Publication Plan April 2024

Object

Representation ID: 6432

Received: 30/05/2024

Respondent: Hampton Oak Ltd

Agent: Vista Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Given that accommodating the unmet need of neighbouring authorities underpins the soundness tests of positive preparation and local plan effectiveness, the significant reduction (by 3,360 homes) in the plan’s contribution to the GBBCHMA’s unmet need (in comparison to the last submission version of the plan) can at best be described as illogical and renders to plan unsound.

The duty to cooperate prevails and as such, we assert that there remains a need for this plan to play its part in addressing this growing unmet HMA need through the allocation of more homes, which for this predominately Green Belt authority, must mean making the most of sustainable growth opportunities in the few non Green Belt locations within the district. The proposed 640 home contribution to the GBBCHMA represents a 2% contribution to the overall ‘best case’ c.35,000 homes shortfall to 2031. In our view, and particularly given the strong spatial connection that South Staffs has with the Black Country, the plan needs to deliver a much higher percentage contribution.

Object

Representation ID: 6433

Received: 30/05/2024

Respondent: Hampton Oak Ltd

Agent: Vista Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Spatial strategy proposes less allocations in Tier 3 settlements than the previous publication version of the plan.

It retains a significant reliance on windfall housing delivery without any realistic prospect of that coming forward due to the Green Belt nature of the district. The reality is that the only windfall development (beyond single plots or conversions) that will be possible will be rural exception proposals. The delivery of c. 600 homes as predominantly rural exception schemes seems highly unrealistic. Tier 1 settlements account for over 60% of the total housing supply and over 95% of the new housing allocations. Any delays in the delivery of these sites will inevitably have significant impacts on the ability for the council to maintain a 5 year supply of housing land. As such, it is considered that this is another compelling reason for the spatial strategy to look to the lower tier settlements for further housing growth through allocation.

Policy requires redrafting to ensure that the delivery of the homes presently identified for allocation through the Local Plan review should be much greater having full regard to the requirement to increase the contribution towards the unmet needs arising from GBBCHMA overspill and the need to eliminate the uncertainty of windfall reliance, particularly where it forms such a significant proportion of total supply.

Object

Representation ID: 6434

Received: 30/05/2024

Respondent: Hampton Oak Ltd

Agent: Vista Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We assert that the Fenton House Lane site, to the immediate north of Wheaton Aston, which by the council’s own evidence is a suitable site within this settlement to deliver growth can assist the council in proving a greater number of homes within the district through a proportionate extension in a non-Green Belt location.

In the Regulation 18 Preferred Options version of the plan, the land to the immediate north west of the Site (SHLAA ref 610) was allocated for residential development. Thus, it is reasonable to conclude that there are no technical constraints to its delivery. The same conclusions can be drawn in respect of the Fenton House Lane site.

The Housing Site Selection Topic Paper 2024 finds no show stopping constraints, recognising that there is moderate to high landscape sensitivity but that is no different to the majority of land in this broad location. Ultimately, the site fails to secure an allocation because Wheaton Aston as a Tier 3 settlement has not been identified (in this revised version of the plan) for any housing growth beyond the existing commitments and allocations.