Publication Plan April 2024

Object

Representation ID: 6376

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Districts own housing requirement based on the standard method of 4,086 homes is not justified. We consider that there are exceptional circumstances which justify an alternative approach to assessing housing needs. The economic prosperity of the district is being guided by the economic growth scenario considered in the South Staffordshire Economic Development Needs Assessment Update (2024) (EDNA).The EDNA notes how the number of jobs generated by the growth scenario is significantly higher than the number of jobs generated by the local housing need figure. The district already has very significant gross commuting flows and we consider these will be exacerbated by the local housing need figure. On this basis, it justified to align jobs and housing growth which would have a positive effect of reducing commuting flows. The housing requirement should be increased to align with economic growth and Dunston Garden Village should be allocated as a new settlement.

The 640-home contribution towards the unmet need of the GBBCHMA is predicated on limiting Green Belt release to Tier 1 settlements. The contribution has not been informed by effective joint working on cross-boundary strategic matters and has not been informed by agreements with the GBBCHMA. Furthermore, the contribution is not justified.

The Council have also chosen to alter the Green Belt boundaries in the Publication Plan as there are exceptional circumstances to do so including assisting with unmet housing needs. The updates to the NPPF do not justify a reduction in the contribution towards unmet needs. There is also no evidence to suggest that Strategic Growth Study 2018 is no longer up to date, but irrespective, there is still a significant unmet housing need. Evidence points towards a worsening situation in terms of unmet housing needs which have increased, not decreased, since the first Publication Plan.The 640-home contribution will do little to assist the unmet needs and the reduction in the contribution largely defers the issue to other authorities within the GBBCHMA who are not as far advanced in their plan-making process.

There is currently a 10% buffer in the supply, whereas the first Publication Plan had a buffer of 13% which was considered necessary for soundness. No justification has been provided for reducing the buffer and we consider that is should at least remain at 13%.

Object to Policy DS6 from the 2022 Publication Plan that set out a longer term aspiration for a new settlement along the A449 corridor. it was entirely appropriate for the first Publication Plan to set the direction of growth beyond the plan period. Indeed, that approach is supported by national policy in the context of identifying safeguarded land, where necessary, to meet longer-term development needs stretching well beyond the plan period. It was also entirely appropriate for that growth be directed to the transport corridor given the findings of the Strategic Growth Study 2018. Nothing has changed since the first Publication Plan to indicate that Policy DS6 was unsound.The topic paper finds that the settlement options do not perform so well as to change the preferred spatial housing strategy. However, planning for the longer-term development needs beyond the plan period would not alter the preferred spatial housing strategy for the plan period. Supporting documents demonstrate that the highways and access to services issues in the housing sit assessment topic paper can be addressed.

This policy should have a clear requirement within it to ensure the Council undertake regular annual monitoring of housing delivery and set out what actions will be taken if housing delivery is slow to progress or drops below a five-year supply, which in our view should trigger a full review of the Local Plan. This will be critical if no further unmet needs from the GBBCHMA are to be met and no additional allocations are made.

Object

Representation ID: 6377

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lack of flexibility in the policy in terms of requiring &0% of properties to be 3 bedrooms or less is not justfied. The most suitable and appropriate manner to assess housing mix is by determination of the market at the time of submission of a planning application, rather than at the point of adoption of the Local Plan. Furthermore, needs and demand will vary from area to area and site to site. Indeed, there may be instances when a site is wholly suitable for a different housing mix than currently prescribed by the policy.

Object

Representation ID: 6378

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the prescribed split between the tenures, we do not consider that the lack of flexibility within this part of the policy is justified.Different proportions of social rent and shared ownership should be allowed to come forward, based on the latest evidence of need at the time of making a planning application. The shared ownership definition should also be broadened so that it encapsulated all other affordable routes to home ownership in line with the NPPF definition.

Object

Representation ID: 6379

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We do not consider that this policy is justified in terms of the requirement for 100% of homes to be M4(2).

The figure for M4(2) homes in the Housing Market Assessment Update does not take account of the accessibility and adaptability of existing housing stock, and the topic paper also notes that it is not possible to demonstrate this, owing to the lack of data available.

Object

Representation ID: 6380

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We do not consider that this part of the policy is justified.The need for self and custom build plots is relatively low. The blanket approach of the policy, which is not necessary owing to the low demand, is likely to frustrate the delivery of regular housing particularly for volume housebuilders whose approach may not always be compatible with self-building.

Object

Representation ID: 6381

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The documents referenced under Criteria a) are material considerations and should, if necessary, be listed as key documents beneath the policy rather than in the policy itself since their content are not being scrutinised as part of this Local Plan process.

Under Criteria c) and the requirement to incorporate tree lined streets, An element of flexibility needs to be drafted into the wording of the policy to reflect national policy and take account of the fact that there may be specific cases why this would be inappropriate.

Criteria I should be removed as it is unnecessary duplication with Policy HC1.

Object

Representation ID: 6382

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Internal Space Standards Topic Paper (2024) notes that not all property types delivered since the optional standard was introduced meet the standard. This does not demonstrate the need for the policy. What it demonstrates is that these property types have been deemed acceptable in the past, all matters considered. The topic paper also notes that Registered Providers have in the past declined invitations to bid for affordable homes, due to their design and lack of sufficient internal space. However, a policy which requires all new homes to meet the standard is not necessary to address that issue, as clearly not all homes in the district will be delivered by Registered Providers.

Object

Representation ID: 6383

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We note that the Future Housing Growth & Playing Pitch Requirements Topic Paper (2024) identifies current and projected shortfalls in provision. However, this may not necessarily be the case in the future, particularly when the shortfalls are minimal for the most part.

We consider that the policy needs rewording so that it requires a contribution only when it is demonstrably necessary, so that it is consistent with national policy and meets the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010.

Object

Representation ID: 6384

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy should be reworded so that this is clear which developments are exempt from the requirements, in line with The Biodiversity Gain Requirements (Exemptions) Regulations 2024. The policy also says that proposals must demonstrate the measurement of biodiversity net gain through the submission of the biodiversity metric. However, the post-development habitat value need only be demonstrated through the biodiversity metric after approval. The policy should be reworded so it is clear what information needs to be submitted and when, in line with the requirement of the Environment Act 2021 as inserted into the Town and Country Planning Act 1990.

Object

Representation ID: 6385

Received: 31/05/2024

Respondent: BDW Trading Limited

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As noted under our comments to Policy DS4 there must be a policy commitment within the Local Plan to undertake this monitoring in light of the fact that it is no longer a legal requirement for Council’s to undertake this. The plans also says that the monitoring framework will play an integral role in providing an understanding of whether a review of the Local Plan is needed. However, there is a notable omission of any trigger points within the monitoring framework that would prompt the requirement for a Local Plan review. As such, we do consider that the monitoring framework will be ineffective. To address this, the monitoring framework needs to include trigger points for a review of the Local Plan, for example, if housing delivery falls below a certain level.