Publication Plan April 2024

Support

Representation ID: 6704

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH note the requirement that the standards set out in the appendix are a starting point for considering the level of cycle and car parking required to support a new scheme. We welcome the inclusion of the other criteria upon which the exact level of parking can be determined and agree that this provides a flexible approach to determining the appropriate level of car parking associated with new development.

Just as a point of correction the car parking standards are set out in Appendix H not Appendix I as referenced within the policy.

Comment

Representation ID: 6705

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Paragraph 22 of the Framework confirms that strategic policies should look ahead over a minimum 15-year period from adoption. The proposed plan period would accord with this if the Plan is adopted in 2026. Should it not be adopted by this time, the Council should consider extending the plan period by a further year or two to accommodate any delay with its adopted.

Comment

Representation ID: 6706

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

The basis upon which the 640 contribution towards the Black Country has been arrived at is less clear. It is noted that the First Publication Plan that was consulted upon in 2022 identified a capacity for 4,000 homes to meet the needs of the wider HMA. Clearly at that time, the Council considered there was capacity to deliver 4,000 houses to meet the needs of the HMA.

It is not, therefore, clear why the Council are now stating that there is only capacity for 640 dwellings to meet the needs of the wider HMA. The only apparent change would be the change in policy set out in the Framework which states that local planning authorities do not need to review their Green Belt boundaries to meet their development needs. Clearly, prior to the publication of this guidance the Council had identified sufficient capacity to accommodate 4,000 dwellings.

Object

Representation ID: 6707

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The sources of supply set out in Table 8 total 5,169 dwellings, which exceeds the housing requirement by 443 dwellings. As such, the Council has identified a small flexibility allowance in its supply in order to meet its, and those of the HMA’s, housing needs. The allowance represents less than 10% of the overall requirement. RH do not consider that this is sufficient as one would typically anticipate a 10% non-implementation rate on allocated sites. Furthermore, the Council are already relying on an 11.5% windfall allowance.

Object

Representation ID: 6708

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

In respect of the windfall allowance, whilst we do not dispute that one can be allowed for in the supply RH do not consider that it can continue to deliver as the same rates as per the recent past. Settlement boundaries within the District have not been reviewed and there is, therefore, a dwindling number of opportunities within these to present redevelopment options to increase the supply of housing. RH contend that allocating new sites presents greater certainty that housing needs will be met rather than relying on windfalls coming forward in a sporadic manner.

Comment

Representation ID: 6709

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Whilst the Council have determined to reduce its contribution to meeting unmet housing needs arising in the HMA from 4,000 to 640 dwellings it still intends to make available over 45 hectares of land for employment needs to meet the needs of the Black Country authorities. Again, exceptional circumstances appear to exist for release of land from the Green Belt to meet employment needs of the authorities but not housing needs. Why are meeting the housing needs of South Staffordshire or the employment land needs of South Staffs and the Black Country considered more important than meeting the housing needs of those in the Black Country and wider HMA?

Object

Representation ID: 6710

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RH do not, therefore, consider that the housing requirement of 4,726 homes has been formulated on a sound basis.

Whilst the Local Plan does propose a 640 dwelling contribution to meet the unmet needs arising in the HMA RH do not consider that this contribution will adequately address the unmet need that has been identified and that the approach will not be effective as it would not result in effective joint work on cross boundary strategic matters.

Neither do RH agree that the size of the buffer (443 dwellings) or the reliance on windfalls (to the extent that is proposed) would ensure that housing needs both within the District and meeting the unmet needs of the HMA will be met.

In order to address RH’s concerns, we would wish to see an increased contribution from South Staffordshire to meeting the unmet needs of the HMA. The 4,000 dwelling figure was never tested, and it is wholly insufficient anyway and will not prevent hundreds of thousands of people going without sufficient accommodation.

Object

Representation ID: 6711

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RH do not object in principle to the spatial strategy in terms of the Council seeking to meet its own housing needs. However, RH do object in light of the comments above in respect of wider unmet housing need arising in the HMA and how this is not being addressed at the current time.

The risk in not identifying any specific allocations in Tier 2 to Tier 4 settlements may mean that they do not receive any further development which as a result could leave an aging population resident in the settlement and a corresponding decrease in demand for certain services (i.e. primary schools) or increase for other services (i.e. GP services).

In terms of the split in development that is to be directed to the various tiers of the settlement hierarchy we note that just under half of the housing requirement for the whole District is to be directed to the settlements of Penkridge and Codsall / Bilbrook. Whilst there is certainly merit in directing a significant proportion of growth to the most sustainable settlements it should not be at the expense of ensuring proportionate levels of growth in the remaining areas of the District.

Object

Representation ID: 6713

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The supporting text at paragraph 5.16 indicates that Tier 1 settlements are capable of accommodating new development as they would help facilitate sustainable commuting. In light of this point, RH note that the land at Castlecroft Farm is well located to the existing built-up edge of Wolverhampton City which would provide convenient access for residents who work in the City Centre to access opportunities present there. In terms of meeting any overspill or unmet need that arises in the conurbation RH contend that locations that immediately abut the edge of Wolverhampton should be the preferred location to direct new housing development.

Object

Representation ID: 6714

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

In light of RH’s comments about how an unmet arising within the HMA is to be met, specifically the contribution that South Staffordshire is making to address this, we do not consider that the spatial strategy development is sound.

RH consider that the land at Castlecroft Farm is one such location where new development could be accommodated in close proximity to the existing urban area that could meet needs arising outside of the District. In sustainability terms this is considered a more appropriate approach as it would be meeting the needs of where it was arising. As such, RH do not consider that the spatial strategy is sound as the policy is not positively prepared as the unmet need is not being met where it is practical to do so and thereby a more sustainable option is available as opposed to the that is currently proposed. Furthermore, we do not consider that the policy is effective as it is not based on effective joint working on cross boundary strategic matters.

The Council, therefore, appear willing to direct growth to the edge of Stafford which is outside of the HMA that South Staffordshire sits purely on the basis that the land is not in the Green Belt.