Publication Plan April 2024

Object

Representation ID: 6850

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. 2022 Rep – the policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach.

Comment

Representation ID: 6851

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. 2022 Rep – Bellway support the provision of accessible homes that are suitable to meet the needs of older people, however if the Council is to adopt the higher optional standards within the Building Regulations for accessible and adaptable homes, it should only do so by applying the criteria set out in the PPG.

Object

Representation ID: 6852

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. 2022 Rep – the requirement to meet the NDSS is considered reasonable. External space standards and amenity spaces should not be explicitly stated within the policy.

Comment

Representation ID: 6853

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. 2022 Rep – Bellway support the Council’s endeavours to encourage electric vehicle uptake but should avoid repeating EV requirements which are otherwise secured through Building Regulations.

Support

Representation ID: 6854

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. 2022 Rep – the approach of this policy is welcomed.

Comment

Representation ID: 6855

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Kinver - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. 2022 Rep – the broad themes of the policy are understood and achievable, the policy is not clear on whether this requirement will be triggered where sites are also providing compensatory green infrastructure on sites which have been taken out of the Green Belt.

Comment

Representation ID: 6856

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Wombourne - Please refer to our previous representations made in December 2022 on this matter at Appendix 1. 2022 Rep – an enhancement in the provision of green infrastructure can be achieved on both sites with buffers to the Green Belt to the north and west.

Comment

Representation ID: 6857

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. 2022 Rep – Bellway will work to provide modern and future-proof infrastructure provision within sites to be delivered.

Comment

Representation ID: 6858

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Bellway are supportive of the policy requirement to provide “measures to assist with halting the decline of species and to address biodiversity loss” however this should be proportionate and reflected as such in the policy. We suggest including the wording “proportionate measures”. The list of potential enhancements should be presented as examples and not act as an exclusive and closed list.

Comment

Representation ID: 6859

Received: 31/05/2024

Respondent: Bellway Homes Ltd

Agent: Turley

Any feasible and viable policy should be restricted to regulated energy only. The unregulated energy consumption is the function of residents’ use and cannot be influenced by the developer. Points A2 – A4 refer to regulated energy and any requirements which go beyond national standards should only relate to regulated energy.

Emissions reduction targets should be in line with the latest national standards. The policy should be updated to only reference alignment with the 2025 Future Homes Standard requirements.

Maximising the provision of renewable energy could lead to unintended consequences or contradictions in design. The policy should be updated to achieve net zero regulated carbon emissions where feasible and viable, in line with latest national policy requirements.

Offsetting – the policy refers to both regulated and unregulated emissions and therefore should be amended to regulated emissions only. A viability assessment for the cost of offsetting carbon has to be undertaken and included as part of the viability assessment for the policy to be sound. The Council should set out its expectation on a timeframe for spending the funds collection.

Post occupancy evaluation – concerned over lack of clarity with regard to a sample size, which could potentially put a disproportionate burden on the housebuilder. Post-modelling should be carried out on 10% of homes.

There are a number of potentially significant omissions from the viability assessment that justifies NB6A, the Council should review the assessment to ensure it is sound and meets the requirements of the NPPF.

Text specific to each policy amendment can be found in Appendix 10.