Publication Plan April 2024

Comment

Representation ID: 6715

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

It is noted that in the Council’s Duty to Cooperate paper (April 2024) which other Councils the Council confirm it intends to engage with through the plan-making process. This includes both Dudley and Wolverhampton Councils although Sandwell is omitted. The list also excludes other Councils that are in the same HMA, of which there are 13 in total, such as Birmingham, Solihull, Lichfield and Stratford-upon-Avon. We consider it imperative that the Council seeks to engage with these other authorities in the same HMA as the Council if the housing need is going to be met. Furthermore, the Council should not be selective about which houses or need in the HMA is choses to assist with meeting.

Object

Representation ID: 6716

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Council confirms that in the First Publication Plan it had proposed to make 4,000 dwellings available to contribute to meeting the unmet need arising in the wider HMA, which Redrow considered was insufficient at the previous Regulation 19 consultation. However, the Council has now changed its Local Plan strategy and is now only proposing to make a contribution of 640 dwellings to meet the needs arising in the wider HMA.

It is not clear whether the Council proposes to maintain its signature to the Statement of Common Ground that it signed previously. Since it was signed in 2022, the Black Country authorities have abandoned the preparation of the Black Country Plan and proceeded to prepare individual Local Plans.

Notwithstanding that a token of contribution to meeting this unmet of the wider HMA is proposed, this will make no difference in addressing the 110,000 dwelling shortfall that exists. As it stands, we do not consider that the Duty to Cooperate has been fully discharged and that an appropriate strategy or level of agreement has been reached between the HMA authorities as to how the level of unmet will be met across the HMA.

Object

Representation ID: 6718

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The Council consider that there are exceptional circumstances to amend the Green Belt boundaries in order to meet its own needs but that these exceptional circumstances do not extend to meeting the needs in the wider HMA. RH consider that there is also sufficient justification for reviewing the wider Green Belt boundaries in order to meet additional development needs arising elsewhere.

Green Belt land is being released to meet employment land requirements arising both in South Staffordshire but also the wider HMA. The review of Green Belt boundaries is, therefore, being selectively applied notwithstanding that there are considered to be exceptional circumstances in doing so to meet the District’s own needs.

The Council has, therefore, undertaken a review of the Green Belt proposing to amend boundaries to meet its development needs. The extent of the Green Belt changes are such that are only intended to assist with meeting the housing needs of the District and do not extend to the unmet housing needs arising in the HMA.

RH object to the selective application of exceptional circumstances to justify a partial review of Green Belt boundaries where they meet the Council’s needs only and not those of the wider HMA notwithstanding that the scale of unmet need is significant.

Support

Representation ID: 6721

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH generally support the vision set out in terms of addressing the climate emergency and creating beautiful and thriving new places in which people can live, work and enjoy leisure activities. We support Strategic Objective 3 that seeks to provide housing to meet the needs of different groups in the community, including a good range of market and affordable housing of varying sizes and tenures to meet different requirements.

Object

Representation ID: 6723

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RH considers that the policy exceeds the current level of building regulations for energy efficiency and would therefore present an onerous requirement on developers to go beyond what is currently required. In principle RH support the move to more energy efficient homes we do not consider that the application of this policy is the appropriate route to achieve this.
We do not consider the policy is sound as it is not consistent with national policy and represents a duplication of control over matters that building regulations currently address. RH would wish to see the policy deleted or significantly reworded.

Object

Representation ID: 6724

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

In principle, we do not have any specific objections against the sites that have been chosen and we consider that all of them would be required in order to meet the housing requirement that has been identified. Whilst RH do not object to specific sites, we do object to the omission of the land at Castlecroft Farm as a proposed housing allocation in the Plan. Our objection is based on the fact that we consider that a significantly larger number of dwellings is required to meet the unmet needs arising in the HMA as had previously been proposed by the Council.

Full details of the site at Castlecroft Farm can be found in the full representation.

To address RH’s concerns the inclusion of the site as a draft allocation for 600 dwellings would address the soundness issue.