Publication Plan April 2024

Object

Representation ID: 6773

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy MA1 requires the submission and approval of site wide masterplans for the strategic sites to precede the submission of planning applications, or as part of that planning application process. They will be a material consideration in the determination of the planning applications for the strategic sites. Approval prior to the submission of planning applications in particular, has the potential to delay deliveryof these strategic housing allocations within the plan period, thereby running the risk of the Council not delivering the 1,877 dwellings identified as coming forward from them. Vistry considers that the 10% buffer of overprovision is therefore not sufficient to overcome the consequence of this potential nondelivery
or shortfall in delivery from the two strategic sites within the plan period.

Object

Representation ID: 6775

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Vistry does not dispute the general level of housing the Council is proposing for its own needs to be provided within the plan period. strongly objects to the vast reduction in unmet need provision, given the overall and increasing GBBCHMA shortfall and any subsequent lack of agreement to this reduced figure by the GBBCHMA Councils. Furthermore, the figure of 640 in Policy DS4 appears to have been arrived at simply as a consequence of the capacity of the sites chosen to meet its own identified needs and the capacity-led development strategy it has chosen to pursue. Whilst to a certain extent this is a product of the changes to the NPPF, it should not negate the requirement to plan effectively for increasing housing needs. It is effectively an arbitrary number/provision. Furthermore, it is not clear which allocated sites or locations are making this
provision. Vistry considers, in the interests of transparency, that this should be made clear in the Plan.

Object

Representation ID: 6776

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The 2041 Plan proposes to focus the majority of its housing requirement within two new strategic sites. It is recognised by Vistry that there is an inherent finite capacity for development within smaller settlements before other options have to be considered to accommodate the growth required, although Vistry maintain that further expansion of Bilbrook/Codsall, given its sustainable credentials is considered possible and sustainable.number of the allocated sites have considerable constraints that affect their housing capacities that have not been fully recognised. As a result, they are not fully deliverable within the plan period raising questions as to whether they are in fact the most
appropriate locations for the development. The 2041 Plan is unsound in this respect.

Object

Representation ID: 6791

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy SA3 identifies a number of housing allocation that are carried forward from the 2018 adopted Site Allocations Document on safeguarded land. It is some six years since these sites were allocated/identified, and yet the majority have not come forward for development. Vistry considers this raises questions about their realistic deliverability and capacities within the plan period. The housing sites 285/459, also contain three parallel high voltage electricity power lines running across the site meaning that significant mitigation would be required and again potentially affecting site capacities.Vistry considers that Tier 2 (and below) settlements cannot sustainably accommodate such large increases in housing and that a proportion of this should be directed back to sustainable Tier 1 settlements, notably Bilbrook. Policy NB2 requires a minimum of 10% biodiversity net gain, is not clear to
what extent the site capacities of the allocated sites (strategic or otherwise) have taken this into account
– this is particularly pertinent to those allocated sites brought forward from the adopted Site Allocation
Document given this predates the Environment Act.

Object

Representation ID: 6803

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Omission site: LAND SOUTH OF PENDEFORD HALL LANE, BILBROOK

The Vistry site at Pendeford Hall Lane is both viable and deliverable within the 2041 Plan period. It is not dependent financially on the delivery of major road or rail infrastructure. The site can start to deliver housing earlier in the plan period, fits perfectly with the development strategy of the local plan. All of the land required to enable the development of a new settlement is in the control of a national housebuilder/master developer.It is unconstrained environmentally and is unconstrained by any need to divert utilities or services. Its viability means that it can deliver policy compliant levels of affordable housinghas no access constraints and is predicated on a clear access and mobility strategy which enshrines the principles of safe, sustainable travel.

Object

Representation ID: 6813

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

This site is 51ha in size and sits to the north of Penkridge, which is a tier one town. Whilst a tier one town, there are limited facilities within Penkridge with just local convenience store. Whilst the concept plan identifies the fairly recent anaerobic digestion plant to the north-east of the site, there is little if no consideration of the implications of this through design. Any new strategic housing scheme directly adjacent to such a sensitive industrial use would therefore need to take into account this use and the associated large buffer area. It is also important to note, that Penkridge is almost entirely reliant on the A449 for access. This is a single carriageway road running north south through the centre of Penkridge. It is noted that the site is located in close proximity to the M6, however junctions 12 and 13 are both located in the region of 4km
away to the south and north. Based on the above, and given the number of uncertainties, Vistry maintain that it is not possible to determine the level of housing and development that the allocation can provide and deliver by 2041. It is highly likely that the total capacity will be below the 1,029 currently proposed.

Object

Representation ID: 6816

Received: 24/05/2024

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The 640 unmet need provision is acknowledged. However, it does not in any way negate the fact that the 640 is a considerable reduction from the 4,000 previously proposed and at time when housing need and the unmet need from neighbouring authorities has only increased. Vistry is supportive of the principle and sentiment of providing for unmet need, but not the level of provision. This is because the quantum of housing for which the Council is planning is wholly insufficient at least as far as the unmet need is concerned. The need does not disappear because of changes in the NPPF. There has been no movement or published update to the GBBCHMA Housing Supply and Need Position Paper despite increasing shortfalls of delivery, collaboration on the Black Country Plan has broken down and each of the three BC authorities is ‘going it alone’ . Fundamentally, paragraphs in the NPPF on DTC and protection of Green Belt effectively produce a conflicting position that Council’s like South Staffordshire have to navigate. Notwithstanding this, Paragraph 27 of the NPPF still requires the SoCG to be agreed, to be produced and publicly made available. This is still outstanding and therefore, Vistry consider that the Plan is unsound on the basis that it is not ‘positively prepared,’ which paragraph 35 (a) of the NPPF