Publication Plan April 2024

Object

Representation ID: 7054

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Windfall development comprises 600 homes. Historic windfall delivery rates have been based on historic permissions to achieve a capacity of 35dph. These developments were based on less onerous policy provisions which did not require the delivery of 10% BNG, NDSS or M4(2)/M4(3) compliant homes. The strategy also fails to address affordability concerns, stating that affordable housing could be reduced to below 30% if viability is an issue.
DS5 is currently considered unsound and is not justified based on proportionate evidence nor positively prepared. It is considered that additional housing allocations capable of accommodating housing needs in sustainable locations accessible to public transport should be delivered.

Object

Representation ID: 7055

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Clowes is seeking the allocation of housing land at Himley with a gross site area of 4.59 hectares and a net site area of 2.59 hectares creating development for 88 units. A site masterplan has been included at Appendix 1. Site details can be found in paragraphs 2.10 – 2.15 of the full representation (residential).

Object

Representation ID: 7056

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Clowes land interests extend to 71.2 hectares and the masterplan at Appendix 2 demonstrates how a range of B2 and B8 uses could be delivered on the site with a combined floor area of 84,844 square metres. The site is deliverable, on a principal commuting route on the edge of a conurbation and it could help deliver improvements to the A449/B4176 road junction. It has the potential to deliver a meaningful contribution to new employment provision within South Staffordshire. Site details can be found in paragraphs 2.11 – 2.14 of the full representation (employment).

Object

Representation ID: 7057

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

HC1 is overly prescriptive in relation to housing mix and pre-empts housing need through the Plan period rather than simply referring to the SHMA. The SHMA shows a clear need for 4-bedroom market and affordable family homes. HC1 should delete specific reference to the delivery of 2 and 3-bedroom homes (proposed text in paragraph 6.2 of full representation). Requiring 70% of properties to be 3-bedroom or less on major developments does not afford sufficient flexibility in order to meet the need to provide for a range of size, type and tenure of different groups.

Comment

Representation ID: 7058

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The use of the phrase ‘disproportionate’ when describing the quantum of 4+ bedroom houses lacks the precision and clarity needed for Plan policy. It does not provide sufficient flexibility. Housing mix should be guided by market signals as reflected in the most up-to-date assessment needs.
The Plan acknowledges an increased need to accommodate home working. HC1 as currently drafted will restrict the ability to meet these needs across the Plan period. The policy should recognise that needs and demand will vary from area to area, including individual settlements. Mix can also influence the viability of development and the policy should recognise this. The policy is considered unsound.

Comment

Representation ID: 7059

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Clowes welcome text which recognises that a blanket approach to density is unlikely to be effective. Reliance on the delivery of housing developments at a higher density does not provide a reliable strategy for the housing requirement and therefore a greater number of housing sites will be necessary to achieve the required housing numbers. The numerous policy requirements places increased pressure on sites and the ability to achieve higher densities. The allocation of additional housing sites would allow for the delivery of much needed homes balanced alongside the need to delivery high quality residential environments.

Comment

Representation ID: 7060

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The use of the term ‘major residential development’ in this context requires a definition. The policy also needs to ensure that evidence is provided when considering viability, especially on brownfield sites. The 30% requirement appears to be supported by the Viability Study but it does highlight the challenges in delivering such a requirement and the need for higher site values to be achieved to deliver this. The Council’s position to continue using S106 agreements to secure the necessary infrastructure to support and mitigate development is supported.

Comment

Representation ID: 7061

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The requirement to ‘pepper pot’ affordable housing is generally supported. However, the policy should recognise that for management purposes, Registered Providers do require a degree of clustering of affordable housing within a development. Clowes supports the removal of the suggestion that grant funding for homes to be provided under the requirements of the policy.
The frequent reference to the Affordable Housing SPD is noted, but it should do no more than clarify the Local Plan policy.

Comment

Representation ID: 7062

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The policy needs to define ‘older people’ as it is unclear as to exactly who the policy is targeting or who would be eligible to occupy such dwellings. The Council do not define what ages will be restricted for single storey development and, as such, the policy requires clarification. There is no evidence to suggest that the provisions of HC4 have been subject to viability testing for major developments. Extra care and retirement living often need a minimum critical mass to be viable and the Council needs to determine which should be able to support the provision of such accommodation, it also needs to provide much greater clarity on when such housing will be required and to make clear that some housing types may be required on any given site.

Comment

Representation ID: 7063

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

It is noted that the Plan continues to require 100% of all housing to be M4(2) compliant. This raises an issue of affordability. Whilst the principle is agreed, it is not a requirement of the whole population to have such a provision and delivering this will have an impact on the overall capacity of sites to deliver new homes. The M4(2) standard is optional within Building Regulations, if the Government had intended that evidence of an ageing population alone justifies adoption of optional standards, then such standard would be mandatory. The requirement for 100% M4(2) homes is not considered to be adequately justified, neither is policy HC4.