Publication Plan April 2024

Object

Representation ID: 6180

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

The NPPF clearly sets out the role of the Green Belt and what type of development should be allowed.

We do not consider the Local Plan should include any Green Belt related policy that would result in increased restrictions on the Green Belt in excess of national policy requirements.

Further guidance on acceptable types of development in the Green Belt is welcome.

Object

Representation ID: 6181

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Further guidance is required in connection to the amount of compensation required and how that will be calculated. Appendix B- F should be amended to make clear which sites this proposed policy could potentially apply to.

Object

Representation ID: 6182

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

The plan target has reduced significantly since the previous 2022 Publication Plan. We are aware of changes to the NPPF 2023 in relation to Green Belt releases.It does not imply that no Green Belt boundary changes should be made, or this should be significantly reduced from previous consultation documents as Green Belt boundary changes should not have been taken lightly.

The most position statement across the Great Birmingham HMA confirms there is still a significant shortfall. We consider additional land/sites is required to meet not only the needs of South Staffordshire in the form of a buffer to the housing figures in the event of both smaller allocated sites or larger SUE sites not delivering as expected but also to assist neighbouring areas as part of the Duty to Co-operate.

We are disappointed to see the removal of site 079 Land at Kiddemore Green Road. The site would not only provide much needed family housing but also a range of housing including bungalows and care facilities. The site would also accommodate car parking facilities to assist with the lack of parking in the centre of the village. We therefore consider this site provides a number of benefits that would justify exceptional circumstances to validate its retention in the plan as a proposed allocation.

Object

Representation ID: 6183

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Do not agree with the plan being too prescriptive which could potentially hinder the delivery of sites.The requirement that 70% of properties comprise of three-bedrooms or less is restrictive and does not afford the flexibility expected by NPPF Paragraph 63 in order to meet the need to provide for a range of size, type, and tenure for different groups.

Reference that "the market housing must include a minimum of 70% of properties with 3 bedrooms or less" should be removed from the policy.

Object

Representation ID: 6184

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The use of the term 'major residential development' in this context requires a definition to save confusion as to what size of development affordable housing becomes a requirement, it is presumed to be the same as that within the NPPF Glossary.

It is important for policy set out in the Local Plan and any forthcoming SPDs shows a level of flexibility as the viability of a site needs to be assessed at the time of the application in addition to at the time of the adoption of the Local Plan to ensure developments can continue despite factors which could impact viability.

Object

Representation ID: 6186

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy wording does not define 'older people', so it is unclear as to exactly who this Policy is targeting or who would be eligible to occupy such dwellings.

It stipulates that all major development should provide bungalows, age restricted single storey accommodation such as flats and maisonettes, sheltered/retirement living and extra care housing with care and other supported living.

It is unclear if the policy is requiring ALL of the above-mentioned housing types on all sites or whether a site should include one or some of the housing.If it is the former, we consider this to be overly prescriptive of enforcing every major site to accommodate all housing types in addition to all other policy requirements such as those set out within policies HC 1,2,3,5 and 8 in addition to open space needs and biodiversity net gain requirements etc.

Site 079 Kiddemore Green Road would provide a percentage of bungalows and retirement living in a sustainable location and considering this it should be retained as an allocation.

Object

Representation ID: 6187

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Further clarification is required on how policies HC4 and HC5 defer and what is the criteria for when they would be applied to a site and planning application as policy HC4 wording suggests it should be all major development sites whereas HC5 suggests there are a number of criterion to be met before the requirement for specialist housing to be integrated on a site.

Object

Representation ID: 6188

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Currently, there is little information available in connection to what will be included in the self-build register (number of sites required, size of property preferred, location etc for example) to know how it could potentially impact proposed sites.

Whilst we generally supports the concept of self-build/custom housing, we do not consider providing them as part of a larger housing development is always the most appropriate solution because self/custom builders are more likely to want a more bespoke location/setting. Smaller dedicated self/custom sites are therefore a more appropriate answer.

We support the position that should a proposed custom self-build plot not be sold after 12 months following active marketing, then the developer will be permitted to build out the plan as a standard property type.

Comment

Representation ID: 6189

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

The introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance is supported. However, again we do not consider the policy should be overly prescriptive to the extent where it is restrictive and prevents each scheme having individual flair and taking into consider the local characteristics.

Support

Representation ID: 6190

Received: 30/05/2024

Respondent: St Mary's Presbytery and The Archdiocese of Birmingham

Agent: First City Limited

We support the inclusion of guidance in connection to the space about dwelling amounts and inclusion of the statement “Flexibility may be applied in relation to the above standard, depending upon the site orientation and the individual merits of the development proposal.” In relation to both the distance between dwellings and the amount of external space as this can be significantly impacted by the layout of sites and the orientation of dwellings.

We consider it also important to note that some properties such as age restricted single storey accommodation (bungalows) including sheltered/retirement living in the form of bungalows or maisonettes should have smaller, more manageable gardens.