Publication Plan April 2024

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Comment

Publication Plan April 2024

Policy DS4: Development Needs

Representation ID: 7242

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Representation Summary:

Local Plan Review policy – Taylor Wimpey considers that the Council’s current position fails to provide any certainty of an outcome or clearly defined timescale. The Council should introduce an additional Local Plan policy which requires the plan to be reviewed within two years of adoption.

Comment

Publication Plan April 2024

3.6

Representation ID: 7243

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Representation Summary:

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 appropriate and in accordance with the NPPF to make provision for the cross-boundary needs. Taylor Wimpey has significant concerns regarding the proposed contribution to the unmet need following the reduction in the contribution. The Council has suggested that there is not sufficient evidence regarding the quantum of unmet needs and this uncertainty provides adequate justification to defer this issue to a future Local Plan review – this is fundamentally incorrect. Taylor Wimpey considers the planned contribution is insufficient in the context of the severeness of the unmet needs. We are concerned the Council is planning to defer dealing with this issue when it should be addressed immediately. We encourage utilising a functional relationship-based approach which would result in a contribution of c.8,650 dwellings and could be sustainably accommodated in South Staffordshire.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 7244

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Details on the revised spatial strategy can be found in paragraphs 2.38 – 2.42 of the full representation. The land at Clent View Road site has not been allocated for development in either the 2022 or 2024 publication plan. Whilst the Council has outlined its justification for pursuing the preferred spatial strategy, a central tenet of the approach is that the quantum of the GBBCHMA unmet need is unknown and consequently a small contribution is acceptable. It is clear the unmet needs of the GBBCHMA exceed 100,000 dwellings and the Council should not defer this matter to a later date. The release of Green Belt land to help address the unmet need is entirely consistent with the NPPF. It is not compliant with national policy to release only those sites which perform the worst against the Green Belt purposes. There is a need to consider the broader Green Belt policies within the NPPF as a whole.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 7245

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Taylor Wimpey considers that the revised spatial strategy is overly contrived and has been designed to lower the housing requirement and to limit Green Belt release. The previous spatial strategy was considered to be sustainable, as demonstrated by the evidence base which underpinned the PP 2022. Taylor Wimpey strongly encourage the Council to release further Green Belt through the Local Plan review to address the unmet need of the GBBCHMA and should allocate growth on the western edge of the Black Country, specifically the west border of Stourbridge. Stourbridge is sustainably located and provides access to a variety of existing services, facilities and employment opportunities. Taylor Wimpey considers that development on the edge of Dudley should be supported given the functional relationship between South Staffordshire and Dudley.

Object

Publication Plan April 2024

Policy DS5 – The Spatial Strategy to 2041

Representation ID: 7246

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It is clear that the Council will need to release further housing land, either to address the GBBCHMA’s or District’s needs. There are limited options for meeting these long-term needs outside of the Green Belt and very likely that the Council will against need to revisit releasing GB land in due course. Identification of additional safeguarded land will ensure GB boundaries will not need to be altered at the end of the plan period.

Object

Publication Plan April 2024

Policy SA3: Housing Allocations

Representation ID: 7247

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Clent View Road
Details on the site from the SHELAA are in paragraphs 2.66 – 2.70, Green Belt are in paragraphs 2.71 – 2.73 and general site details are in paragraphs 2.74 – 2.80 of the full representation, with a vision document in Appendix 1. The site is adjacent to the western edge of Stourbridge, within a 30-minute walk of the town centre where Stourbridge Town Railway station is available. The site would deliver approximately 400 high-quality new dwellings with a mix of house type and tenure.

Object

Publication Plan April 2024

Policy HC1: Housing Mix

Representation ID: 7248

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

HC1 is too inflexible and should allow for proposed housing mixes to be justified based on market signals and evidence of housing need and demand at the time of decision-making, rather than a prescribed housing mix set out in the current Housing Market Assessment which could quickly become out-of-date. Flexibility is required as the housing mixes across urban, suburban and rural areas will generally be reflective of the locations’ existing characteristics. Whilst Taylor Wimpey supports the Council’s approach of assessing development on a site-by-site basis, they would encourage the Council to apply a degree of flexibility to the policy.

Comment

Publication Plan April 2024

Policy HC4: Homes for older people and others with special housing requirements

Representation ID: 7249

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Representation Summary:

Taylor Wimpey welcomes that the Council is committed to making housing accessible for all. Notwithstanding this, Taylor Wimpey are concerned that the policy is not sufficiently flexible and does not allow for site specific circumstances or viability to be considered, which contradicts the guidance set out within the PPG.

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