Publication Plan April 2024

Object

Representation ID: 6867

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Our client objects to DS4 / to the level of housing growth being planned for and the Council’s proposed change in their housing growth strategy.

The only justification the Council has provided to support the change in their growth strategy is related to changes to the NPPF. Extracts from the NPPF can be found in the full representation. We acknowledge the amended wording allows for authorities to choose whether to review Green Belt boundaries but there is now no reference to reviews being based on meeting objectively assessed needs and Councils have always have to demonstrate that exceptional circumstances exist. We fundamentally disagree with SSDC’s interpretation of the policy and the use of the revised NPPF to justify the change in strategy to reduce Green Belt release and the number of homes being proposed to the GBBCHMA shortfall.

Object

Representation ID: 6868

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Planning for the minimum local housing need is not aspirational and we object to the proposed strategy as it does not accord with national policy. The PPG states the standard method is the starting point and therefore do not support the Council only planning to deliver homes to meet the minimum housing need. The 10% buffer comprises the proposed 640 dwelling contribution and is therefore not considered a significant buffer.

Object

Representation ID: 6869

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We support the contribution to the unmet need of the GBBCHMA but object to the 640 dwelling contribution. Details on the Duty to Cooperate Topic Paper and the NPPF can be found in the full representation. It is considered that the significant reduction in meeting the shortfall is without justification and also an ineffective strategy for addressing a strategic matter.

Object

Representation ID: 6870

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The 2022 Publication Plan proposed 4,000 dwellings to the unmet need and therefore SSDC does have capacity to practically deliver more than 640 dwellings. The only thing that has changed is the NPPF. We therefore do not consider that sufficient justification has been provided on how the 640 dwelling contribution has been calculated and that other land in the District is now not suitable. SSDC have previously objected to plans being produced by other GBBCHMA authorities that were proposing a minimal contribution.

Object

Representation ID: 6871

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The increase in contribution of employment land will create unsustainable patterns of travel as a greater number of people have to commute into the District for employment, as SSDC is failing to provide enough homes to meet the economic growth ambitions.

Object

Representation ID: 6872

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We object to DS5. Paragraph 5.13 states that SSDC has tested further spatial strategy options. Option I was not previously consulted on or identified as a preferred option in the 2022 Publication Plan. The PPG requires a Sustainability Appraisal and we do not consider that sufficient justification has been provided for pursuing Option I rather than pursuing Option G. Option I appears to have been ‘created’ by the Council in order to achieve their interpretation of the amended NPPF and support the reduction in housing. SSDC has produced evidence in order to support their unjustified desire to deliver less housing, rather than evidence informing the strategy.

Object

Representation ID: 6873

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In the adopted Core Strategy, the settlements of Kinver, Perton, Wombourne and Brewood are identified as ‘main service villages’. These have been re-categorised to Tier 2 settlements where growth and release of Green Belt is restricted. This approach will limit growth and constrain their potential to deliver more services.

Barratt strongly object to the assessment of Kinver as a Tier 2 settlement, and to the proposed Rural Settlement Hierarchy. Kinver should remain a ‘main service village’ as it is a sustainable settlement capable of supporting significant growth. Evidence to support Kinver being a ‘main service village’ or Tier 1 settlement can be found in the full representation.

Object

Representation ID: 6874

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SSDC claim Option I directs growth towards sustainable non-Green Belt development sites. SSDC have not provided justification on the reasonable alternatives assessed around the Tier 1 settlements for the HMA contribution and why the proposed capacity is limited to 640 dwellings. There are dismissed sites which perform comparatively to the sites proposed to be allocated (examples given in the full representation). There is inconsistency with how Option I has been applied to Green Belt sites. The Spatial Strategy should be amended to reflect a strategy which is positively prepared and fully justified.

Object

Representation ID: 6875

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our client objects to NB1. There is no national requirement to afford all sites which meet the criteria for designation, with the same protection as if it were designated. We therefore consider that the policy should seek to protect only local designated sites.

Object

Representation ID: 6876

Received: 31/05/2024

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

NB2 states that “consideration must be given to the aims and objectives of the Local Nature Recovery Strategy”. The LNRS is currently being developed by Staffordshire County Council and Stoke-on-Trent City Council. Therefore, the document has not yet been published and no public consultation has been undertaken on the document. NB2 has not been informed by up to date information and shaped by evidence and is therefore not justified or consistent with national policy.