Publication Plan April 2024

Comment

Representation ID: 7173

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Whilst important that consideration is given to the potential requirement for a species mitigation licence, this should be identified within the supporting text or the Natural Environment and Biodiversity SPD for information purposes only. The requirement should be deleted from NB1. The provisions are reliant upon Natural England responding in relation to an initial licence application which is considered onerous and unnecessary given NE are not required to grant at this stage. To require this input ‘upfront’ has the potential to unnecessarily slow the submission of applications. The policy is unsound as it is neither justified not consistent with national policy.

Comment

Representation ID: 7174

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Taylor Wimpey are supportive of the need to address net losses to biodiversity. Given the 10% BNG is a mandatory requirement for all developments, the detailed provisions in NB2 are considered unnecessary and a duplication of national policy requirements. The policy should be simplified with clauses A-C deleted so as to avoid potential misinterpretation within the wording.

Comment

Representation ID: 7175

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Amendment to the policy to read ‘all trees, woodland and hedgerows should be protected and retained wherever possible’.

Object

Representation ID: 7176

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Although a move towards delivering greater energy efficiency is supported, it is important that the Development Plan’s response to climate change is realistic and consistent with national legislation and policy provisions. The recent Ministerial Statement was clear that Local Plans should not be placing onerous requirements on developers which exceed the requirements of national Building Regulations. The Local Plan is not supported by robust evidence to support this approach. There is the risk of making various assumptions without vigorously testing against the specifics of the revised policy and the potential cost implications for proposed developments. The policy conflicts with Government advice and should be deleted.

Comment

Representation ID: 7177

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Clause A7 – there are issues of data protection and consent surrounding the recording and sharing of data with a third party and/or the reliance on the cooperation of private home-owners to share data in order to meet with the requirements of any monitoring condition associated with the policy. There is no evidence that the Council have considered or addressed the GDPR implications of this requirement, it is not practical to be delivered in the form proposed and is therefore considered unsound.

Comment

Representation ID: 7178

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Taylor Wimpey fully appreciates the value of Whole Life-Cycle Carbon Assessments and the need for some post construction, pre-occupation assessment. There remains concerns over the inclusion of the policy, in particular when read alongside paragraph 13.15. Clause C2 is considered unnecessary with Building Regulations providing the basis on which the construction of buildings should adhere to. There should be no expectation placed on housebuilders to exceed national standards which have already been through vigorous viability testing.

Object

Representation ID: 7179

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Clause C4 raises a number of concerns and is not considered practical in the form proposed, nor is it considered necessary given requirements under Building Regulations. In terms of the introduction of a planning condition requiring verification of embodied carbon quantities, this does not meet with the 6 tests for planning conditions. The requirement for an Energy Statement is referenced only within the supporting text, if deemed necessary to deliver the requirements of NB6C it should be explicitly set out within the policy itself. The policy is unsound as it is neither justified not consistent with national policy.

Support

Representation ID: 7180

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Land off Pool House Road is included with SA3 as an allocation for a minimum of 82 dwellings. This is supported by Taylor Wimpey but some minor amendments are required to ensure the policy is sound. Details regarding Wombourne can be found in paragraphs 5.3 – 5.7 of the full representation. This site is capable of early development in the first five years of the plan, and all site details can be found in paragraphs 5.11 – 5.14 of the representation, with the sustainable connectivity details in paragraphs 5.15 – 5.20.
As outlined in the site proforma, a specific requirement is for highway and pedestrian connectivity between site 285 and site 459, but due to intervening third party land on the public right of way, Taylor Wimpey cannot provide a link between the sites. It is therefore necessary that the proforma be amended to state that only pedestrian access is required between the sites. This would ensure that the site-specific matters for site 285 within SA3 is legally compliant.

Comment

Representation ID: 7240

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Taylor Wimpey considers that the Council’s approach to calculating its minimum LHN figure is broadly correct and welcomes that the Council has updated the LHN figure since the 2022 PP. Notwithstanding the above, Taylor Wimpey would like to highlight the LHN figure is a minimum starting point and considers that the SHMA update and 2024 PP have not sufficiently considered whether an uplift to the minimum LHN figure is required. The NPPF recognises that there is an implicit link between housing need and economic growth, and they should not be decoupled from each other. Taylor Wimpey would encourage the Council to produce a Topic Paper or update to the SHMA which addresses whether an uplift to the minimum LHN figure should be applied.

Comment

Representation ID: 7241

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Buffer - It is critical that the Local Plan’s housing trajectory has sufficient land supply across the plan period. Taylor Wimpey supports the principle of the Council’s approach of ensuring a sufficient headroom is built into the supply and applying the buffer to both its housing need and the contribution to the unmet need of the Black Country. However, Taylor Wimpey has concerns regarding the reduction in buffer from 13% to 10%. The proposed 10% buffer is well below the range identified by other Councils and found sound at the examination. Taylor Wimpey recommends that a minimum of circa 20% headroom should be incorporated into the Local Plan.