Publication Plan April 2024

Object

Representation ID: 6946

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan is not capable of being found sound, subject to Modification. This is onlyachievable through the full assessment and reconsideration of sites and settlements across the District, including our clients’ land interests set out within this submission.

Object

Representation ID: 6947

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

South Staffordshire must be able to demonstrate that it has engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross-boundary strategic issues,
and the requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question of effective cooperation. We consider that the Council, on the available evidence have failed to demonstrate sufficient cross-boundary working.

Object

Representation ID: 6948

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

While we endorse the overall strategy found in the SA, there are still certain problems with its implementation, including an identified inconsistent approach to site selection that has arisen as a result of multiple iterations of the SA having being produced concerns relating to the legal compliance and soundness of the Plan overall are as follows:
The revised strategy is considered to prioritise avoiding Green Belt release over fulfilling a justified housing requirement
When there are other sustainable development opportunities available, the approach unnecessarily relies on two key development sites to provide a sizable amount of the housing requirement the strategy will not, therefore, deliver a sustainable pattern of development in accordance with the provisions of the NPPF.
Areas of noncompliance are as follows:
The assessment of proposed allocations and scoring of reasonablealternatives has been inconsistent
For there to be compliance with Article 5 of the SEA Directive, thepublic must be presented with an accurate picture of what
reasonable alternatives there were to the proposed policies and why they were not considered to be the best option. Given that there have been multiple iterations of the SA, we do not consider that the public will have a clear understanding of the all reasonable alternatives both in terms of strategy and specific sites.

Object

Representation ID: 6949

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Disagree with the Council's calculation of the local housing need using the standard method and additionally consider that there is substantial evidence to support an uplift to the minimum standard method housing and is considered to be between 364 to 441 dwellings per annum.
There will be about 101,000 dwellings worth of unmet needs over a 22-year period beyond what is provided by current and emerging Local Plans in the corresponding local authority regions.

It is not thought that South Staffordshire Council's proposed commitment of 640 homes would adequately address unmet need. The minimum contribution that should be taken into consideration is the 4,000 houses that were originally suggested and included in the
November 2022 Draft Plan for South Staffordshire.

More details are provided in a detailed
Housing Need Assessment report, found at Appendix 1 of the submission.

Object

Representation ID: 6950

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Boningale Homes do not support an approach where by compensatory land is required when sites, that have demonstrated Exceptional Circumstances or Very Special Circumstances, are removed from the Green Belt.
The Council should be reminded that the allocation of land as Green Belt does not indicate any intrinsic landscape, biodiversity or ecological value and that indeed Green Belt is a policy designation only. Accordingly, where it is demonstrated that land is required to be released from the Green Belt to meet housing needs, it is inappropriate and unjustified to require compensatory measures.

Object

Representation ID: 6951

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Boningale Homes is supportive of the settlement hierarchy and particularly the identification of Codsall as a tier 1 settlement and Brewood as a tier 2 settlement. We submit that further growth should be allocated to the tier 1 and tier 2 settlements to ensure the housing need figure.Whilst an approach to the appropriate use of brownfield and previously developed land is supported, with regard to wider regeneration aspirations however realistic timeframes have to be considered when projecting
completions from such sites.
With specific regard to meeting rural housing needs, we do not believe that the Council’s approach to the development needs of the Rural Area adequately reflects best practice. Despite evidence of need in the rural area, there is very limited scope provided for additional development in rural parts of the District beyond
committed and allocated development. Planning new homes in suitable rural settlements, such as Bishops Wood, has an important role in ensuring the long-term vitality, vibrancy and sustainability of rural communities.
consider that a greater level of development should be
directed towards the rural settlements in South Staffordshire, whilst noting the clear benefits of directing the majority of growth in tier 1 and tier 2 settlements to ensure that the aims set out above are delivered.

Object

Representation ID: 6952

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As is detailed in Appendix 1 of the SA, the Land East of Bilbrook the proposed allocation scores as follows;
• Landscape: scored major negative impacts
• Green Belt: scored major negative impacts
• Education: scored major negative impacts

In addition to the above, we have some remaining concerns relating to land assembly matters, the commitment of the landowners to bring the site forward in line with the emerging trajectory and the viability of the proposed infrastructure required to make the site suitable for allocation.

Object

Representation ID: 6953

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is important to note that housing mix as identified in the Council’s latest evidence base will only provide a snapshot in time in relation to the current housing needs. As such, the policy should provide for flexibility going forward so that the Plan is able to respond to changes in circumstances at the time of an application being submitted to the Local Planning authority so that development opportunities can make better use of the land available whilst responding to the housing needs at that time.

Object

Representation ID: 6954

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The above policy requires the provision of affordable housing on all major development sites. Boningale Homes support the Council in its pursuit of securing affordable housing to meet the needs of local communities across
the borough. The Framework is clear that the delivery of affordable housing should account for both need and the effects on development viability.

As a general observation the targets up to 40% seem high given the underlying residential sales rates experienced. In addition to more detailed appraisals forming part of the viability evidence base (including how each of the assumptions are being applied), it is not currently clear what underpins the conclusion in regard to affordable housing need.

Object

Representation ID: 6955

Received: 31/05/2024

Respondent: Boningale Homes ltd.

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Current provision is largely focused on sheltered housing and care homes. However, these do not address the ever-rising demand from homeowners to access age-appropriate housing, of the same tenure. The Council’s evidence base identifies a critical need for specialist
accommodation, The Housing Market Assessment 2024 indicates approximately one third (36.5%) of the population will be aged 60 or over in 2041. The Housing Market Assessment 2024 indicates a need for 1,198
additional specialist homes up to 2041, including 1,000 sheltered homes, and 198 extra care units. A further 153 additional registered care spaces may also be required. Whilst we accept that not all ‘care schemes’ should be classed as C2, a blanket approach to the provision of affordable housing would result in affordable housing being required on schemes which are already being delivered in order to address a specific specialist need. This is considered unacceptable and will not aid in the delivery of specialist accommodation to meet the needs of older and vulnerable residents. The Council should support development opportunities, such as those
proposed by Boningale Homes at Codsall and Hockerhill Farm that seek to provide modern, state-of-the-art specialist care facilities to meet the identified need within the District.