Publication Plan April 2024

Comment

Representation ID: 6467

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Disagree with Strategic Objective 1 in its aim to require “compensatory improvement to the environmental quality and accessibility of the remaining Green Belt”. We question how this will be mandated and what level of viability testing has been undertaken to ensure that development is not stymied due to the requirement.

Agree with Strategic Objectives 2, 3, 4, 5, 6, 7, 8 and 13.

Agree with Strategic Objective 9 and 10 However, it is also here that meeting the Duty to Cooperate is essential in identifying and delivering cross-boundary infrastructure which would facilitate unmet housing need from neighbouring authorities.

Strategic Objective 11 and 12 are laudable, however it is our view that the building regulations regime is the best way to set standards for energy performance in new buildings.

Object

Representation ID: 6468

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We agree that Green Belt development should enhance access to outdoor sport and recreation, enhance landscape, visual amenity and biodiversity – as indeed many proposals within the Green Belt are capable of (including the subject site). We also agree with DS1 that where Very Special Circumstances can be demonstrated with regards to inappropriateness, planning permission should be granted. However, this is a difficult hurdle to get over and the most appropriate way to deliver large scale new housing is through a positively prepared local plan.

We do not agree that affordable housing to meet local community needs should be “limited”, considering the significant and worsening affordable housing shortage within South Staffordshire, as demonstrated by the c.1,500 households on its social housing waiting list. South Staffordshire should look to encourage as many forms of affordable housing delivery as possible, including via Rural Exception Sites.

Object

Representation ID: 6469

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Despite paragraphs 147 and 148 of the latest NPPF, we disagree that Green Belt proposals must require “compensatory improvements” in order to gain planning consent. We instead agree with motion set by paragraph 57 that requires contributions to be necessary to make development acceptable in planning terms, directly related to the development and related in scale and kind.

We further question whether these further obligations have been tested within South Staffordshire’s evidence base with regards to financial viability. The cost of these compensatory improvements must be tested against existing assumptions for developer contributions, to ensure financial viability

Object

Representation ID: 6470

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The unmet need identified in paragraphs 5.9 to 5.11 attributed to the authorities in the Black Country and Birmingham have as much as 106,653 homes worth of unmet need (78,415 from Birmingham and 28,643 from the Black Country). Wolverhampton and Dudley alone account for over 12,000 homes as unmet need. It appears that South Staffordshire have all but abandoned their previous approach of meeting c4,000 units of this unmet need via the Duty to Cooperate, and since then very little has changed to warrant this new approach.

Policy DS4 should make clear that the delivery of 4,726 homes is a minimum target and should encourage sustainable development on all sites where all other development plan policies are met.

Object

Representation ID: 6471

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We believe that the spatial strategy should allocate potential housing sites on the urban fringes of the Black Country which already benefit from good sustainable transport links and higher order services such as surgeries, schools and shops. There are also significant employment opportunities throughout the Black Country that simply do not exist within the rural areas of South Staffordshire. We believe policy DS5 should encourage strategic development in urban fringe locations to extend existing larger settlements.

Object

Representation ID: 6472

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The housing allocations at Policy SA3 do not allocate any housing to urban edge sites, which would take advantage of existing services and transport infrastructure of neighbouring Black Country settlements. We do not agree with allocations over reliant on the tiered settlements of South Staffordshire as this completely ignores the fact that the authority is inter-dependent with the Black Country for employment, retail and educational opportunities and that meeting the needs of the Black Country will require the release of some Green Belt land within South Staffordshire: something that was acknowledged in the later iteration of the emerging Black Country Plan and the previous Reg 19 Local Plan for South Staffordshire published in 2022.

Regarding the site Land at Sandyfields Road, an allocation here would serve as a logical site to deliver unmet housing need arising from neighbouring authorities of Dudley and Wolverhampton. The site can deliver a good mix of housing in accordance with the density and type prescribed within the proposed policies, whilst delivering green infrastructure and other public benefits. We urge the council to cooperate with neighbouring authorities now and we urge the council to consider cross-boundary working on potential housing. We hope that the council gives further consideration to our client’s site at Sandyfields Road, and it should be included as a housing allocation within the Submission Plan.

Comment

Representation ID: 6473

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

We agree with Policy HC1 and the need to deliver a strong housing mix that meets the needs of a variety of different households, regarding bedroom numbers and mix. However, we would urge flexibility in its application where there are clear vagaries in the housing market throughout the authority.

Support

Representation ID: 6474

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

Agree with Policy HC2, that development should seek to make efficient use of land by achieving a least the minimum density of 35 dwellings per ha, and in many cases should exceed this minimum density, to encourage the delivery of more housing across South Staffordshire. However, this should not be at odds with prevailing character, nor the need to accommodate 10% BNG for instance.

Support

Representation ID: 6475

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

We agree with Policy HC3 that 30% affordable housing should be delivered at the tenure mix as described within the policy. On small sites of less than c.10 units, specific wording should be added to allow a given lower end threshold for on-site affordable housing, below which an off-site payment in lieu may be provided.

Support

Representation ID: 6476

Received: 30/05/2024

Respondent: Seven Capital

Agent: RCA Regeneration

We agree with Policy HC4 & HC5 and the need to provide homes for older people and those with special housing requirements.