Publication Plan April 2024

Object

Representation ID: 6906

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Identify a significant shortfall in supply(5,649 dwelling supply shortfall) set out in their Table 1. This should be rectified through the allocation of additional sites, including Land off Bridgnorth Road, Wightwick.

Object

Representation ID: 6929

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Objection to draft Policy DS5 is made to the Council’s approach to ignoring growth adjacent to the urban edge of Wolverhampton, including in recognition of the SSLPR’s contribution to assisting to meet the unmet needs of the GBBCHMA. As drafted, we consider Policy DS5 is not positively prepared, justified, effective nor consistent with national policy and therefore cannot be considered sound in line with the NPPF. The Spatial Strategy fails to recognise that there are locations in South Staffordshire on the edge of adjacent urban conurbations which are highly sustainable and will deliver a more appropriate pattern of growth. Consider that the substantial unmet needs arising from the GBBCHMA represent cogent exceptional circumstances for Green Belt boundary amendments.

Object

Representation ID: 6930

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Draft Policy SA3 omits Land off Bridgnorth Road, Wightwick as an allocation. There are no technical or environmental reasons why Land off Bridgnorth Road cannot be allocated, with the only concerns raised in the assessment of the site in the Housing Site Selection Paper either considered to be unfounded or able to be dealt with through detailed design and masterplanning. Land off Bridgnorth Road is developable and easily deliverable within the early part of the SSLPR Plan period. The site is well placed to access a number of key services and facilities, including Wightwick Hall Secondary School and Sixth Form which is directly adjacent to site and is easily accessible by active travel modes. it is considered that the contribution of Land off Bridgnorth Road to the purposes of the Green Belt is far more limited than the wider assessment of parcels S59 and more specifically S59C. it is considered that concerns relating to landscape impact with specific reference to Land off Bridgnorth Road are unfounded, and not a constraint that renders the site unsuitable as an allocation for residential development.it is considered that concerns relating to trees are unfounded and not a constraint that render Land off Bridgnorth Road unsuitable as an allocation for residential development.

Object

Representation ID: 6931

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Draft Policy HC1 lacks flexibility in seeking to require a minimum of 70% of residential dwellings on new development to be 3 bedrooms or less.

Object

Representation ID: 6932

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? No

Sound? Yes

Duty to co-operate? No

Draft Policy HC2 is unduly onerous in requiring residential development to achieve a minimum of 35 dwellings per net developable hectare, without sufficient flexibility.

Object

Representation ID: 6933

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Draft Policy HC4 seeks to require compliance with Building Regulations Part M4(2) without sufficient evidence.

Object

Representation ID: 6934

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy is ambiguous and does not provide sufficient clarity with regard to the expectation of an applicant for a major development proposal, particularly given the Council does not publish its Self-Build and Custom Housebuilding Register or any data relating to it publicly. Further, it is considered the Council’s Self-Build and Custom Housebuilding Register couldn’t be relied upon as clear evidence to support such a policy intervention in any case given the ability for an individual to enter their details on to multiple Registers, skewing the data derived, when that individual may have no means or desire to carry out such a project in reality in any case.addition, the delivery of self-build and custom build plots on larger residential schemes are unlikely to be desirable to those on the Councils’ Self-Build and Custom Housebuilding Register given the majority of self-builders and custom builders tend to seek standalone plots in the open countryside. It is also considered that the requirement for developers to actively market plots at a reasonable price for a minimum period of 12 months as set out in the third paragraph of draft Policy HC8 is unreasonable.

Object

Representation ID: 6935

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The fourth paragraph of Draft Policy HC12 seeks to implement, as a minimum, the requirements of the Nationally Described Space Standard (NDSS) for all new residential development in South Staffordshire.
L&Q Estates are supportive of the NDSS being used to influence the standard of housing developments, however there may be instances where greater flexibility is required in order to meet need. Further, L&Q Estates consider that the introduction of such standards is contrary to the NPPF which is clear that optional technical standards for accessible and adaptable housing should only be introduced where this will address an identified need for such properties. L&Q Estates consider that if the Government had expected all properties to be built to NDSS, that they would have made such standards mandatory and not optional requiring sufficient evidence.

Object

Representation ID: 6936

Received: 29/05/2024

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Consider that this policy is unnecessary given it seeks to go further than current Building Regulations and given the Future Homes Standard which is due to be implemented in 2025, in advance of the likely adoption of the SSLPR. This will update Part L of Building Regulations and require new build dwellings to be future-proofed with low carbon heating and world-leading levels of energy efficiency. It is noted that a Written Ministerial Statement issued by Baroness Penn and delivered by Housing and Planning Minister Lee Rowley MP in December 2023 sets out clear direction on the need for Local Plans to avoid setting energy efficiency standards which go beyond current and future planned Building Regulations requirements.