Publication Plan April 2024

Comment

Representation ID: 7208

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

Land South of New Road, Featherstone
Concept Development Plan in Appendix 1. The site benefits from a wide range of local services and facilities within Featherstone, including a primary school, children’s centre and nursery, convenience stores, doctors’ surgery, community hall and leisure facilities. A bus service runs along New Road immediately to the north of the site. The site has potential capacity for 400 new homes which comprises two sites split by Rabbit Lane. David Wilson Homes is of the view that Featherstone should be identified as a Tier 2 settlement, and the growth at this site is in line with other Tier 2 settlements.
David Wilson Homes believes that Site 396 continues to be assessed incorrectly in the plan’s evidence base. It scores ‘major negative’ for landscape and townscape despite the Landscape Study (2019) scoring the landscape sensitivity as ‘low moderate’, and therefore this should score ‘minor negative’ overall. The site scores ‘major negative’ for education, however no justification is provided for this when it is acceptable walking distance to Featherstone Academy Primary School, and therefore should score ‘minor negative’ overall.
Site 396’s constraints have been overplayed in the Council’s evidence and, as such, Site 396 should be a proposed housing allocation in the Plan, or as a minimum, safeguarded land. It is accepted that a draft policy proposing to allocate or safeguard might be subject to a clause that it should not come forward until the link road has been delivered.

Object

Representation ID: 7209

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Details on duty to cooperate and shortfalls for neighbouring local authorities are detailed in the relevant paragraphs in the full representation. It is not clear how the HMA authorities, who intend to submit their plans before the 30th June 2025, can meet the duty to cooperate when leaving such a significant scale of unmet need. The previous Publication Plan demonstrates that South Staffordshire has suitable and deliverable capacity to deliver at least 4,000 homes which can contribute to the GBBCHMA unmet need. No plan should be progressed to adoption until the scale of the unmet need and where it is to be delivered has been agreed.
Approximately 10% additional homes will be provided to ensure “plan flexibility”, this is not reflected in the housing target, which would increase the need by 473 dwellings. It is assumed the district intends to provide for this allowance through windfall sites, however additional sites should be allocated to meet this need.

Object

Representation ID: 7210

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is a clear inconsistency in the proposed new settlement hierarchy, particularly with regards to Featherstone. Featherstone has a strong offering of services and facilities which are commensurate with other Tier 2 settlements. The audit of services undertaken by the Rural Services and Facilities Audit (2021) makes a clear case for Featherstone being identified as a Tier 2 settlement.

Comment

Representation ID: 7211

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

No changes have been made to this policy since the 2022 Publication Plan. DWH’s comments therefore remain that the policy should be more flexible, recognising that housing needs vary within different areas and on a site-by-site basis. The policy must ensure that the viability of development proposals is protected whilst providing an appropriate housing mix for the site location and local market. A prescriptive housing mix policy would apply a blanket approach which could restrict the ability of new development to respond to the needs of the local area. It is not clear why a highly prescriptive housing mix is included in HC1.

Comment

Representation ID: 7212

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach. Impact on scheme viability is referenced in the existing Policy H2, and there should also be an allowance for a consideration of site viability.

Object

Representation ID: 7213

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

If the Council wishes to adopt the higher optional standards within the Building Regulations M4(2) for accessible and adaptable homes, it should only do so by applying the criteria set out in the PPG. The Council should provide localised evidence making the specific case for South Staffordshire which justifies the inclusion of optional higher standards for accessible and adaptable homes in this policy. There is a need for the policy to be consistent with national standards unless a specific evidenced reason exists for a higher standard to be applied.

Comment

Representation ID: 7214

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

External space standards and amenity spaces should not be explicitly stated within the policy. Planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to achieve suitable quality residential environments.

Comment

Representation ID: 7215

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Object

Representation ID: 7216

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirements for carbon emission reductions in the policy go beyond the Government’s Future Homes Standard roadmap that most developers are working to and on which they have based their future plans. We agree with the need for advancing carbon reduction standards but these targets are not the most appropriate way to achieve the desired outcomes. It may not be the best solution to build ahead of the Future Homes Standard as it may have a potentially detrimental local impact on delivery through a lack of sufficiently skilled labour available to implement these new technologies at scale. South Staffordshire should be flexible in the application of this policy to take account of site-specific constraints which may constrain the onsite provision of, or offsite connection to, renewable/low carbon energy generation.

Comment

Representation ID: 7217

Received: 31/05/2024

Respondent: David Wilson Homes

Agent: Turley

In principle, we do not object to a Whole Life Carbon Assessment (WLCA) being required, there are issues surrounding data collection to be able to undertake a proper WLCA. Details on Environmental Product Declarations are in the relevant paragraphs under NB6C in the full representation. Careful consideration should be given to the timing of submission of the WLCA to the Council and should be part of the planning conditions.