Publication Plan April 2024

Object

Representation ID: 7313

Received: 31/05/2024

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

South Staffordshire considers that the Framework Changes are relevant to the change in strategy which underpins its current regulation 19 plan. Key excerpts from the NPPF and relevant case law can be found in ‘Framework Changes: Exceptional Circumstances and Green Belt Review’ in the full representation. Under both the previous and current versions of the NPPF, Green Belt boundaries can be changed if Local Authorities choose to do so because of exceptional circumstances.
Out-of-date evidence and a revised strategy amount to significant changes which are amendments, evidently more than a correction or supplementary and go to the heart of the plan. To roll back so much of the plan indicates that further evidence gathering, and a regulation 18 consultation, would be a more appropriate route. We recognise that this approach means the Council would not benefit from the protection of a 4-year supply, but the repercussions of progressing a plan which is later found unsound is much greater in terms of their ability to direct development and avoiding abortive costs.

Object

Representation ID: 7315

Received: 31/05/2024

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Although the draft plan acknowledges that one of its key roles is to assist in meeting the significant unmet need of the GBBCHMA, the proposed strategy is now not positively prepared and fails to explore all practical and sustainable options, resulting in an unsatisfactory contribution to the GBBCHMA. There has been very limited progress towards solving the issue of the unmet need in the GBBCHMA. We consider that evidence exists to demonstrate the need for a great contribution and to grow proportionately in line with the growing GBBCHMA as a minimum. Details of the GBBCHMA shortfall can be found in ‘Housing Need’ in the full representation. All available evidence suggests that the unmet housing need has not decreased and can be calculated to be in excess of 100,000, so there is no justification for the new approach taken by SS.
We maintain that for this plan to be positive, justified and effective, there needs to be a greater contribution towards meeting the unmet need of the GBBCHMA.

Object

Representation ID: 7317

Received: 31/05/2024

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The spatial strategy now only releases Green Belt in suitable Tier 1 settlements and places a significant reliance on windfall housing delivery without any realistic prospect of that coming forward. The Council is unnecessarily constraining potential by not growing Tier 2, 3, and 4 settlements, growth which has been naturally occurring for centuries. Bishops Wood has the potential for some practical and sustainable growth with a managed transition to the next tier category, needing only minimal additional service/facilities provision to be more sustainable and accessible. The plan ignores existing needs and provides no opportunities to address housing, economic, community facilities, or infrastructure requirements within Tier 4 settlements. Not only does this plan not include any allocations at Tier 4 settlements, it seeks to remove even small allocations.
Details of windfall can be found in the first table of the full representation. The LPA windfall calculations are based on the whole of the Authority and does not accurately reflect windfall delivery in Bishops Wood. A rough calculation of the Councils information on previous windfall performance might indicate that Bishops Wood could deliver 26 dwellings per annum, however the character of Bishops Wood leaves little potential for sub-division of plots. There is no positive plan for Bishops Wood or any Tier 4 settlements, and no consideration for the existing needs and opportunities. The strategy is not appropriate, it provides no room for natural growth of Tier 4 villages.
In order that a more equitable distribution of dwellings is made across the district and to ensure that much needed services and facilities can be sustainably delivered, it is considered that further appropriate allocations can be made to those Tier 4 villages. It is contended that Bishops Wood is one such settlement that is appropriate to receive a small-scale allocation, and site 096 is the most appropriate location for that allocation.

Object

Representation ID: 7318

Received: 31/05/2024

Respondent: Offoxey Road Limited

Agent: Cerda Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Offoxey site stands as the most suitable location within this settlement (Bishops Wood) for delivering growth. It already benefits from a resolution to grant by Planning Committee. By extending proportionately along the southern edge of the village, the site can contribute significantly to the housing needs. Specific site details, including nearby services and facilities can be found in ‘Site Location and Context’ in the full representation. Details of the site assessment and Green Belt for the Offoxey site are in the relevant paragraph. In light of our own assessment of the harm that the development of the site in question, and not including the remainder of the sub-parcel, would have upon the Green Belt, would equate to a moderate score if all of the site were to be developed, and low-moderate score if only partly developed. We assert the Council’s assessment is flawed and does not represent an appropriate basis for justified and effective plan making. Details on highways, ecology, drainage, flooding, utilities and the key benefits of the site can be found in ‘Development Principles’ in the full representation.