Publication Plan April 2024

Support

Representation ID: 6523

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes generally supports the policy approach set out in Policy DS4.

Comment

Representation ID: 6524

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Unmet need from neighbouring authorities – details of unmet need in paragraphs 3.8 – 3.15 in full representation. Lovell Homes supports the Council in providing a contribution to assist in meeting these unmet needs, however, raises concerns that this is not evidence based. The capacity-led approach will need to be explored and tested through the EiP.

Comment

Representation ID: 6525

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Economic uplift – further consideration should be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth. Further evidence is necessary to consider the balance between jobs and the working age population that would be necessary to satisfy the jobs demand.

Support

Representation ID: 6526

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the proposed spatial strategy to 2041 which recognises environmental capacity and seeks to make best use of existing infrastructure whilst recognising opportunities to deliver new infrastructure.

Settlement hierarchy – Lovell Homes supports the settlement hierarchy which considers the relative sustainability of villages within the District. Wombourne achieved one of the highest services/facilities rankings of all villages within the District despite it not benefitting from a railway station and Lovell Homes supports the identification of it as a Tier 2 settlement.

Spatial distribution of housing growth – Lovell Homes supports the distribution of housing growth to the most sustainable villages. Lovell Homes considers that the proposed development strategy has due regard to where housing needs exist.

Object

Representation ID: 6527

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Lovell Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Lovell Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District.

Support

Representation ID: 6528

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the efficient use of land and supports the flexibility provided by HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure.

Support

Representation ID: 6529

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the mechanism within HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Viability is dynamic and the Council’s evidence base relates to a snapshot in time.

Object

Representation ID: 6530

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered that a specific requirement for bungalows is not appropriate if instead the Council pursues a policy of requiring 100% of all homes to meet optional M4(2) requirements.
The Government has consulted on raising accessibility standards for new homes but the requirement for all homes to meet M4(2) standards is yet to be mandated. If the Council intends to pursue a policy in respect of M4(2) standards this must be evidenced. Lovell Homes considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.
The Policy should be amended to require a maximum of 50% of all new homes to be delivered to meet the optional M4(2) standards, especially where this could be in addition to other homes for older people and others with special housing requirements required by Policy HC4.

Support

Representation ID: 6531

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

The 2022 SHMA identifies 30 applicants on the self-build register as of Spring 2022, noting that 10 of these applicants are also on a register within another LPA. This demonstrates a very low level of demand. Lovell Homes considers HC8 provides a justified and proportionate approach to meeting this specific need, which requires the consideration of the Council’s Self Build Register on major developments but falls short of requiring a specific percentage of provision.

Support

Representation ID: 6532

Received: 31/05/2024

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance.