Publication Plan April 2024

Comment

Representation ID: 6830

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Kinver - Paragraphs 2.1 – 2.8 set detail the recent history of the Plan and NPPF changes.

Wombourne - Paragraphs 2.1 – 2.7 set detail the recent history of the Plan and NPPF changes.

Object

Representation ID: 6831

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Please refer to our previous representations made in December 2022 on this matter at Appendix 1. It is not clear how the HMA authorities intending to submit before June 2025 can meet the duty to cooperate when leaving such a significant scale of unmet need. The previous Publication Plan demonstrates that South Staffordshire has suitable and deliverable capacity to deliver at least 4,000 dwellings towards the unmet need.

Object

Representation ID: 6832

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

The reduced contribution is not reflective of the functional links between SS and the Black Country. SS is encouraged to revisit the contributions proposed and reengage with the wider HMA authorities.

Comment

Representation ID: 6833

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The core theme of the Publication Plan is protecting the Green Belt which is emphasised by the removal of many proposed GB sites. This is based on a fundamental misinterpretation of Paragraph 145 and 230 of the NPPF. This notwithstanding, we have no in principle concern in respect of the wording of draft policy DS1 itself and support the plan as a whole, however we emphasise the importance of reconsidering the approach to reviewing the Green Belt.

Support

Representation ID: 6834

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The policy is considered to align with NPPF paragraph 147. Sufficient flexibility is provided by the policy where contributions could be provided in lieu of a specific scheme being identified, which is supported. As such, it is considered to be sound.

Object

Representation ID: 6835

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Kinver - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The change to the housing target based on the changes to the NPPF cannot be relied upon as justification for not reviewing the Green Belt in South Staffordshire. Approximately 10% additional homes will be provided to “ensure plan flexibility”, this is not however reflected in the housing target, which would increase the need by 473 dwellings. It is assumed the District intend to provide for this allowance through windfall sites, however additional sites should be allocated to plan positively and to ensure sustainable locations come forward.

Object

Representation ID: 6836

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Wombourne - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The change to the housing target based on the changes to the NPPF cannot be relied upon as justification for not reviewing the Green Belt in South Staffordshire. Approximately 10% additional homes will be provided to “ensure plan flexibility”, this is not however reflected in the housing target, which would increase the need by 473 dwellings. It is assumed the District intend to provide for this allowance through windfall sites, however additional sites should be allocated to plan positively and to ensure sustainable locations come forward. The site at Strathmore Crescent is available and could come forward early in the plan period to meet the additional needs of the district.

Object

Representation ID: 6837

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Kinver - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The policy sets out that growth will be directed towards the most accessible and sustainable locations. Kinver is identified as a ‘Tier 2 Settlement’ – details of Kinver are in paragraphs 3.23 and 3.24 of the full representation. The Spatial Strategy limits the growth of Tier 2 settlements, this is not considered reflective of the inherent sustainability of Kinver which have been disproportionately restricted by the updated Publication Plan.

Object

Representation ID: 6838

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Kinver - The omission of Hyde Lane, Kinver is in part a misinterpretation of the NPPF. Kinver benefits from a range of services and is highly accessible. There are proposed allocations in Kinver and Wombourne which have been identified as sustainable locations for development. Therefore, it is considered that these settlements could provide further growth for the District.

Object

Representation ID: 6839

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Legally compliant? No

Sound? No

Duty to co-operate? No

Wombourne - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. The policy sets out that growth will be directed towards the most accessible and sustainable locations. Wombourne is identified as a ‘Tier 2 Settlement’ – details of Wombourne are in paragraphs 3.13 and 3.14 of the full representation. The Spatial Strategy limits the growth of Tier 2 settlements, this is not considered reflective of the inherent sustainability of Wombourne which have been disproportionately restricted by the updated Publication Plan.