Publication Plan April 2024

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Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6778

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

Our client objects to DS4 / to the level of housing growth being planned for and the Council’s proposed change in their housing growth strategy.

Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6779

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

The only justification the Council has provided to support the change in their growth strategy is related to changes to the NPPF. Extracts from the NPPF can be found in the full representation. We acknowledge the amended wording allows for authorities to choose whether to review Green Belt boundaries but there is now no reference to reviews being based on meeting objectively assessed needs and Councils have always have to demonstrate that exceptional circumstances exist. We fundamentally disagree with SSDC’s interpretation of the policy and the use of the revised NPPF to justify the change in strategy to reduce Green Belt release and the number of homes being proposed to the GBBCHMA shortfall.

Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6780

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

Planning for the minimum local housing need is not aspirational and we object to the proposed strategy as it does not accord with national policy. The PPG states the standard method is the starting point and therefore do not support the Council only planning to deliver homes to meet the minimum housing need. The 10% buffer comprises the proposed 640 dwelling contribution and is therefore not considered a significant buffer.

Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6781

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

We support the contribution to the unmet need of the GBBCHMA but object to the 640 dwelling contribution. Details on the Duty to Cooperate Topic Paper and the NPPF can be found in the full representation. It is considered that the significant reduction in meeting the shortfall is without justification and also an ineffective strategy for addressing a strategic matter.

Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6782

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

The 2022 Publication Plan proposed 4,000 dwellings to the unmet need and therefore SSDC does have capacity to practically deliver more than 640 dwellings. The only thing that has changed is the NPPF. We therefore do not consider that sufficient justification has been provided on how the 640 dwelling contribution has been calculated and that other land in the District is now not suitable. SSDC have previously objected to plans being produced by other GBBCHMA authorities that were proposing a minimal contribution.

Object

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 6783

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

The increase in contribution of employment land will create unsustainable patterns of travel as a greater number of people have to commute into the District for employment, as SSDC is failing to provide enough homes to meet the economic growth ambitions.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 6784

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

We object to DS5. Paragraph 5.13 states that SSDC has tested further spatial strategy options. Option I was not previously consulted on or identified as a preferred option in the 2022 Publication Plan. The PPG requires a Sustainability Appraisal and we do not consider that sufficient justification has been provided for pursuing Option I rather than pursuing Option G. Option I appears to have been ‘created’ by the Council in order to achieve their interpretation of the amended NPPF and support the reduction in housing.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 6785

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

SSDC claim Option I directs growth towards sustainable non-Green Belt development sites. SSDC have not provided justification on the reasonable alternatives assessed around the Tier 1 settlements for the HMA contribution and why the proposed capacity is limited to 640 dwellings. There are dismissed sites which perform comparatively to the sites proposed to be allocated (examples given in the full representation). There is inconsistency with how Option I has been applied to Green Belt sites. The Spatial Strategy should be amended to reflect a strategy which is positively prepared and fully justified.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 6786

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

We do not consider that SSDC are achieving the objective to “meet needs in a manner which builds on the district’s existing infrastructure and environmental capacity”. Implications of removing Cross Green as an allocation are set out in DS5 representation and in DS4, SA3 and SA5 representations. Brinsford Park and Ride is listed in Appendix A of the IDP as an infrastructure project, without the allocation of Cross Green, the land will not be safeguarded to facilitate the future delivery of a park and ride station at Brinsford. Land at Cross Green should be re-allocated.

Object

Publication Plan April 2024

Policy EC3: Employment and Skills

Representation ID: 6787

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The requirement for an Employment and Skills Plan to be prepared for all developments of 100 or more residential units is not supported by Taylor Wimpey. It is not clear how any certainty could be provided through the provision of such a Plan. It should be recognised that the business model employed by Taylor Wimpey and other major housebuilders relies upon subcontractor businesses. Despite this, if Cross Green were re-allocated, construction stage opportunities are identified in the full representation.

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