paragraphs 5.5 – 5.10 of the full representation. A vision document is attached to appendix two.

Comment

Representation ID: 7230

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Broadly, St Philips supports the Council’s approach to assessing its minimum LHN. St Philips welcomes the fact that the Council has reflected on the critical concerns raised in response to the previous Publication Plan in respect of omitting completions from the housing requirement. However, the NPPF and PPG are clear that the figure generated is a minimum and it is not clear whether the Council has considered –
A) An affordable housing need uplift would be required to account for the in-migrating households from the Black Country and Birmingham
B) The Council’s current approach seeks to promote unsustainable patterns of commuting. The Council has not adequately addressed whether there would be a sufficient supply of housing to meet the employment needs identified
The Council should prepare a further SHMA or Topic Paper which considers whether affordable housing or economic uplifts should be applied to the LHN figure.

Object

Representation ID: 7231

Received: 31/05/2024

Respondent: St Philips

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Unmet housing needs – St Philips welcomes the Council’s commitment to addressing part of the GBBCHMA unmet need through the Local Plan review. Despite the changes within the NPPF it remains entirely appropriate and in accordance with the NPPF to make provision for the cross-boundary needs. St Philips has significant concerns regarding the proposed contribution to the unmet need following the reduction in the contribution. The Council does not propose to address Birmingham’s needs at all, or meaningfully contribute to the BCAs. St Philips considers that the Council is seeking to defer rather than deal with the issue, and it is critical that the Council makes an appropriate contribution towards the unmet need now as the needs are acute. There are sites throughout the District that could sustainably contribute to addressing more of the unmet need – with the site at Wolverhampton Road, Wedges Mills being one.