Publication Plan November 2022

Comment

Representation ID: 4389

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the proposed spatial strategy to 2039 which recognises environmental capacity and seeks to make best use of existing infrastructure whilst recognising opportunities to delivery new infrastructure.

Bloor Homes supports the distribution of housing growth through the identification of strategic sites close to the Black Country and proportionate growth focused to the villages.

Bloor Homes notes the GBBCHMA Strategic Growth Study recommended the broad location to the west of the Black Country is capable of accommodating dispersed housing growth of between 500 and 2,500 dwellings. The emerging spatial development strategy only seeks to allocate one site in this broad location for approximately 390 dwellings. This is below the 500 dwelling lower limit
for this broad location as identified within the Strategic Growth Study.

Comment

Representation ID: 4390

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes is promoting Land at The Straits (Site Ref: 560 and 566) for residential development. These two sites, that comprise Land at The Straits, are suitable, available and achievable and should be considered if it is determined through the Examination in Public that omission sites are necessary to make the Local Plan sound.

The information contained within this representation, read in conjunction with the appended illustrative concept plan and the Council’s published evidence base demonstrates that Land at The Straits is a suitable and deliverable site for residential development, subject to its release from the Green Belt.
There are no existing uses that would require relocation and no issues of contamination that would require remediation. Many of the potential impacts of the development of the site can be mitigated through design and in many casesa positive outcome can be achieved.

It is submitted that Land at The Straits represents a sound strategic housing allocation and should be considered if, through the Examination in Public
process, omission sites are required to make the Local Plan sound.

Object

Representation ID: 4393

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At present the SHMA assumes that the projected growth of the working age population in South Staffordshire will grow by 6,618 people between 2020-2040. Whilst this is in excess of the forecast jobs growth outlined in the EDNA, Bloor Homes is concerned that the EDNA fails to realistically consider additional jobs created at WMI. Further consideration should therefore be given to whether the minimum local housing need figure derived from the standard method would support the necessary growth in the working age population to create a balanced community within South Staffordshire to support such jobs growth, even taking into consideration the 4,000 additional homes to meet unmet needs in the wider housing market area
See supporting representations for further details.

Object

Representation ID: 4397

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Bloor Homes would wish to raise concerns that the proposed direction of travel appears overly prescriptive with all market housing proposals to include 70% of properties to comprise three bedrooms or less.
The SHMA utilises a long-term balancing housing market (LTBHM) model to determine future demand for housing. Bloor Homes would question whether this model does actually determine demand rather than need. The demand is often for a larger open market property than a household may need to provide additional flexibility e.g. working from home. Therefore, the approach to capping the percentage of larger homes, particularly open market homes, fails to provide a good level of flexibility to allow for changing market signals across the plan period or to address varying needs in different locations within the District
See supporting representations for further details.

Object

Representation ID: 4401

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered that a specific requirement for bungalows is not appropriate if instead the Council pursues a policy of requiring 100% of all homes to meet optional M4(2) requirements.
The Government has consulted on raising accessibility standards for new homes but the requirement for all homes to meet M4(2) standards is yet to be mandated. If the Council intends to pursue a policy in respect of M4(2) standards this must be evidenced. Bloor Homes considers that whilst there may be justification for implementing optional M4(2) standards, the 100% requirement is not justified.
See supporting representations for further details.

Object

Representation ID: 4402

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.
See supporting representations for further details.

Object

Representation ID: 4410

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Concern is raised that the emerging requirements appear to provide no flexibility with regards to a site’s context.
See supporting representations for further details.

Object

Representation ID: 4411

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

A locally specific CO2 reduction requirement is unnecessary and without justification for deviation from Government emerging Future Homes standards to be considered through building regulations
See supporting representations for further details.

Support

Representation ID: 4413

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes has worked collaboratively with the Council, the City of Wolverhampton City Council, other stakeholders, infrastructure providers and the Council’s masterplanning consultants in developing a shared Vision and set of Objectives for the new neighbourhood east of Bilbrook.
In respect of Land East of Bilbrook, the proposed strategic housing allocation, provides an opportunity to deliver up to 800 dwellings alongside new infrastructure as identified in Policy SA1. The key infrastructure and design requirements set out in Policy SA1 are supported by Bloor Homes.
Bloor Homes’ land interests extend to all land within the proposed East of Bilbrook allocation, with agreements in place between the landowners and Bloor Homes, providing confidence that a comprehensive and co-ordinated approach to development can be achieved in its delivery. Bloor Homes can demonstrate the site is suitable, available and achievable, with further information provided within Chapter 12 of this representation (see attachments) and the Development Framework document attached at Appendix 2 (see attachments).

Comment

Representation ID: 4414

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

In terms of the strategic approach to the Green Belt there is an acknowledgement within the Local Plan that there needs to be changes to the Green Belt boundary to accommodate growth requirements within the Plan period. It is agreed that Green Belt release is necessary to deliver a sustainable
spatial strategy.

Bloor Homes agrees that exceptional circumstances exist for Green Belt release within the District to allow for sustainable development within the plan period.

The Publication Plan recognises that the character of South Staffordshire is directly influenced by the fact that around 80% of the District lies within the West Midlands Green Belt. The rural nature of the District also results in a lack of brownfield opportunities to meet any future housing needs beyond the proposed plan period.